Last Updated: 05/18/2023
Moatable, Inc., along with our affiliates and subsidiary sites (collectively, “Moatable”, “company”, “we”, “our”, “us”) are committed to protecting the privacy of our customers. Moatable provides management expertise, scalable operations, and capital to help our businesses to grow, scale, and provide our business’ customers with a high-value user experience.
By using this site, you agree to take basic steps to ensure your privacy online. You agree to log out of this site when you are finished, protecting your information from other users. You also agree not to share your password or login ID with anyone else. In addition, you agree to take reasonable precautions against malware and viruses by installing antivirus software to protect your online activities.
What Is Personal Information?
“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Personal Information may include the following: name, address, date of birth, gender, credit card/payment information, username and password, and contact data (i.e., email address, telephone number, and employer name).
If you use Site features operated by third-party social networking services (such as Facebook), we may receive information you have made available to those services, including the geographic location of your mobile device and other information about you (such as name, email address, gender, locale, time zone, languages, social media profile URL, personal website URL, biographical information, date of birth, photo, list of devices, education history, work history, hometown, interests, current city, political views, favorite athlete and teams, relationship status and information, religion, name of significant other, and certain security settings information) and your contacts on those services. Some of these social networking services allow you to push content from our Sites to your contacts or to pull information about your contacts so you can connect with them on our Sites. Some of these services also will facilitate your registration for our Sites or enhance or personalize your experience on our Sites. You should make sure you understand the information your third-party social networking services may make available to our Sites.
We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove or hide any Personal Information.
· Visitors to, or users of, its website
· Prospective and current customers using this site
· Service providers and business partners
· Prospective and current employees
· Other third-parties that Moatable interacts with
We collect this information to continually improve and enhance the functionality of Moatable. We gather certain information automatically. This information may include IP addresses, browser type, Internet
Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or click stream data. We link this automatically collected data to other information we collect about you.
Collection of Personal Information
We take your privacy seriously and employ information protection controls in keeping with industry standards and practices or applicable governmental requirements to safeguard your information and protect your anonymity. Personal Information about you may be collected from you through various sources, including information (i) that is entered manually and voluntarily by you on the Site and other forms or postings on the Site; (ii) that you provide regarding your preferences (for example, based on your activity on our website); (iii) from other sources with your consent (for example, from other institutions such as auditors or administrators); (iv) from sources in the public domain; and (v) from other interactions you may have with us (for example, discussions or emails with our staff, including through the use of the Site’s contact features).
In addition, when you visit our Site, we may gather anonymous technical and navigational information, such as computer browser type, Internet protocol address, cookie information, pages visited, and average time spent on our Website. This information does not personally identify you and may be used, for example, to alert you to software compatibility issues, to customize any advertising or content you see, fulfill your requests for products and services, contact you, conduct research, or analyze and improve our Site design and functionality.
Such information collected by us is stored and processed in the United States. By using the website, you consent to the foregoing collection and use of information and any such transfer of information outside of your country. We make no representation or warranty with respect to any duty to permanently store any Personal Information you may provide.
Personal Information You Choose to Provide
In order to provide the best experience when you visit our website, we may ask you for Personal Information. Personal Information includes, for example, your name and e-mail address, both of which you may be asked to provide when registering with Moatable. A description of some of the ways that you may provide Personal Information to us, as well as further details on how we may use such Personal Information, is given below.
If you email us using a “Contact Us” link or form on our Website, we may ask you for information such as your name and e-mail address so we can respond to your questions and comments. If you choose to correspond with us via e-mail, we may retain the content of your e-mail messages, your e-mail address, and our response to you.
We may occasionally ask website visitors to complete online surveys and opinion polls about their activities, attitudes, and interests. These surveys help us improve our products and services. When asking for participation in these surveys, we may ask you to provide us with your name and email address.
Our Website may offer visitors contact forms to request additional details and to download collateral. If you fill out one of our web forms, we may ask you for information such as your name and email address
so we can respond to your questions and comments. If you choose to correspond with us via web forms, we may retain the form data which can include name, email address and other contact related details.
Website Usage Information
Technologies such as: cookies, beacons, tags, and scripts are used by Moatable and our marketing partners, analytics providers, and customer support systems. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We may supplement data we collect through automated means with information about your location (such as your zip code) to provide you with content that may be of interest to you.
