PRIVACY POLICY AND DATA OWNERSHIP

Effective date: 2011/09/04

Use of Data

iClick collects our client’s users’ information when they are visiting our clients’ websites. The information includes, but is not limited to, all sales and marketing information provided by our clients’ online advertising or other campaign information, and all individually identifiable information about users at clients’ websites, including statistical, demographic, and behavioral information. iClick collects information solely on an “as-necessary” basis in order for iClick to provide its services to our clients and our clients grants to iClick a limited license to use such information to perform its obligations. iClick will treat all information collected as confidential. Clients’ limited license to iClick includes, but is not limited to, the right to collect all information of users visiting our clients’ websites, either directly or through other means, such as the use of redirects and 1-by-1 pixels. iClick will not disclose any information collected from client to any third party unless such disclosure is (i) approved by client, who in turn has obtained the approval of their users, or who has not opted out of the right to distribute their information, or (ii) is made by iClick in response to an order by a competent court of law, and provided that iClick has given client reasonable notice of such order, and an opportunity to contest, or (iii) supported by a Non-Disclosure Agreement which enable iClick to co-operate with third party for data analytics purpose. iClick may improve and promote its service offerings, aggregate the information collected from clients with other data so that it is non-personally identifiable with respect to both clients and users to clients’ website(s).

Our Commitment To Privacy

Our clients’ and their users’ privacy is important to us. To better protect privacy of the users information we obtain we provide this notice explaining our online information practices and how information is collected and used. To make this notice easy to find, we make it available on this product website (i.e optimix.asia) and at every point where personally identifiable information may be requested.

Purpose of Data Collection

We use the information collected to evaluate the effectiveness of customers’ marketing campaigns in a statistical way and then come up with different strategies by human or a machine’s self-learning capability for further campaign improvement. Finally, we never use or share the personally identifiable information provided to or collected by us online in ways unrelated to those described.

How We Use the Information

This notice applies to all information collected or submitted on the XMO Tracking Service. XMO acts as SaaS (i.e. Software as a Service) for each of our clients who use XMO to understand more about how the visitors react to their online marketing campaigns and eventually complete the campaign goals including online purchases, enquiries or membership registration, etc as defined by our clients. On top of collecting our clients’ users’ behavioral patterns in an anonymous way, we also collect certain technical information such as IP address, browser version and operating system. In addition to the above and in order to create statistical information, we may also, upon our client’s request, and subject to their users consent, collect personally identifiable information like email address or member ID but they will not be disclosed, sold or transferred to any 3rd party.

Our Commitment To Data Security and Disposal

To prevent unauthorized access, maintence of data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. As soon as reasonably practicable, once service to a client has been completed, all information identifiable to a user, collected by us, for that service, shall be properly and securely destroyed and permanently deleted from our systems.

Obligations of our Clients

Our clients are under obligation to disclose to their users, that personal information they are submitting are being collected for analytic purposes and our clients are obliged to provide an opt out provision to their users whether or not they agree their personal information to be disclosed to us.

How We Use Cookies

XMO uses only 1st party cookie to the base domain of ‘optimix.asia’. The cookie information does not include personal data such as name, email, phone number or gender. If you would prefer, you can opt out your browser to XMO tracking by rejecting cookies specifically from the domain ‘optimix.asia’ or by our cookie opt-out page on (http://xmo.optimix.asia/en/optout).

How To Contact Us

Should you have other questions or concerns about these privacy policies, please call us at +852 3700 9000 or send us an email at privacypolicy@i-click.com.