ICE COBOTICS - GLOBAL PRIVACY POLICY

Last Updated: October 2023

 

1.         Introduction

 

ICE Cobotics and its affiliates (collectively “ICE Cobotics”) respect your privacy and are committed to protecting your personal information.

 

Purpose of this Global Privacy Policy

 

This Global Privacy Policy explains our privacy practices for the activities described herein.  Please read this Global Privacy Policy carefully to understand how we collect, use, share and otherwise process your personal information and to learn more about your rights and choices regarding your personal information. 

 

It is important that you read this Global Privacy Policy together with our Terms of Use or any other policy or notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. 

 

Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.  Specific privacy policies or notices may apply to some of our products (“Products”) and services (“Services”).  Please visit the webpage of the specific Product or Service to learn more about our privacy and information practices in relation to that Product or Service. 

 

Any references to “ICE Cobotics”, “ICE”, “we”, “us”, “our” or the “Company” is a reference to ICE Cobotics involved in the collection, use, sharing or otherwise processing of personal information. 

 

Contact Information

 

If you have any questions or complaints with respect to this Global Privacy Policy or the way in which we process your personal information, you may contact us via the contact details below:

 

ICE Cobotics EMEA

Email address: [email protected]

Postal address: Airborne Avenue, 55, 2133 LV, Hoofddorp, The Netherlands

 

If you reside in a state in the United States which recognizes privacy rights under law, and if you have any questions or complaints with respect to this Global Privacy Policy or the way in which we process your personal information, you may contact us via the contact details below:

 

ICE Robotics LLC, dba ICE Cobotics

Email address: [email protected]

Postal address: 101 E Roosevelt Ave, Zeeland, Michigan 49464, the United States of America

 

If you are located in mainland China, and you have any questions or complaints with respect to this Global Privacy Policy or the way in which we process your personal information, you may contact us via the contact details below:

 

ICE Cobotics (Guangdong) Company Limited

Email address: [email protected]

Postal address: Fushan Section, Liaobu Town, Dongguan, Guangdong, China

 

If you are located in Hong Kong, and you have any questions or complaints with respect to this Global Privacy Policy or the way in which we process your personal information, you may contact us via the contact details below:

 

ICE Cobotics (H.K.) Company Limited

Email address: [email protected]

Postal address: Room 3512-22, 35th Floor, No.1 Hung To Road, Kwun Tong, Kowloon, Hong Kong

 

Changes to this Global Privacy Policy and You Notifying us of Changes

 

We will notify you of any material changes to this Global Privacy Policy.  It is important that the personal data we hold about you is accurate and current.  We will from time to time publish the up-to-date version of our Global Privacy Policy on our Website.  Please keep us informed if your personal information changes during your relationship with us.

 

Third-Party Links

 

Our official website may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy notices.  When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

2.          Categories of Data  

 

“Personal information” or “personal data” means any information relating to an identified or identifiable individual.  We or our service providers may collect, use, store and transfer different kinds of personal data about you which we have grouped together below:

 

·       Identity Data includes name, username or similar identifier;

·       Contact Data includes email address and telephone numbers;

·       Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services;

·       Profile Data includes username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;

·       Usage Data includes information about how you use our Services;

·       Marketing and Communication Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.    

 

If you use our Products or Services, we may collect personal information about you.  It may be necessary for us to receive and process your personal information to provide respective Products and Services to you.  Such processing of personal data will be protected with adequate security measures and be conducted in a manner so as to have the lowest possible impact on your personal rights and interests.  By using our relevant Products or Services, you will be deemed as having consented to our collection and processing of your personal information in accordance with this Global Privacy Policy (and the relevant program-specific privacy notice, if any). 

 

International Data Transfers

 

If you choose to provide us with information, we may transfer that information to our affiliates, subsidiaries, third party service providers or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world.  Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data, in particular standard contractual clauses. 

 

If you would like to obtain more information about such safeguards you can request this from us via the contact details above. 

 

Minor Users

 

This website is not intended for children and we do not knowingly collect data from children.  If we learn that we have received information directly from a child under the age of 16 without the parent or legal guardian’s verified consent, we will use that information only to respond to the child / parent / guardian to inform the child that he or she may not use the website.

 

3.          How We Collect Your Personal Data

 

We use different methods to collect data from and about you, including through:

 

Direction interactions.  You may give us your personal data by filling in forms or by corresponding with us by post, email or otherwise.  This includes personal data you provide when you:

 

·       apply for our Services;

·       create an account on our website or other official portals;

·       purchase or rent a Product;

·       subscribe to our Services or publications;

·       request marketing materials to be sent to you;

·       respond to our survey; or

·       give us feedback.