Most web browsers can be set to tell you when a cookie has been sent to you and give you the opportunity to refuse that cookie. Refusing a cookie may in some cases prevent you from using or negatively impact the display or function of our Website or certain areas or features of our Website. There are numerous resources on the Internet that can provide more information about how cookies work and how you can manage them.
If advertisements appear on our website, the advertisers may employ cookies and other tracking technologies in connection with those advertisements. Your accessing any of those advertisements from our webpage may cause your exposure to those tracking technologies. Third party websites that you visit may use the cookies placed by third party vendors for similar purposes. We have no responsibility for any such cookies and other tracking technologies.
Web Beacons, also known as pixel tags and clear GIFs, (“Web Beacons”), are electronic images that allow a website to access cookies and help track marketing campaigns and general usage patterns of visitors to those websites. Web Beacons can recognize certain types of information, such as cookie numbers, time and date of a page view, and a description of the page where the Web Beacon is placed. No personally identifiable information about you is shared with third parties through the use of Web Beacons on the Site. However, through Web Beacons, we may collect general information that will not personally identify you, such as: Internet browser, operating system, IP address, date of visit, time of visit, length of visit, and path taken through the Site.
· Internal use of Web Beacons: Moatable may use Web Beacons internally to count visitors and recognize visitors through cookies. Access to cookies helps personalize your experience when you visit the Site.
· Email: Moatable may include Web Beacons in HTML-formatted email messages that are sent to you. Web Beacons in email messages help to determine your interest in and the effectiveness of such emails.
· External use of Web Beacons: Moatable may also use Web Beacons externally. For example, Moatable may report aggregate information about visitors, such as demographic and usage information, to its affiliates and other third parties. Moatable may also include other Web Beacons within the Site.
Your Opt In/Opt Out Choices
You may “opt in” and/or “opt out” of certain uses of your Personal Information. For example, you may have the opportunity to choose whether you would like to receive email correspondence from us. Your Personal Information will not be shared with third-party service providers unless you give consent. You will have the opportunity to opt out of Moatable marketing emails by clicking the “opt out” or “unsubscribe” link in the email you receive. You can also request this via email at firstname.lastname@example.org.
Please take note that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications with us.
Permitted Use of Personal Information
Moatable uses your Personal Information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your Personal Information to support our business functions, such as fraud prevention, marketing, and legal functions. To do this, we combine personal and non-Personal Information, collected online and offline, including information from third-party sources.
· Fulfill Requests: To fulfill your requests for products and services and communicate with you about those requests. This includes sending information to others if you ask us to do so.
· Understand Customer Behavior: To better understand customer behavior so that we may improve our marketing and advertising efforts and to improve the distribution of our products and services.
· Personalize Offerings: To help us personalize our websites and advertising.
· Protection: To protect the security and integrity of our websites and our business.
· Legal: To comply with legal and/or regulatory requirements.
· Responding to Customer: To respond to reviews, comments, or other feedback you provide us.
· Employment Applications: In connection with a job application or inquiry, you may provide us with data about yourself, including your educational background, resume, professional licenses, legal work eligibility status, and other information including your ethnicity where required or permitted by law. We may use this information throughout Moatable, its subsidiaries and affiliates, and its joint ventures, for the purpose of employment consideration.
By providing us with your phone number, you consent to our using your phone number to deliver or cause to be delivered to you at that phone number telemarketing calls (which may use an automatic telephone dialing system) and artificial or prerecorded voice or text messages from us. If you do not wish to receive such calls or messages, you may opt out. You release us from any possible liability or claim stemming from how we use your phone number, included but not limited to claims arising from the Telephone Consumer Protection Act (“TCPA”). You understand that you are not required to provide this consent and authorization and that it is not a condition to qualify to receive our services.
Use, Disclosure, and Sharing of Personal Information
· Service Providers
We may use third-party partners to help us operate and maintain our Website and deliver our products and services. We may also share your information with our service providers and other third parties (“Affiliated Parties”) that provide products or services for or through this Website or for our business (such as website or infrastructure hosting companies, communications providers, email providers, analytics companies, credit card processing companies, and other similar service providers that use such information on our behalf).
