Alibaba Cloud International Website Privacy Policy

(Version: August, 2017)

This Privacy Policy applies to the access and use of the Alibaba Cloud International Website currently located at www.alibabacloud.com and the Alibaba Cloud International Marketplace Platform currently located at www.alibabacloud.com/marketplace (the “International Marketplace”) (collectively the “Alibaba Cloud Platform”), including, and the use by registered users of the Alibaba Cloud Platform of Alibaba Cloud products and services (the “Cloud Services”) provided by the Alibaba Cloud entity listed in Clause 2 of the Terms of Use (referred to as “we”, “our” or “Alibaba Cloud” hereinafter). Terms not defined in this Privacy Policy shall have the same meaning as in the Terms of Use of the Alibaba Cloud Platform.

This Privacy Policy sets out how we may collect, use, transfer, retain, secure and disclose your personal data and/or personal data about your customers or end users that you provide to us pursuant to your use of the Alibaba Cloud Platform and/or our Cloud Services, as well as other terms relating to data location. It also describes your choices regarding use, access and correction of your personal data. By accessing the Alibaba Cloud Platform or using the Cloud Services, you consent to the collection, use, transfer, retention and disclosure of such personal data in accordance with the terms of this Privacy Policy and agree to accept and be bound by the terms herein.
Many of our Cloud Services offered through the Alibaba Cloud Platform are intended for use by business organisations. You acknowledge and agree that if you use your organisation’s email address to register an account and purchase or use our Cloud Services, the owner of the domain associated with your organisation’s email address, and/or your organisation, may monitor or control your account with the Alibaba Cloud Platform and access, process, and/or control your personal data, as well as the contents of your communications and files. You acknowledge and agree that your organisation’s use of our Cloud Services may be subject to your organisation’s own rules or policies, and you shall direct all privacy enquiries relating to such rules or policies to your organisation’s administrators. We are not responsible for the privacy or security practices of your organisation.
Cloud Services may be used by our customers (i.e. registered users of Alibaba Cloud) to develop or host their own services and products for the customer’s end users. Any information collected or handled by Alibaba Cloud in such circumstance 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. End users should direct all privacy enquiries, such as any requests to access, correct, amend or delete personal information, to the Alibaba Cloud customer providing their services or products. We are not responsible for the privacy or security practices of our customers.

A. COLLECTION OF PERSONAL DATA

  1. If you are (i) an individual or (ii) a representative of a business organisation at the time you register to become a user of the Alibaba Cloud Platform and/or purchase Cloud Services, you may be asked to complete registration forms which require you to provide information such as your email address, mobile number, country, preferred language, name, contact address, and screen nick name. You may also provide to us additional optional contact information in your account profile, such as email address for sub-accounts, and additional contact phone numbers.

  2. We record and retain details of your activities (including any purchase or use of our product offerings and services) when you use the Alibaba Cloud Platform and/or certain Cloud Services for legal and/or business purposes. If you make purchases or otherwise transact online through the Alibaba Cloud Platform, we also collect information related to such transactions including, but not limited to, the types and specifications of the Cloud Services, pricing information, and any trade dispute/complaint records.

  3. When you contact our customer support, sales or other departments, we keep records of the communications.

  4. If you make online purchases for our Cloud Services through the Alibaba Cloud Platform, you may be required to provide information related to your payment instrument (such as credit cards), including information about your payment instrument organisation, your payment instrument number, the security code, and the expiration date of your payment instrument, directly to our payment service provider.

  5. Please note that it is mandatory for you to provide certain categories of data (as specified at the time of collection). In the event that you do not provide any or sufficient data marked as mandatory, we may not be able to complete the registration process or provide you with our Cloud Services.

  6. We also record and retain records of users’ buying and browsing activities on the Alibaba Cloud Platform, including but not limited to Internet Protocol (“IP”) addresses, browsing patterns and buying behavioural patterns. In addition, we automatically gather statistical information about our Alibaba Cloud Platform and visitors to our Alibaba Cloud Platform including, but not limited to, IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors.

  7. We may from time to time collect additional information from you (such as copies of identification documents) and obtain information about you from third parties in order to carry out risk control, fraud prevention and compliance procedures. For example, we may collect payment-related information from third parties and combine it with information we collect about you for the purpose of fraud prevention and risk control.

