Many of our Cloud Services offered through the FortSpace Platform are intended for use by business organizations. If you use your organization’s email address to register an account and purchase or use our Cloud Services, the owner of the domain associated with your organization’s email address, and/or your organization, may monitor or control your account with the FortSpace Platform and access, process, and/or control your personal information, as well as the contents of your communications and files. Your organization’s use of our Cloud Services may be subject to your organization’s own rules or policies, and you shall direct all privacy enquiries relating to such rules or policies to your organization’s administrators. We are not responsible for the privacy or security practices of your organization.
Cloud Services may be used by our customers (i.e. registered users of FortSpace Platform) to develop or host their own services and products for the customer’s end users. Any information collected or handled by FortSpace Platform in such circumstances 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 FortSpace customer providing their services or products. We are not responsible for the privacy or security practices of our customers.
A.COLLECTION OF PERSONAL INFORMATION
If you are an individual or a representative of a business organization at the time you register to become a user of the FortSpace 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.
We record details of your activities (including any purchase or use of our product offerings and services) when you use the FortSpace Platform and/or certain Cloud Services for legal and/or business purposes. If you make purchases or otherwise transact online through the FortSpace 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.
When you contact our customer support, sales or other departments, we may record the communications for security and customer services purposes and collect additional information to verify your identity.
If you make online purchases for our Cloud Services through the FortSpace Platform, you may be required to provide information related to your payment instrument (such as credit cards), including information about your payment instrument organization, your payment instrument number, the security code, and the expiration date of your payment instrument, directly to our payment service provider.
Please note that certain categories of information are necessary for us to provide the Cloud Services, such as user name, address, phone number, and email address. These categories will be specified at the time of collection. In the event that you do not provide any or sufficient information marked as mandatory, we may not be able to complete the registration process or provide you with our Cloud Services.
We also record records of users’ buying and browsing activities on the FortSpace Platform, including but not limited to Internet Protocol (“IP”) addresses, browsing patterns and purchasing patterns. In addition, we automatically gather statistical information about our FortSpace Platform and visitors to our FortSpace Platform including, but not limited to, IP addresses, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors.
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
We collect, retain, use and disclose personal information for the following purposes:
- processing your registration as a user, providing you with an user ID for our FortSpace Platform and maintaining and managing your registration;
- providing you with customer service and responding to your queries, feedback, claims or disputes;
- providing the Cloud Services to you and/or your end users;
- processing your purchases and/or subscriptions on the International Marketplace;
- personalizing our communication with you based on your order history, and performing research or statistical analysis in order to improve our product offerings and services;
- publishing any information you voluntarily submit (which may include, but is not limited to, a photograph or other personal information you provide) to our FortSpace Platform to be published on our FortSpace Platform through the publishing tools (such as our discussion forums);
- 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;
- performing risk control, legal compliance and sanctions screening; and
- performing screening and checks for unlawful, fraudulent, deceptive or malicious activities.
Subject to obtaining your specific consent (or where otherwise permitted by applicable law in your jurisdiction), we may use your name, phone number, residential address, email address and fax number (which may incorporate personal information) to provide notices, surveys, product alerts, related communications and other marketing and promotional materials to you relating to goods and services offered by us on our FortSpace Platform.
C.DISCLOSURE OF PERSONAL INFORMATION
We may share your information, including personal information, as follows:
Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
Service Providers. We may disclose the information we collect from you to third party vendors, digital wallet companies, service providers, contractors or agents who perform functions on our behalf.
We also disclose information in the following circumstances:
Business Transfers. If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, Acceptable Use Policy, or this Policy, or as evidence in litigation in which FortSpace is involved.
Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
D.TRANSFER OF PERSONAL INFORMATION
As part of providing you with the Cloud Services, we may need to transfer your personal information from your jurisdiction to an overseas jurisdiction. Recipients of the information in these jurisdictions may be subject to information privacy laws less protective or not equivalent to those in your own jurisdiction. Such overseas transfer or processing of your personal information may be 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). You appoint us to perform any such transfer of personal information to any such country and to store and process such personal information 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 information 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 information subjects to permit the use of the same.
We use commercially reasonable endeavors to protect the personal information 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 information in registration information and payment information and the adoption of identity, credential and access management measures for transmission of such personal information to prevent security breaches and unauthorized access of personal information. We limit access to your personal information and other information to people who need to access to such information for their work.
Nevertheless, no information 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 information, we cannot guarantee the security of any personal information 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 FortSpace Platform and our Cloud Services.
We retain your personal information as long as you have an account with us, as needed to provide services or products to you, to resolve disputes, or as required or permitted by applicable laws, such as tax and accounting laws.
F.RIGHT TO ACCESS/CORRECT PERSONAL INFORMATION
You have the right to request access to your personal information held by us (or on our behalf) and to request correction or deletion of such personal information. Additionally, upon request, we will provide you with information about whether we hold your personal information. You may also have supplemental rights under applicable law in relation to your personal information. For example, if you are an EEA user, you have the right to object to or request the restriction of processing of your personal information, and to request portability of your information.
In case where we act as a processor, we have no direct relationship with the individuals whose personal information we process. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate information should direct their query to FortSpace’s client (the information controller).
We do not knowingly collect personal information of minors (persons under the age of 18). If a minor has provided us with personal information 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 information relating to the relevant minor.
We and our partners use “cookies” and/or similar technologies to store specific information about you and track your visits to our FortSpace 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 information that is sent to your browser and stored on your device. A cookie can be sent to your device only if you access our FortSpace Platform using a device. If you do not de-activate or erase the cookie, each time you use the same device to access our FortSpace Platform, our web servers will be notified of your visit to our FortSpace Platform and in turn we may have knowledge of your visit and the pattern of your usage.
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 FortSpace 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 FortSpace Platform more often and certain features of our FortSpace Platform may be unavailable.
By accessing and using our FortSpace 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.