We may share data with Moatable partners to contact you based on your request to receive such communications, help us perform statistical analysis, provide sales support, or provide customer support. We also partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you.
Third-party service providers are contractually restricted from using or disclosing information, except as necessary to perform services on our behalf or to comply with legal requirements.
· Compelled Disclosures
Moatable may be required to disclose collected information in order to (i) respond to investigations, court orders or legal process, (ii) to investigate, prevent or take action regarding illegal activities, suspected fraud, potential threats to the physical safety of any person, (iii) violations of the Company’s terms of service, or (iv) as otherwise required by law.
· Your Ability to Access, Limit Use and Disclosure
You may request access to your personal data to update, correct or delete, or to limit the use or disclosure of, your personal data.
Individuals wishing to view, update, delete, or supplement their personal data may do so by contacting the business that provided Moatable their personal data directly to make their requests, or alternatively they can submit their request via email to email@example.com. Individuals outside the European Union (“EU”) may also use this email to submit complaints about privacy and our collection or use of their personal information.
· Disclosure of Personal Information
Moatable does not sell or otherwise disclose the Personal Information it holds to third parties, except for the following exceptional circumstances:
· Third Parties: Moatable will not rent or sell your Personal Information to others but may disclose Personal Information to third-party vendors and service providers that work with Moatable. We will only share Personal Information to these vendors and service providers to help us provide a product or service to you at your request and in accordance with our respective agreement. We will ensure appropriate contractual clauses are in place to ensure compliance with applicable data protection legislation.
· Business Purposes: In a prospective business transaction, Moatable may disclose Personal Information where Moatable has entered into an agreement that restricts the use and disclosure of that data solely for purposes related to the transaction, protects the data by security safeguards appropriate to the sensitivity of the information, and if the transaction does not proceed, the data is returned to Moatable or destroyed within a reasonable time. With respect to employee data, Moatable may disclose Personal Information if it is necessary to establish, manage or terminate an employment relationship, as allowed by law.
· Legal and Safety Reasons: Moatable may be required to disclose Personal Information to law enforcement agencies, government agencies, or legal entities. We may disclose information by law, litigation, or as a matter of national security to comply with a valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law. We may also need to disclose Personal Information in the event of an emergency that threatens an individual’s life, health, or security. If the data requested is held on behalf of a customer, Moatable will inform the customer unless it is prohibited to do so by law. Moatable may be required to disclose information without your consent or knowledge if: (i) it is reasonable to expect that disclosure with the customer’s knowledge or consent would compromise an investigation of a breach of an agreement or a contravention of the law; (ii) it is reasonable for the purposes of preventing, detecting or suppressing fraud and it is reasonable to expect that the disclosure with the customer’s knowledge or consent would compromise the ability to prevent, detect or suppress the fraud; (iii) it is necessary to identify an individual who is injured, ill or deceased to a government institution or the individual’s next of kin or authorized representative and, if the individual is alive, with notification to the individual.
· Change of Ownership: If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy, or otherwise, that company would receive all information gathered by Moatable on the website. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.
Right to Correct Personal Information
Your Right to Correction. You have the right to request the correction of any inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as you may direct.
We take reasonable and appropriate precautions, including administrative, technical, personnel, and physical measures, to safeguard Personal Data against loss, misuse, theft, and unauthorized access, disclosure, alteration, and destruction. We also use Secure Sockets Layer (SSL) encryption when transmitting sensitive information. In addition, our business practices are reviewed periodically for compliance with policies and procedures governing the security and confidentiality of our information.
To help protect the privacy of data and personally identifiable information you transmit through use of this site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
Data Retention and Storage
All Personal Information is retained only for as long as it is necessary for the purposes for which it was collected or transferred. Moatable retains your information for business purposes, for as long as your account is active, and/or as long as is reasonably necessary. Moatable will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time. At any point in time, you can withdraw consent and we will immediately stop processing your data.
International Transfer of Personal Information
Moatable may share customer information within our affiliated companies for a variety of purposes, for example, to provide you with the latest information about our products and services and offer you our latest promotions. “Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with the subject entity. “Control,” for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity. To facilitate our global operations, Moatable may transfer Personal Information from your home country to other Moatable locations across the world. To protect your Personal Information, we will only transfer data to countries who provide an “adequate” level of Personal Information protection. If the data is transferred to counties without “adequate” protection as determined by the European Parliament, we will use additional safeguards to ensure your data is protected.
