PRIVACY POLICY FOR ADLINK

ADLINK Technology Inc. and its affiliates (“ADLINK”, “we”, “our”, or “us”) respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 26 June, 2023. We may change this policy from time to time by updating this page so please revisit and reread it periodically. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.THE DATA WE COLLECT ABOUT YOU:

1. Identity data – first and last name, user name
2. Contact data – address, email address and phone numbers
3. Technical data – Last login, internet protocol addresses, location
4. Usage data – Information on how you use the website
5. Marketing and Communications Data includes your preferences in receiving marketing from us.

IF YOU FAIL TO PROVIDE PERSONAL DATA:

2. HOW IS YOUR PERSONAL DATA COLLECTED: 

• Download products, Whitepapers, On Demand webcasts and register for a webcast
• Request a quote or more information or give feedback
• Create an account on the site
• Subscribe to services or publications 

3. HOW WE USE YOUR PERSONAL DATA

• Where we need to perform the agreement we are about to enter into or have entered into with you.
• Where we have your consent.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

5. MARKETING

6. CHANGE OF PURPOSE  

7. DISCLOSURES OF YOUR PERSONAL DATA

• External Third Parties and other organisations that processes data on our behalf.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• Distributors and business partners with whom we have established business relationships for the purpose of offering and selling our products and services. As part of these relationships, we may share the personal data of individuals whom we reasonably believe to be interested in our offerings, so that such distributors and partners may contact those individuals to assess interest and promote or sell our products and services. These parties may use the shared personal data solely for the joint purpose of marketing and selling ADLINK products and services, and are required to handle such data in compliance with all applicable personal data protection laws.

8. INTERNATIONAL TRANSFERS 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield https://www.privacyshield.gov/welcome, which requires them to provide similar protection to personal data shared between the Europe and the US.
   

9. DATA SECURITY

10. DATA RETENTION

11. YOUR LEGAL RIGHTS 

• Right of access – you have the right to request a copy of the information that we hold about you. 
• Right of rectification – you have a right to correct information that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the information we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the information we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to legal protections in respect of automated processing or profiling.
• Right to judicial review: in the event that the Company refuses your request for access. We will provide you with a reason why and you have the right to complain as outlined below.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (‘ICO’) on individuals’ rights under GDPR.

If you would like to exercise any of those rights, please:

• Email, call or write to us. All requests should be addressed to our Data Compliance Officer (details below)
• Let us have enough information to identify you
• Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• Let us know the information to which your request relates.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. CONTROLLER AND CONTACT 

ADLINK is the Controller for the purposes of this Privacy Policy.

If you have any questions about this Statement, would like to exercise any of your rights, or have any complaints you wish to discuss with us, please contact us using the following information:

ADLINK Technology Inc.
No. 66, Huaya 1st Rd., Guishan Dist., Taoyuan City 333411, Taiwan, R.O.C.
Tel: +886-3-216-5088
Fax: +886-3-328-5706
E-mail: privacy@adlinktech.com

In the event that you wish to make a complaint about how your personal information is being processed by the Company, or how any query or concern has been handled, you may, depending on your location, have the right to lodge a complaint with your local data protection authority. We would, however, appreciate the opportunity to address your concerns before you approach your local data protection authority.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

1. SCOPE

This California Privacy Notice only applies to you if you are a California resident.

This California Privacy Notice applies only to personal Information that we collect, but does not apply to personal information excluded from the scope of the California Privacy Law. By accessing or using our website, services, and/or submitting your information to us, you understand and consent to our collection and use of your personal information as described herein.

2. PERSONAL INFORMATION WE COLLECT

We may collect personal information about you when you provide it to us, when we observe it from your actions, when you authorize us to obtain it from third parties, when we obtain it from publicly available sources and for employment and human resource purposes. For example, we collect information that you provide to us when you use our website, purchase our products, apply for our job openings, or choose to receive news, updates, and alerts from us. In the preceding 12 months, we may have collected the following categories of personal information.

