ModusLink Privacy Policy

ARTICLE 1 - PRIVACY STATEMENT

1. Introduction - T3 Micro, Inc., 228 Main Street, Suite 12, Venice, CA 90291 (hereinafter, the “Operator”) is committed to protect the privacy of the consumer and has taken adequate technical and organizational security measures to ensure that information which is obtained from the consumer will be secure and confidential.

2. Purposes of the collection and use of information

The information the Operator collects directly (or via its service provider acting as a data processor for the processing of orders), when the consumer orders a product includes the consumer’s name, email address, residing details and payment information (including but not limited to credit card number and expiration date of the credit card). This information enables the Operator to complete and process, via its service provider, the order of the consumer pursuant to the contract and/or keeps the consumer updated on the status of the order. The consumer may decide not to provide such information, but the consumer must recognize that by doing so, the Operator will not be able to process the order of the consumer. If the consumer explicitly agrees thereto, the Operator may also provide the information set forth above (excluding the payment information) gathered from the consumer to ModusLink B.V. in the form of various reports used to monitor usage of the web-site, viewing and traffic patterns, and other consumer behaviors, in accordance with the Cookies Policy.

The legal basis used by the Operator to implement the data processing are the following: (i) consumer consent, (ii) performance of the contract, (iii) compliance with a legal obligation to which the Operator is subject, or (iv) legitimate interests pursued by the Operator (eg. consumer profiling).

3. Protection of information - The Operator strives to ensure that every online communication with the consumer meets the Operator’s high standards of privacy and security by using a secure server with software that encrypts all of the consumer’s personal and confidential information before he or she sends it to the Operator. In addition, the Operator takes strong measures to protect all consumer data against unauthorized access.

4. Use of “cookies” - The Operator uses cookies which are small bites of information that are stored by the browser on the hard drive of a computer, subject to the consumer's consent. The cookies which the Operator uses, allows the Operator to recognize each returning consumer and their relevant information so that the consumer does not need to input the same information more than once. The Operator does not place any personally identifying confidential information in the consumer’s cookies. In addition, cookies are not used to access information entered on the secure server. This information can only be accessed when the consumer enters his or her name and order reference number. For more information on the use of cookies on the website, please see the Cookies Policy.

5. Sharing of your personal information - As noted above under paragraph 2 of this article, the Operator only shares consumer information obtained through its web-sites with T3 Micro in the form of various reports if the consumer explicitly agrees thereto, and with its service provider in relation to the ordering process. The Operator itself will not trade, sell or rent personal information of the consumer (such as name, address, phone number, or company name) to third parties without the consumer’s consent. The Operator also protects the consumer’s privacy by limiting employee access to and use of this data. The Operator may provide statistics to outside companies about the web-sites, consumer traffic and viewing patterns, including sales and related site information. However, such information is compiled into a statistical aggregate, which does not include any personally identifying (whether directly or indirectly) information.

In certain cases and for order and payment processing purposes, the Operator may transfer personal information identified in paragraph 2 of this article to third parties which are located outside of the European Economic Area, for example in the USA. Payment Processing Systems of Visa/MasterCard for example are based in the USA.

The Operator entered into contractual measures based on the European Commission model clauses with the data recipients located outside the European Economic Area to ensure that all personal data transferred receive an adequate level of data protection within the meaning of the GDPR and that appropriate technical and organizational security measures are in place to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

6. Changes to this privacy policy - The Operator reserves the right to change the terms of this privacy policy at any time. When changes are made, the Operator will revise the "last updated" date at the top of the policy. If there are material changes to this policy or in how the Operator will use the personal information of the consumer, the Operator will notify the consumer by prominently posting a notice of such changes sufficiently in advance to allow said consumer to discontinue using the website or cancel his or her account (where relevant) if s/he does not agree with these changes. The Operator encourages in any event all consumers to review this policy whenever they visit the site.

7. Release of information for legal reasons - The Operator may release information concerning the consumer’s use of the website as required by law and when the Operator believes in good faith that such release is appropriate to protect the Operator’s rights and/or comply with a judicial proceeding, court order or legal process served on the Operator or the website.

8. Your Rights - Regarding the processing of the consumer's personal data, the consumer has a right of access, right of rectification, right of erasure (or "right to be forgotten"), right of restriction of processing, right to object to processing and right to data portability as well as a right to lodge a complaint with a supervisory authority (the Dutch Data Protection Authority or "Autoriteit Persoonsgegevens").

To exercice such rights, the consumer shall contact:

Paul Mundt
Adaptant Solutions AG
Rosenheimer Strasse 139
81671 Munich

Phone: +49 89 904 101 30 - 2
E-mail: paul.mundt@adaptant.io

9. Data Retention - In accordance with Operator’s policies consumer personal data will be retained for a 5-year period, unless a longer period is required to comply with applicable data retention obligations or in order to fulfill regulatory requirements.

ARTICLE 2 - SECURITY

1. The Operator is concerned with the security of the data which is collected and has implemented appropriate technical and organizational measures to prevent unauthorized access to that information. These measures include policies, procedures and technical elements relating to data access controls. Such measures are reasonably designed to help protect the consumer’s personal information from loss, unauthorized access, disclosure, alteration or destruction. The Operator may use encryption, secure socket layer, firewalls, physical lock and key, internal restrictions, password protection and other security measures to help prevent unauthorized access to consumer’s personal information. In addition, the Operator uses standard security protocols and mechanisms to exchange the transmission of sensitive data.

2. In the event that consumer’s personal data is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable laws require notification, the Operator will notify the consumer of the breach. Notice will be given promptly, consistent with the legitimate needs of law enforcement and any measures necessary for the Operator or law enforcement to determine the scope of the breach and to assure or restore the integrity of the data system. The Operator may delay notification if the Operator or a law enforcement agency determines that the notification will obstruct a criminal investigation, unless and until the Operator or the law enforcement agency determines that notification will not compromise the criminal investigation.

Last Updated: November 28, 2018