Company Response to a Data Request and/or Security Breach
In regard to the aforementioned rights to voice questions, make requests regarding your data privacy or withdraw consent, we will respond to your request within 30 days. In some cases, however, we may limit or deny your request if: the law permits or requires us to do so, if it infringes on the privacy of other individuals or internal procedures, if we find the request to be unfounded or excessive, or if we are unable to verify your identity.
If the volume or complexity of the request requires internal processing at Moatable beyond 30 days, Moatable will inform the requester within 30 days of the reasons for an extension and may charge a reasonable fee to cover administrative costs.
Security of all information is of the utmost importance for Moatable. Moatable uses technical and physical safeguards to protect the security of your Personal Information from unauthorized disclosure.
We use encryption technology to keep all information secure. We also make all attempts to ensure that only necessary people and third parties have access to Personal Information. Nevertheless, such security measures cannot prevent all loss, misuse, or alteration of Personal Information and, unless otherwise agreed in a written agreement between Moatable and the applicable party, we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the case of a data breach, we will notify you without undue delay of any loss, misuse or alteration of Personal Information that may affect you. We will notify relevant regulatory bodies within 72 hours of identifying a breach.
Important Notice to European Union Individuals: The General Data Protection Regulation (GDPR)
To facilitate our business practices, your Personal Data may be collected, transferred to, and stored by us in the United States. As a result, your Personal Data may be processed outside the European Economic Area (“EEA”), and in countries which are not subject to an adequacy decision by the European Commission, and which may not provide for the same level of data protection in the EEA. In this event, we will ensure an adequate level of protection, for example by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.
Moatable commits to resolve complaints about your privacy and our collection or use of your personal information under GDPR. European Union individuals with inquiries or complaints should use firstname.lastname@example.org to submit complaints about your privacy and our collection or use of your personal information.
Alternative Means of Contact
If you would rather correspond via mail, please use our mailing address:
45 W Buchanan St Phoenix, AZ 85003
If you have any unresolved privacy concerns that we have not addressed to your satisfaction after contacting us, you have the right to contact the EU Data Protection Authorities by clicking on the following link: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Your Right to Access Your Data
We acknowledge the right of UK, EU, and Swiss individuals to access their personal data. You may request to access and limit use and disclosure of this data by sending an email to email@example.com.
Your Ability to Choose How Your Data Is To Be Used
If you are located in Canada, this section applies to you
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
· If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
· For investigations and fraud detection and prevention
· For business transactions provided certain conditions are met
· If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
· For identifying injured, ill, or deceased persons and communicating with next of kin
· If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
· If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
· If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
· If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
· If the collection is solely for journalistic, artistic, or literary purposes
· If the information is publicly available and is specified by the regulations
Overview of California Consumer Privacy Laws
Do California Residents Have Specific Privacy Rights?
Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 179883, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
California Consumer Privacy Act (CCPA)
On January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) took effect and established requirements and rights relating to personal information of California consumers. This section for California residents applies solely to visitors, users, and others who reside in the State of California
(“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect: We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
We will use and retain the collected personal information as needed to provide the Services or for:
Category A – As long as the user has an account with us
Category B – As long as the user has an account with us
Category G – As long as the user has an account with us
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
· Receiving help through our customer support channels;
· Participation in customer surveys or contests;
· Facilitation in the delivery of our Services and to respond to your inquiries;
Fair Information Practices
The Fair Information Practices, also known as the Fair Information Practice Principles (FIPPs), form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
· We will notify the users via email within seven (7) business days
· We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
To be in accordance with CAN-SPAM we agree to the following:
If at any time you would like to unsubscribe from receiving future emails, you can email us at firstname.lastname@example.org and we will promptly remove you from ALL correspondence.
Children’s Online Privacy Protection Act (COPPA)
We do not collect any information from anyone under 18 years of age. Our website is directed to people who are at least 18 years old or older. If we learn that we have mistakenly collected personal information from a child under age 18, we will delete that information as soon as possible. If you believe that we might have information from or about a child under age 18, please contact us via email at email@example.com.
Updates to Our Privacy Statement
45 W Buchanan St Phoenix, AZ 85003