• Personal identifiers, including, but not limited to, real name, alias, postal address, unique personal identifier (including signature), online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
• Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including, but not limited to, physical characteristics or description, telephone number, state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
• Characteristics of protected classes or groups under state or federal law, including, but not limited to, age, ethnicity and race, marital status, gender, military or veteran status, nationality, citizenship, request for care leave for family or self, including pregnancy leave.
• Commercial information, including, but not limited to, records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
• Biometric information, including, but not limited to, as fingerprints, health, or medical data.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, web cookies, and information regarding a consumer’s interaction with an internet website application or advertisement.
• Geolocation data, including, but not limited to, information used to identify your device location.
• Audio and visual, including, but not limited to, audio, electronic, visual (pictures), thermal, olfactory, or similar information, such as call and video recordings.
• Employment information, including, but not limited to, work history, salary, years on the job, or current and prior employer.
• Education information, including, but not limited to, details about education, school, degrees earned, or information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
• Inferences drawn from any of the information identified above to create a profile about, for example, preferences and characteristics.

Some of the personal information listed above is considered sensitive personal information, including, but not limited to, social security/tax identification number, government identification number, passport number, driver’s license or state identification number, account log-in, precise geolocation, genetic data, financial account, debit card or credit card number in combination with any required security or access code, credentials to access an account, religious or philosophical beliefs, union membership, mail, email and text messages unless the business is the intended recipient of the communications, and racial or ethnic information when required to be collected by law.

3. SOURCES OF PERSONAL INFORMATION

We collect the personal information referenced above from sources which depend on our relationship with you. The information below lists the categories of sources from which we collect personal information.

• Directly from you or an individual acting on your behalf.
• Public records, information made available by federal, state, or local government entities.
• Service providers or other third parties that provide data to support offering technology products and services or employment activities such as fraud prevention, completing transactions, supporting our everyday operations, and workforce management.
• Our website.

4. REASONS FOR COLLECTION AND USE OF PERSONAL INFORMATION

We collect and use personal information about consumers for the following business or commercial purposes.

To offer and manage products and services, including but not limited to

• Fulfilling or meeting the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

For human resource management, including but not limited to

• Identifying and processing employment applicants, including conducting background checks, and verifying qualifications for employment.
• Administering employee services, including pay/compensation.
• Providing benefits to employees and dependents, including healthcare and retirement plans.
• Managing the health and safety of our employees.

To comply with laws and regulations, including but not limited to

• Applicable technology, business, and employment laws.
• For us to evaluate our compliance with employment.

To provide security, including but not limited to

• Using of security cameras to protect you and our employees when on our premises.
• Protecting your account if accessed by a new device and by a device in a new area.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.

To manage our business and enhance services, including but not limited to

• Using cookies to identify your access device.
• Performing accounting, auditing, and reporting activities and other internal management obligations.
• Complying with our policies, procedures, and contractual or legal obligations.
• Evaluating and engaging in business transactions.
• Contracting with service providers to perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
• Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
• Enabling or effecting, directly or indirectly, a commercial transaction.
• Managing leads and facilitating the sales of our products and services through our distributors and partners with whom we have a business relationship.

For marketing, including but not limited to

• Communicating with you regarding products and services offered by us, when in compliance with federal and state laws and regulations.
• Use of employee names or images for marketing materials.
• Undertaking internal research for technological development and demonstration. .

For other purposes for which we provide specific notice at the time the information is collected.

5. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information, including sensitive information, about consumers to third parties and service providers. The information below addresses practices in the prior 12 months. The details of the categories of information are detailed in the sections above.

Personal identifiers, including but not limited to

• Vendors and service providers to conduct day-to-day business, including to maintain or service accounts, provide customer service, process payments and transactions, verify customer information, and maintain websites and technology infrastructure.
• Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.
• Vendors and service providers to assist us in protecting your accounts and personal information.
• Government agencies and related third parties as required to comply with laws and regulations.
• Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.
• ADLINK may use the personal information consistent with this California Privacy Notice, federal, and state privacy laws.
• Business partners as part of a sale or transfer of business.
• Distributors and business partners with whom we have established business relationships for the purpose of offering and selling our products and services.

Personal information, including but not limited to

• Vendors and service providers to conduct day-to-day business, including to maintain or service accounts, provide customer service, process payments and transactions, verify customer information, and maintain websites, and technology infrastructure.
• Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.
• Vendors and service providers to assist us in protecting your accounts and personal information.
• Government agencies and related third parties as required to comply with laws and regulations.
• Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.
• ADLINK may use the personal information consistent with this California Privacy Notice, federal, and state privacy laws.