 

Third-party sources.  We may receive personal data about you from various third parties including our third-party service providers.  We employ other companies and individuals to perform functions upon our behalf.  Examples include storing and analysing data, providing search results and links (including paid listings and links), providing customer service or payment processing.  They have access to user information needed to perform their functions but may not use it for other purposes. 

 

You are not under a statutory obligation or otherwise obliged to provide us with your information, but if you refrain from doing so, we may not be able to provide you with our services. 

 

This Global Privacy Policy solely describes how we handle your personal data and does not explicitly describe how third parties from which we collected your personal data process your personal data.  We have no influence on this.

 

4.          How We Use Your Personal Data

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Examples of legal basis are:

 

(i)          you have given your consent for the processing of your personal information for one or more specific purposes; or

 

(ii)         the processing is necessary for the purposes of the legitimate interests pursued by us or a third party, but only if your interests, fundamental rights or fundamental freedoms do not outweigh our legitimate interest.  Accordingly, we performed a balancing test.  If you would like to receive more information on the outcome of a balancing test in a specific circumstance, please contact us via the above-mentioned contact details. 

 

Most commonly, we will use your personal data in the following circumstances: (a) where we need to perform the contract we are about to enter into or have entered into with you; (b) where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests; (c) where we need to comply with a legal or regulatory obligation. 

 

Please find below the purposes for which we process your personal information and the legal basis on which we rely:

 

Activity: When you apply for our Products or Services

Purpose: Responding to your request (i.e. providing you with requested information and materials); providing our Products or Services

Legal basis: Legitimate interest in engaging with our (potential) customers

 

Activity: When you create an account on our website or portal

Purpose: To register you as a new customer or prospect; to administer and protect our website and portal

Legal basis: Legitimate interest in engaging with our (potential) customers

 

Activity: When you purchase or rent our Product

Purpose: Processing and delivering your order, manage payments, fees, and charges and providing information about our Products

Legal basis: Legitimate interest in performing under a contract with the company you represent

 

Activity: When you purchase or subscribe for our Services

Purpose: Processing and delivering your order, manage payments, fees, and charges and providing information about our Services

Legal basis: Legitimate interest in performing under a contract with the company you represent

 

Activity: When you request marketing materials to be sent to you

Purpose: Sending marketing communications

Legal basis: Consent

 

Activity: When you conduct a survey or give us feedback

Purpose: Collecting feedback on our Products and Services, improving our Products and Services and responding to feedback on our Products and Services

Legal basis: Legitimate interests of ICE Cobotics, being the review and improvement of our Products and Services

 

Activity: When you access or use our website, portal, Products or Services

Purpose: Using data analytics to improve our website, portal, Products or Services, marketing, customer relationships and experiences

Legal basis: Legitimate interest of ICE Cobotics being the review and improvement of our Products and Services

 

Email and Text Messaging Marketing and Outreach

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing.  You can manage the marketing and outreach we provide to you by opting out, which is described in the “Opting Out” section below. 

 

Opting Out

 

You can ask us to stop sending marketing messages at any time by replying to a marketing email with “unsubscribe” in the subject line, clicking “unsubscribe” in the marketing email itself, or by contacting us at any time.  

 

By entering your phone number and other contact details into our website, you consent to receive marketing messages at the phone number and other contact details provided.  Consent is not a condition of purchase.  Message and data rates may apply.  Message frequency varies.  Reply HELP for help or STOP to cancel. 

 

Cookies Policy

 

We may place “cookies” on the browser of your computer.  Cookies are small pieces of information that are stored by your browsers on your computer’s hard drive.  Cookies may enhance the convenience and use of our website.  For example, the information provided through cookies may be used to recognize you as a previous user of the website (so you do not have to enter your personal information every time), offer personalized information for your use, and otherwise facilitate your experience using the website.  You may choose to decline cookies if your browsers permits but doing so may affect your ability to access or use certain features of the website.

 

Web Beacons

 

We may also utilize web beacons on our website.  A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.  The information collected through these automated means may include information that we gather and store about your visit to, and use of, the website, such as your IP address, type of browser and operating system used, date and time you access the website, pages you visit, and, if you linked to the website from another website, the address of that website.  This data does not include personal information and is not treated as personal information under this Global Privacy Policy, but may include the IP address of your device.  We may link an IP address to information that is personally identifiable. 