B. PURPOSES FOR THE COLLECTION, RETENTION, USE, DISCLOSURE AND TRANSFER OF PERSONAL DATA

If you provide any personal data to us, you consent (or shall have procured the relevant consent from your organisation, your end users, or relevant third parties) to our collection, retention, use and disclosure of that personal data for the following purposes:

  1. processing your registration as a user, providing you with an user ID for our Alibaba Cloud Platform and maintaining and managing your registration;
  2. providing you with customer service and responding to your queries, feedback, claims or disputes;
  3. providing the Cloud Services to you and/or your end users;
  4. processing your purchases and/or subscriptions on the International Marketplace;
  5. performing research or statistical analysis in order to improve the content and layout of our Alibaba Cloud Platform, to improve our product offerings and services;
  6. publishing any information voluntarily submitted by you (which may include, but is not limited to, a photograph or other personal data you provide) to our Alibaba Cloud Platform to be published on our Alibaba Cloud Platform through the publishing tools (such as our discussion forums);
  7. to comply with applicable law, legal process or lawful government request, or in respect of any claims or potential claims brought against us or our parent companies, shareholders, subsidiaries and affiliates;
  8. processing the personal data in accordance with your instructions;
  9. performing risk control, legal compliance and sanctions screening;
  10. performing screening and checks for unlawful, fraudulent, deceptive or malicious activities; and
  11. purposes which are reasonably related to the aforesaid.

Additional Purposes

Subject to obtaining your specific consent and/or where permitted by applicable law, we may use your name, phone number, residential address, email address and fax number (which may incorporate personal data) to provide notices, surveys, product alerts, communications and other marketing and promotional materials to you relating to goods and services offered by us on our Alibaba Cloud Platform.

C. DISCLOSURE OF PERSONAL DATA

  1. You agree that we may disclose your personal data to third party service providers engaged by us at our sole discretion to assist with providing you with our services (including providing customer services to you, contacting you regarding promotions products and services, performing risk control, fraud prevention and legal compliance procedures, and conducting payment processing services) (the “Third Party Service Providers”). These Third Party Service Providers may be located in Singapore or outside of Singapore, and are under a duty of confidentiality to us and are only permitted to use your personal data in connection with the purposes specified in Section B above, and not for their own purposes.
  2. You acknowledge that the International Marketplace enables you to purchase or subscribe to products and services (“Marketplace Products”) from companies other than Alibaba Cloud (“Third Party Vendors”), and should you purchase or subscribe to Marketplace Products offered by a Third Party Vendor, you agree that we may provide such Third Party Vendor with your personal data for the purposes of processing your purchase and/or subscriptions on the International Marketplace. Other than such personal data disclosed by Alibaba Cloud to the Third Party Vendor, in some cases you may be required to submit personal data to Third Party Vendors to use such Marketplace Products. This Privacy Policy does not apply to such collection, use or disclosure of personal data by Third Party Vendors. The privacy policies of Third Party Vendors may differ from ours, and we have no control over the information that you submit to those Third Party Vendors. You should read the relevant privacy policies for those Third Party Vendors before providing your information to such Third Party Vendors.
  3. You agree that we may disclose your personal data to other companies within the Alibaba Group for the purposes specified at Section B above.
  4. Any personal data supplied by you will be retained by us for legal and/or business purposes and will be accessible by our employees for or in relation to any of the purposes stated in Section B above, and will be retained and/or processed by any Third Party Service Providers engaged by us and third parties referred to in C.1 and C.2 above for or in relation to any of the purposes stated in Section B above.
  5. We may provide statistical information to third parties, but when we do so, we do not provide personally-identifying information without your permission.
  6. We have established and will establish relationships with other parties and websites to offer you the benefit of their products and services. We offer you access to these other parties and their websites either through the use of hyperlinks to these sites from our Alibaba Cloud Platform or through offering “co-branded” sites in which both we and other parties share the same uniform resource locator, domain name or pages within a domain name on the Internet, such as https://jp.alibabacloud.com/. In some cases you may be required to submit personal data to register or apply for products or services provided by such third parties or co-branded partners. This Privacy Policy does not apply to these third party sites or co-branded sites. The privacy policies of those other parties may differ from ours, and we have no control over the information that you submit to those third parties. You should read the relevant privacy policy for those third party sites and co-branded sites before responding to any offers, products or services advertised by those parties.
  7. Our website offers publicly accessible community forums. You acknowledge and agree that any information you provide in these areas may be accessed, read, collected, and used by others anywhere in the world. To request removal of your personal data from our community forums, contact us at intlcompliance@service.aliyun.com.

D. TRANSFER OF PERSONAL DATA

As part of providing you with the Cloud Services, we may need to transfer your personal data from your jurisdiction to an overseas jurisdiction. Recipients of the data in these jurisdictions may be subject to data privacy laws less protective or not equivalent to those in your own jurisdiction. You acknowledge and agree that any such overseas transfer or processing of your personal data is necessary to process and administer your customer account and to provide the Cloud Services (including providing customer services to you, contacting you regarding promotions, products and services, performing risk control, fraud prevention and legal compliance procedures, and conducting payment processing services) and you consent to the same. You further agree and consent to Alibaba Cloud processing your personal data on your behalf pursuant to this Privacy Policy and/or the Alibaba Cloud Membership Agreement and you appoint us to perform any such transfer of personal data to any such country and to store and process such personal data in order to provide our Cloud Services to you. You are solely responsible for ensuring compliance with any laws or regulatory obligations relating to personal data and/or privacy and your use of the same on or in connection with the Cloud Services, and you warrant that you have obtained all requisite consents from all relevant data subjects to permit the use of the same.

