Dear User,
Thank you for choosing the products and services of IClick Data Technology (Beijing) Limited (Chinese legal name: 爱点击（北京）数据科技有限公司) (“we,” “us,” or “our”). To safeguard your lawful rights and interests and comply with the requirements of the Personal Information Protection Law of the People’s Republic of China (“PIPL”) and other relevant personal-information protection laws and regulations, and to better provide the HubSpot Integration feature of the iParllay platform, we make the following statement as your partner in data-processing activities.
1. Roles of the Parties
To provide the HubSpot Integration feature contemplated by the applicable Service Agreement and Software License Agreement, you acknowledge that, for personal information processed through the Platform, you act as the personal-information processor. You should ensure that the personal information you provide to us has been duly authorized by the relevant individuals and complies with the PIPL and the applicable Service Agreement.
As the entrusted party, we will process data strictly in accordance with your instructions. We will carry out personal-information processing only within your authorized scope and will not exceed that scope or use it for other purposes, including our own purposes or any third party’s purposes. We will take necessary technical and organizational measures, such as remote-login controls, multi-factor authentication, data encryption, access controls, and periodic security assessments, to protect data security.
The source statement says that the Platform has passed the following certifications and assessments:
- Network Security Level Protection 2.0 Level 3 Certification: the information-system security protection capability meets China’s national Level 3 standard;
- ISO 27001 Information Security Management System Certification: Registration No. 08922I20147R0M; and
- ISO 27701 Privacy Information Management System Certification: Registration No. 11322ZPI1009R0M.
Where you process personal information through a third party that cooperates with the Platform, you acknowledge that we provide your data to the third party you select or use based on your authorization. We will not proactively provide data to other third parties unless you expressly request this and provide written authorization.
Third-party services are independently responsible for their own conduct. We do not participate in or interfere with third-party processing activities. Please read the user agreements, privacy policies, and other relevant agreements relating to third-party functions included in the version of iParllay to which you subscribe.
2. Personal-Information Security Incidents
To provide the services contemplated by the applicable Service Agreement and Software License Agreement, you acknowledge that, as a personal-information processor, the personal information you provide to us through the Platform has not experienced data leakage, damage, or loss, and that you have taken technical and other necessary measures to prevent leakage, damage, and loss.
We will take appropriate technical and organizational measures, such as anonymization, de-identification, and encryption of personal data, to protect your data against loss, alteration, unauthorized disclosure, or access. These measures take into account the state of the art, implementation costs, nature, scope, context, and purposes of processing, and the likelihood and severity of risks to the rights and freedoms of natural persons.
If a personal-information leak or other data-security incident occurs, we will notify you as soon as reasonably practicable in accordance with our security-incident response plans and procedures. We will use reasonable commercial efforts to cooperate with you and take measures agreed by the parties or required by applicable law, to help you meet applicable obligations and to assist investigation, mitigation, and remediation.
3. Cross-Border Data Transfer
The source statement says that our servers are located in mainland China. Accordingly, we store and process in mainland China your personal information and personal information processed through the Platform.
As the entrusted party, we provide software functionality that allows you to make business decisions about cross-border transfer, storage, or processing of personal information, including transfer to third parties you select or use, such as HubSpot. You confirm and undertake that you will independently complete compliance procedures required by the PIPL and other applicable laws and regulations, for example obtaining necessary authorization and consent, completing any required data-export security assessment, or entering into a required standard contract for personal-information export, so that a transfer complies with applicable data-protection law.
To the extent permitted by applicable law, we will provide necessary support for your data-export compliance procedures. You acknowledge that this support is limited to the scope expressly set out in legal documents entered into between you and us, including the Service Agreement, Privacy Policy, and Software License Agreement.
4. Personal-Information Subject Rights; Complaints and Reports
If we receive your written instructions, we will respond to requests to exercise personal-information subject rights to the extent permitted by the PIPL and other applicable laws. Before responding, we will notify you and provide relevant details. If we receive a request, complaint, or report from a personal-information subject seeking to exercise rights, and applicable law requires action, we will promptly notify you and provide relevant details. For enquiries about the English legal pages, contact intessa.wan@optaim.com.
The source statement refers to contact methods shown at https://i.parllay.cn/login#/login/email, including email, telephone, and a WeCom QR code, to facilitate your response to personal-information subject requests.
5. Data Return and Destruction
When we terminate Platform services or you stop using them, you may export required data using available Platform functions. The source statement provides that if you stop using Platform services for more than 30 calendar days, the system will automatically delete your iParllay account and related data.
If you remain within the authorized Platform-use period and provide formal written notice, we will take other measures you request, including deletion or anonymization, in accordance with your written instructions, for all data we hold that you provide, including original data and copies.
6. Records, Review, and Assurances
In accordance with the PIPL and other applicable laws and regulations, we retain complete logs of data-processing activities, including access records and operation trails.
Upon your prior written request, we may provide a reputable auditor designated by you with reasonable information needed to substantiate compliance with the applicable Service Agreement, Privacy Policy, and this Statement. We may allow that auditor to audit our processing of data you provide, including by inspection, subject to applicable agreements, law, security, and confidentiality requirements.
7. Relationship to Other Documents and Controlling Language
This Statement supplements the applicable iParllay Service Agreement, Privacy Policy, Software License Agreement, and other notices, rules, or information relating to the collection, use, processing, storage, disclosure, or provision to third parties of personal information. Unless otherwise defined in this Statement, terms defined in the Privacy Policy and other related agreements have the same meaning here.
This Statement is prepared in Chinese and English. If there is any conflict between the Chinese and English versions, the Chinese version prevails. If this Statement or other related agreements are inconsistent with applicable laws or regulations, they are deemed amended to the extent necessary to comply with applicable law.
Company: IClick Data Technology (Beijing) Limited
Chinese legal name: 爱点击（北京）数据科技有限公司
Registered Address: Room 401, 3A Floor, Building F, Huateng Century Headquarters Park, No. 9, Chenjialin, Balizhuang Village, Gaobeidian Township, Chaoyang District, Beijing, China
Contact Email: intessa.wan@optaim.com