 

5.          Disclosure of Personal Data

 

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information.  This does not include trusted third parties who assist us in operating our site, conducting our business, or servicing you, so long as those parties agree to keep the information confidential and are subject to the same or similar data protection rules.  Those parties may include:

 

·            vendors, consultants, and/or other service providers

·            affiliates of ICE Cobotics, including but not limited to, subsidiaries and other affiliates within the same group of companies of ICE Cobotics in the United States, China, Europe and Hong Kong

·            partners of ICE Cobotics

·            in the event of purchase or sale of a business, your personal information may be transferred as part of the transaction

 

Those trusted third-party partners may:

 

·            provide you with various services

·            provide database maintenance and security

·            help us manage transactions

·            help us process and fulfill orders, transactions, or requests

 

We may also release your information when we believe release is necessary to comply with the law or request from governmental (enforcement) agencies, or protect ours or others’ rights, property or safety. 

 

6.          Data Security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

 

7.          Data Retention

 

We will only retain your personal data for as long as necessary to fulfill the purpose we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. 

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

8.          Your Rights

 

Depending on your country, you may have the right or choice to do the following:

 

·            Request access to your personal data

·            Request correction of your personal data

·            Request erasure or deletion of your personal data

·            Object to processing of your personal data

·            Request restriction of processing your personal data

·            Request transfer of your personal data

·            Right to withdraw consent to us processing your personal data

·            Right to not be discriminated against for exercising any of these rights

 

 

9.          EU Data Privacy Rights

 

In accordance with the applicable laws, you have the right of access, the right to rectification, the right to erasure, the right to restriction of processing, the right to data portability and the right to object. Most of these rights are not absolute and subject to exemptions in the law, and/or may only apply to certain types of information or processing.

 

Below we set out your rights in more detail. You can exercise any of your rights by sending an e-mail to [email protected]. We will respond to your request within one month but have the right to extend this period with two further months (for example if your request is complex). If we extend the response period, we will let you know within one month from your request.

 

Please note that to help protect your privacy and maintain security, we may take steps to verify your identity before complying with your request.

 

Your right: Right to access

Description: You may ask us to confirm if we are processing your personal data, and if so, access to your personal data.

 

In such case we will provide you with a copy of your personal data and certain information relating to the processing. This enables to check that we are lawfully processing your personal data.

 

Please note that (data protection) rights and/or freedoms of others may stand in the way of us (fully) complying with your request.

 

If your request is clearly unfounded or excessive, we reserve the right to charge a reasonable fee or refuse to comply in such circumstances.

 

Your right: Right to correction

Description: You may ask to correct or complete your personal data if it is inaccurate or incomplete.

 

Your right: Right to erasure

Description: You may ask us to delete certain of your personal data. There are certain exceptions where we may refuse a request for erasure, for example, where the personal information is required for compliance with law or in connection with claims / a legal dispute.

 

Your right: Right to restriction

Description: You may ask us to suspend the processing of your personal information, but only in certain cases (for example if you want us to establish its accuracy or the reason for processing it).

 

Your right: Right to data portability

Description: You may ask us to help you transfer certain of your information you provided to you or other companies (in a structured, commonly used and machine-readable format), but only if the processing is:

 

i) legally based on your consent or on a contract between you and ICE Cobotics; and

 

ii) carried out by automated means.

 

Please note that (data protection) rights and/or freedoms of others may stand in the way of us (fully) complying with your request.

 

Your right: Right to object

Description: If we are processing your personal information based on a legitimate interest (or those of a third party), you may object to processing on this ground. However, we may be entitled to continue processing your personal information based on (compelling) legitimate grounds.

 

Your right: Right to object to direct marketing

Description: You may request us to stop processing your personal data for direct marketing purposes.

 

Your right: Right to withdraw consent

Description: If the processing of personal data is based on your consent, you have the right to withdraw your consent at any time. Please note that the withdrawal of your consent does not affect the validity of the processing prior to your withdrawal.

 

Your right: Right not to be subject to automated decision making

Description: To the extent applicable, you have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you.

 

Inquiries regarding the processing of personal data should be directed to [email protected].

 

You also have the right to file a complaint with the Dutch data protection authority (Autoriteit Persoonsgegevens). However, before you do that, please contact us first, as ICE Cobotics is committed to resolve complaints about our collection or use of your personal information.

 

10.       CALIFORNIA RESIDENT’S PRIVACY RIGHTS

 

In addition to the rights set forth above in Section 8, California residents have additional privacy protections.

 

ICE Cobotics does not respond to Do Not Track (DNT) signals. For more information regarding our tracking activities, see our Cookie and Web Beacon Policies in Section 4 above.

 

California’s “Shine the Light” law permits individual California residents to request certain information regarding our disclosure of certain categories of personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact: ICE Cobotics Client Care team at [email protected]. This request may be made no more than once per calendar year.

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