E. SECURITY MEASURES

  1. We use commercially reasonable endeavors to protect the personal data that you provide to us. We also employ several security techniques, including but not limited to the use of industry-standard Secure Socket Layer (SSL) encryption for transmission of personal data in registration information and payment information and the adoption of identity, credential and access management measures for transmission of such personal data to prevent security breaches and unauthorized access of personal data. We limit access to your personal data and other data to people who need to access to such data for their work.

  2. Nevertheless, no data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your personal data, we cannot guarantee the security of any personal data you transmit to us and you do so at your own risk. We cannot and do not guarantee security in connection with your use of the Alibaba Cloud Platform and our Cloud Services.

  3. We may retain your information for as long as your account is active or as needed in accordance with the purpose for which it was collected, to provide you services, to comply with our audit, finance and legal obligations, to resolve disputes, and enforce our agreements with you.

F. RIGHT TO ACCESS/CORRECT PERSONAL DATA; CONTACTING US

You have the right to request access to your personal data held by us (or on our behalf) and to request correction or deletion of such personal data. Additionally, upon request, we will provide you with information about whether we hold your personal information. You may contact us at intlcompliance@service.aliyun.com to request access, correction or deletion of your personal data. We will respond to your request within a reasonable timeframe. You may also have supplemental rights under applicable law in relation to your personal data.

You may receive e-newsletter from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you (or at your member profile).

If a minor (a person under the age of 18) has provided us with personal data without parental or guardian consent, the parent or guardian may contact us on the minor’s behalf to request that we cease any further collection, use and/or disclosure of the personal data relating to the relevant minor.

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: Legal Counsel

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.

G. COOKIES

  1. We and our partners use “cookies” and/or similar technologies to store specific information about you and track your visits to our Alibaba Cloud Platform. We may also use “cookies” to store specific information about your use of certain Cloud Services as part of its features and to facilitate or enhance your user experience of the relevant service. A “cookie” is a small amount of data that is sent to your browser and stored on your device’s hard drive. A cookie can be sent to your device’s hard drive only if you access our Alibaba Cloud Platform using a device. If you do not de-activate or erase the cookie, each time you use the same device to access our Alibaba Cloud Platform, our web servers will be notified of your visit to our Alibaba Cloud Platform and in turn we may have knowledge of your visit and the pattern of your usage.

  2. Generally, we use cookies to identify you and enable us to i) access your registration information so you do not have to re-enter it; ii) gather statistical information about usage by users; iii) research visiting patterns and help target advertisements based on user interests; iv) assist our partners to track user visits to the Alibaba Cloud Platform and process orders; v) track progress and participation in promotions; and iv) facilitate your use of any relevant Cloud Services which may involve the use of cookies. We partner with third parties to manage our advertising on other sites. Our third party partners may use cookies and/or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here, or if located in the European Union click here. Please note you will continue to receive generic ads.

  3. You can determine if and how a cookie will be accepted by configuring the browser which is installed in the computer you are using to access the Alibaba Cloud Platform. If you choose, you can change those configurations. You may be able to change your browser preferences or settings to reject all cookies, or are notified and can choose to consent each time a cookie is sent. If you reject all cookies by choosing the cookie-disabling function in your browser, you may be required to re-enter information on our Alibaba Cloud Platform more often and certain features of our Alibaba Cloud Platform may be unavailable.

  4. To manage Flash cookies, please click here.

  5. By accessing and using our Alibaba Cloud Platform and/or Cloud Services, and by accepting the cookies, you consent to the storage of cookies on your devices. You also consent to the access of such cookies by us and by our partners mentioned above.

H. CHANGES TO THIS PRIVACY POLICY

Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on our Alibaba Cloud Platform. Once posted on our Alibaba Cloud Platform the new Privacy Policy will become immediately effective. We may also in our discretion provide notice to you of any changes to the Privacy Policy. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. You agree that any information and/or personal data we hold about you (as described in this Privacy Policy and whether or not collected prior to or after the amended and restated Policy comes into effect) will be governed by the latest version of our Privacy Policy. We strongly encourage you to visit the Alibaba Cloud Platform from time to time to review the Privacy Policy. Your continued use of the Alibaba Cloud Platform and/or the Cloud Services signifies your acceptance of the changes to the Privacy Policy.
AUSTRALIA ADDENDUM

If you are located in Australia, you acknowledge that Alibaba Cloud (Singapore) Private Limited is bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, please contact our General Counsel at the address for “Outside the EEA” set forth in Part F above, who will review your complaint and respond within a reasonable period.If you are dissatisfied with the handling of your complaint or concern, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au

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