Characteristics of protected classes, including sensitive race and ethnicity information, including but not limited to

• Vendors and service providers to conduct day-to-day business, including to maintain or service accounts, provide customer service, process payments and transactions, verify customer information, and maintain websites and technology infrastructure.
• Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.
• Vendors and service providers to assist us in protecting your accounts and personal information.
• Government agencies and related third parties as required to comply with laws and regulations.
• Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.
• ADLINK may use the personal information consistent with this California Privacy Notice, federal, and state privacy laws.

Commercial information, including but not limited to

• Vendors and service providers to conduct day-to-day business, including to maintain or service accounts, provide customer service, process payments and transactions, verify customer information, and maintain websites and technology infrastructure.
• Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.
• Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.

Biometric information, including but not limited to

• Vendors and service providers to conduct day-to-day business, including to verify customer access to accounts.
• Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.

Internet or other electronic network activity information, including but not limited to

• A vendor may be used to help aggregate data that is not related to an individual.
• Vendors and service providers to assist us in protecting your accounts and personal information.

Geolocation data, including but not limited to

• Vendors and service providers to assist us in protecting your accounts and personal information, such as account monitoring sign-in activity.
• Vendors and service providers to assist with activities for human resources.

Audio and visual, including but not limited to

• Government agencies and related third parties as required if requested by law enforcement.
• Vendors and service providers to assist us in protecting your accounts and personal information.

Employment information, including but not limited to

• Vendors and service providers to conduct quality control activities.
• Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.
• Government agencies and related third parties as required to comply with laws and regulations.
• Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, accountants, and legal services.
• ADLINK may use the personal information consistent with this California Privacy Notice, federal, and state privacy laws.

Education information, including but not limited to

• Vendors and service providers to conduct quality control activities.
• Vendors and service providers to conduct activities for human resources related to potential, existing, and former employees.
• Government agencies and related third parties as required to comply with laws and regulations.
• Third parties to comply with legal and regulatory requirements or provide professional services to us, including auditors, , accountants, and legal services.
• ADLINK may use the personal information consistent with this California Privacy Notice, federal, and state privacy laws.

Inferences, including but not limited to

• ADLINK may use the personal information consistent with this California Privacy Notice, federal, and state privacy laws.

7. SHARE OR SALE OF PERSONAL INFORMATION

ADLINK does not knowingly sell, share or use personal information of consumers to third parties as contemplated by the California Privacy Law, including personal information of minors under 16 years of age.
 

8. RETENTION OF PERSONAL INFORMATION

ADLINK retains personal information (including sensitive personal information) for as long as needed or permitted with respect to the purpose(s) for which it was obtained and consistent with applicable law. In order to determine the appropriate retention period, we consider different criteria, including the sensitivity of the personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, the need for maintaining your personal information to provide you with products and services, and all applicable legal and regulatory requirements.
 

9. EXERCISING YOUR RIGHTS

As a California resident, you have rights related to the personal information we collect, use, and disclose.

• The right to request, free of charge, the following information covering the 12 months preceding your request:
  • The categories of personal information we collected about you.
  • The categories of sources from which the personal information was collected.
  • The purpose for collecting personal information.
  • The categories of third parties to whom we disclosed personal information.
  • The personal information that was disclosed and the purpose for disclosing the personal information, and
  • The specific pieces of personal and sensitive information we collected about you.
• The right to correct inaccurate information.
• The right to delete personal information, subject to certain exceptions.
• The right to non-discrimination in terms of price or service when you exercise a privacy right under California Privacy Law.

10. CONTACT US

Please reach out to us with any questions or concerns you may have about this California Privacy Notice and practices. If you would like to request a copy of our data records or to change, delete or restrict the use of or object to the processing of your personal data that you have previously provided to us, please contact us via email at privacy@adlinktech.com or via telephone at 1-800-966-5200. ADLINK acknowledges and respects our customers’ privacy and will comply with your request as soon as reasonably practicable and consistent with applicable law.

We reserve the right to update this California Privacy Notice from time to time and without further notice. If we make any material changes to the California Privacy Notice, we will notify you through a notice on our website. Continued use of our website or services following posting of such changes and your agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.