We respect your privacy and are committed to protecting your personal information. ThisPrivacy Policy (“Policy”) applies to the access and use of Alibaba Cloud’s Smart Access Gateway application (“the App”) provided to you by the Alibaba Cloud entity listed in Section 8 (referred to as “we”, “our” or “Alibaba Cloud” hereinafter). This Privacy Policy explains how we collect and use your personal information in relation to the App.

The App is designed to provide our cloud service customers (i.e., registered user of Alibaba Cloud services, the “Customer”) a secure environment to connect its end users’ personal device to Customer’s private network at Alibaba Cloud. Any information collected or handled by Alibaba Cloud in such is processed on behalf of our Customer who controls the collection and use of such information. We do not have a direct relationship with the end users of our Customers. Where this is the case, end users should direct all privacy enquiries, such as any requests to access, correct, amend or delete personal information, to the Customer providing their services or products. We are not responsible for the privacy or security practices of our customers.

1. What personal information does the App collect and why?

The personal information that the App collects are:

a) Information for log-in purpose: ID and password set up by you, and other applicable authentication method(s);

b) Information for facilitating optimal connection: IP address;

c) Information for security and authentication purpose: IMEI of your personal device for installation and log-in of the App;

d) Information for troubleshooting and maintenance purpose: log information that is automatically generated through the usage of the App.

The information listed above are necessary for the use of the App. If you wish to withdraw your consent, you will not be able to utilize the App as it is designed for.

If we ask you to provide any other personal information not listed above, we will inform you the category of personal information that we need and the purpose of processing your personal information.

In general, we will use the personal information we collect from you only for the purposes described in this Policy or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as for statistical purposes) if and where this is permitted by applicable data protection laws.

2. Who do we share your personal information with?

We may disclose your personal information to the following categories of third party data recipients:

a) to our group companies, third party services providers and business partners who provide products and/or services to us, or who otherwise process personal information for purposes that are described in this Policy or notified to you when we collect your personal information;

b) to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) to comply with any applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your life, body or property or those of any other person;

c) to any other person with your consent to the disclosure for the purpose that we will inform you before disclosure when getting your consent.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, this Policy will apply.

In case of mergers, acquisition or insolvency or bankruptcy, if the new company or organization will receive your personal information from us, we will request that the new company or organization that will continue to process your personal information in accordance with this Policy. If the new company or organization holding your personal information needs to use your personal information for purposes that are not disclosed in this Policy, the new company or organization will obtain your consent in accordance with applicable laws and regulations.

3. How do we keep your personal information secure?

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

4. What are the data retention/deletion policies?

We keep your personal information to enable your continued use of the App, for as long as it is required in order to fulfill the relevant purposes described in this Policy, as may be required by law (including for tax and accounting purposes), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we will delete your personal information in accordance with applicable law.

5. Your Data Subject Rights

You are entitled to any statutory data subject rights provided under applicable laws in relation to your personal information, such as to access, correct, update and delete your personal information collected and processed by us, to ask for a copy of any personal data that we collected from you, or to require us to cease the collection and processing of your personal information. You may exercise your rights by contacting us using the contact details provided in the section “How to contact us”.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with the required time period and other requirements under applicable data protection laws.

We would not be able to respond to your request in the following circumstances:

a) If response to the part or whole of your request will lead to the infringement of the life, body, property or other rights or interests of you or other third party;

b) If response to the part or whole of your request will seriously interfere our business operation;

c) If response to the party or whole of your request will result in our failure to comply with applicable laws and regulations;

In case where we act as a processor, we have no direct relationship with the individuals whose personal data we process. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Alibaba Cloud’s client (the data controller).

6. Updates of this Policy

We may update this Policy from time to time in response to changing legal, technology or business developments. When we update the Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes of the Policy if and where this is required by applicable data protection laws.

You can see when this Policy was last updated by checking the “Version” date displayed at the top of this Policy.

7. How to contact us?

If you have any questions regarding this Privacy Policy or if you wish to exercise any of these or other rights you may have under applicable law in relation to your personal data, you may send your request in writing to the following contact and address:

  • European Economic Area (EEA)

    For individuals in the EEA, and/or in relation to processing conducted by or on behalf of Alibaba.com (Europe) Limited, please contact:

    Attention: Data Protection Officer

    c/o Alibaba.com (Europe) Limited, 3rd Floor, Davidson Building, 5 Southampton Street, London, England, WC2E 7HA, United Kingdom

    E-mail address: intlcompliance@service.aliyun.com

    If Alibaba.com (Europe) Limited is not the relevant “data controller” for the purposes of EEA data protection law, you will be directed to the relevant entity.

  • Outside the EEA

    In all other cases, please contact:

    Attention: General Counsel /Alibaba Cloud (Singapore) Private Limited, Legal Department, c/o 26/F, Tower One, Times Square, 1 Matheson Street, Causeway Bay, Hong Kong.

    E-mail address: intlcompliance@service.aliyun.com

    In addition to the addresses listed above, if you have a privacy or data use concern which has not been addressed to your satisfaction, you may contact our third party dispute resolution provider (free of charge) here.

    This Privacy Policy also contains links to third party websites. If you experience difficulties using these links, please contact us at intlcompliance@service.aliyun.com.

8. Alibaba Cloud Entities

The Alibaba Cloud legal entity that you are contracting with is Alibaba Cloud (Singapore) Private Limited if you are a resident in any jurisdiction outside of Europe, the United States of America, India, or Malaysia. If you are a resident within Europe, you are contracting with Alibaba.com (Europe) Limited. If you are a resident in the United States of America, you are contracting with Alibaba Cloud US LLC. If you are a resident within India, you are contracting with Alibaba Cloud (India) LLP. If you are a resident within Malaysia, you are contracting with Alibaba Cloud (Malaysia) Sdn. Bhd.