Last updated: 12th December 2016
Information Collected by CLX
In general, CLX will collect information from you based upon our business relationship, your use of the Site, Our services and Our products, as follows:
In order to access and view some content on the Site, you are required to register with CLX before the content is made available to you. During the registration process, you are required to provide Us with certain contact information, including your name, address, phone number and email address. We use this information to contact you about the services We offer in relation to which you have expressed interest.
CLIENT SUPPORT PORTAL
When you contact CLX customer support (“Customer Support”) using any CLX client support portal (the “Client Support Portal”), We may ask you for certain information regarding your enquiry, such as your name, email address or telephone number.
What Are Cookies and How Do I Disable Them?
Cookies are files that web browsers place on a computer’s hard drive. You can disable cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Note that you may be prevented from using the Site or services effectively or at all if cookies are disabled.
Our customer support portals use session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Us to process your online data and requests. Session cookies help Us make sure you are who you say you are after you have logged in. We use persistent cookies, which only we can read and use, to identify the fact that you are an CLX customer or prior site visitor.
FORUMS AND BLOGS
If you participate in any blog or other forum offered by the Site or services, your user ID may be displayed on any content that you post and will therefore be available to the public. Therefore, if you associate your name with your user ID, your name and any related content or posts may be available to the public. You are solely responsible for all liability related to your use of any such blog or forum.
If you send Us correspondence, such as emails or letters, We may collect such information into a file specific to you.
MOBILE USER INFORMATION
We collect information about you when you submit a job application, resume, survey responses or similar information.
If you wish to subscribe to Our newsletters, We will use your name and email address to send the newsletter to you. Out of respect for your privacy, you have the option to unsubscribe from receiving some or all of the newsletters. Please see the “Opt-out” section below.
How We Use Information
We may use data We obtain as described above for purposes relating to the Site and services, including (a) providing the Site and services to you, (b) facilitating third parties to participate in the provision and improvement of the Site and services (including without limitation mobile network operators, hosting partners, and other service providers), (c) raising queries with you, and responding to issues you may raise, whether relating to our services or otherwise, (d) communications relating to surveys and other customer satisfaction-related activities, (e) progressing job applications, to perform credit checks and, (f) verification of personal or business data and payment details and other checks before offering our services to customers.
We will send you service-related announcements when it is necessary to do so. For instance, if Our service is temporarily suspended for maintenance, We might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
We will also communicate with you in response to your customer service enquiries, to provide the services you request, and to manage your account.
Disclosures and Sharing of Information
As a matter of policy, We do not sell or rent any of your information to third parties for any advertising or marketing purposes. However, the following describes some of the ways that We may disclose your information in the normal course of providing Our services.
LEGAL REQUESTS & COMPLIANCE WITH LAWS
PROCESSING OF PERSONAL DATA OUTSIDE EU AND SWITZERLAND
CLX processes Personal Data on behalf of its clients (“Customers”), that has been collected by or on behalf of those Customers including Personal Data received from the European Union. “Personal Data” or “Personal Data” means information relating to an identified or identifiable person. With the objective to validate transfers of Personal Data under European data protection laws to countries outside EU and Switzerland we are making available the European Commission’s controller-to-processor standard contractual clauses, commonly referred to as “model clauses” (in the form adopted by decision 2010/87/EU of 5 February 2010 and with Appendices 1 & 2. Any Customer of Mblox Inc., CLX Networks AB Telekomünikasyon Hiz. LTD. ŞTİ or Mblox Limited who undertakes processing activities on the CLX platform (in respect of Personal Data which is governed by the European data protection laws), should contact firstname.lastname@example.org for more details.
DISCLOSURE OF INFORMATION TO CLX AFFILIATES
Because CLX is a global C company, We may share your information with other CLX affiliates and business units in other parts of the world in order to provide you with Our services. Your Personal Data may be transferred by Us from your home country to CLX employees in CLX offices around the world, who may communicate with you regarding your enquiry. Please understand that We limit access to your Personal Data to only those CLX employees who We believe need access in order to provide services to you or to otherwise perform their duties.
As Data Processor, CLX will only process Personal Data pursuant to the instructions of the applicable Customer (for example where We act as a Data Processor in relation to the processing activities of Customers on Our platform). CLX may use the services of third party Data Processors to process Personal Data in accordance with purposes identified for such Personal Data by the applicable Customer (including but not limited to the provision of services). CLX will not be responsible for determining the authenticity of any purported Data Subject’s request to access his or her Personal Data. In the absence of express instructions to do so from the applicable Customer, CLX will not provide a purported Data Subject with access to his or her Personal Data unless it is demonstrated to CLX’s satisfaction that the applicable Data Controller has refused such access.
From time to time, CLX provides messaging services to health care providers, and serves as a “Business Associate” (as that term is defined pursuant to HIPAA Regulations) to such providers in relation to the handling of protected health information (“PHI”) that is made a part of Our services.
CLX may de-identify or depersonalize data into anonymized and aggregate data that it derives from Customers (“Anonymous Data”). Anonymous Data means data that includes no Personal Data or unique identifiers that could later be used to refer to the Personal Data to which the data was once associated. CLX uses only Anonymous Data in performing analyses, and may disclose Anonymous Data to its Customers who have requested such analyses and to third parties where We are contractually entitled to do so.
This Site is Not for Use by Children
Protecting the privacy of children is important to CLX. For that reason, the Site is structured specifically to not attract anyone under 13, nor do We collect or maintain Personal Data on the Site from those who CLX actually knows are under 13. If CLX learns or is notified that it has collected information from users under the age of 13, CLX will immediately delete such Personal Data.
We provide you the opportunity to ‘opt-out’ of having your Personal Data used for certain purposes, when We ask for this information. For example, if you register with Us but no longer wish to receive Our newsletters and/or related communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing Us at email@example.com.
We take appropriate technical and organizational measures to guard against unauthorized or unlawful processing of your Personal Data and against accidental loss or destruction of, or damage to, your Personal Data. CLX uses industry-standard security measures to protect the integrity and confidentiality of any Personal Data it owns or processes on behalf of Customers, including, in appropriate circumstances, the use of firewalls, restricted access, and encrypted transmissions. CLX limits access to Personal Data to those persons in CLX’s organization who have a business need to process such Personal Data. However, no company, including CLX, can fully eliminate the security risks associated with such Personal Data. Due to factors beyond CLX’s control, CLX cannot ensure that Personal Data will not be disclosed to third parties. For example, CLX may become legally obligated to disclose such data, or, despite precautions, third parties may circumvent security measures to intercept or access such data.
Update Information / Revoke Choices / Suggestions / Contact Information
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CLX Networks AB Telekomünikasyon Hiz. LTD. ŞTİ
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Barbaros Bul. Nispetiye Mah. Beşiktaş,