PARKLU Services Privacy Policy
This privacy policy (“Policy“) describes the policies and procedures of the PARKLU services on the collection, use and disclosure of your information as a user of the services, features, content or applications we offer (the “PARKLU Services“ or the ‘Services’). It also explains the choices you have with respect to the information collected. In general terms, any processing of personal data or information carried out within the PARKLU Services will be based on the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and accountability.
The PARKLU Services provide Key Opinion Leader (KOL) relationship management (KRM) services and an analytics platform pioneering how brands analyze, collaborate, and manage social media influencers in China.
When we refer to users (“Users“, “Registered Users“ or “you") we mean all individuals who use the PARKLU Services and have a login, including those users granted access to the PARKLU Services via their employer or another company ("Customer").
When we refer to PARKLU (collectively referred to as "we", "us", or "our"), we mean the Park Lu entities, either Park Lu Limited Hong Kong or Park Lu Consulting (Shanghai) Limited, or Park Lu PTE Ltd. Singapore (jointly referred to as “PARKLU”), as part of the Launchmetrics Group. Depending on the situation, and pursuant to the terms of the relevant data processing agreement entered with you or a Customer, the relevant PARKLU entity will be subject to a different degree of liability. Such an entity might be considered either as the entity determining the means and the purposes of the processing (a “Controller” or “Business”) or as the entity which inly process your Personal Information according to the instructions received by you or by a Customer (a “Processor'' or “Service Provider”).
Table of Contents:
What Information Do We Collect and Receive?
How Do We Use The Information Collected?
Is Information About Me Secured?
How Long Do We Conserve Your Information?
Who Can Access My Personal Information?
What Happens When There are International Data Transfers?
Notice for California Residents
How Do I Review or Change my Personal Information?
Your Rights under applicable Data Protection Laws
What Happens When There Are Changes to this Policy?
Please read this statement carefully to understand our policies and practices regarding your Information and how we will treat it. In case of doubts or questions, you can contact us at privacy@parklu.com.
Any processing operations carried out on your personal information will be made in full compliance with all the laws and regulations, including laws and regulations of the People’s Republic of China, Hong Kong, Singapore, the European Union (and its member states), Switzerland, United Kingdom, and the United States (“Applicable Data Protection Laws”).
What Does This Policy Cover?
This Policy covers the processing of personal data, gathered when you are using or accessing the PARKLU Services ("Personal Information"). This Policy also covers our treatment of any Personal Information that our business partners (third parties like usage tracking tools, communicating tools and feature improvement tools of the PARKLU Services) share with us or that we share with our business partners.
This Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications ("Third Party Services") that you elect to access through a specific Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.
In addition, a separate agreement governs delivery, access and use of the Services (the "Service Provider Agreement") as well as a data processing agreement governs the processing of customer data (data related to the Service Provider Agreement, "Customer Data") that We receive from Customer for the purpose of providing the PARKLU Services.
What Personal Information Do We Collect and Receive?
The information we gather enables us to provide, personalize, improve and continue to operate the PARKLU Services. In connection with certain aspects of the PARKLU Services, we may request, collect and/or display some of your Personal Information.
We receive Personal Information about you from various sources, including: (i) if you register for the Services, through your User account (your “Account“), and (ii) your use of the PARKLU Services generally; but also (iii) from third party websites and services. When you use the PARKLU Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your Information as described in this Policy.
- Personal Information you provide to us: Users routinely submit Personal Information to PARKLU when using the Services (“User Data” or “Account Information”).
You acknowledge that this information may be personal to you, and by creating an Account and providing Personal Information to us, you allow others, including us, to identify you. Your Account Information is completely isolated from the ones of other customers’ Users Accounts. Only Users of the same Customer account may have access to each other's information.
Accounts can either be created by us or a User on your end, for that purpose you will provide us information that could be Personal Information, such as your
- - Business contact Information (Contact Name, Company Email address, Telephone number, Company Name, Language Preference);
- - Account Information (Last name, First name, Email address/Phone number, Password);
- - Support Data (Account Information for the Service used and related to the support inquiry).
PARKLU also collects, generates and/or receives other information that may be considered Personal Information:
-
Information we collect automatically: We automatically receive and record information from your web browser when you interact with the Services, including your IP address, device, and usage information:
- - Log Data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Services and record it in log files. This log data may include the Internet Protocol (IP) address, user names, the address of the web page visited before using the Services, browser type and settings, the date and time the Services was last used, information about browser configuration and plugins, language preferences and cookie data.
- - Usage Information. We collect information about how both Unregistered and Registered Users collectively use the Services, such as the number and frequency of Visitors to the Services, as well as regarding the performance of the Services ("Aggregate Information"). We may use this data as Aggregate Information, as a statistical measure, but not in a manner that would identify you personally, your Account or your web browser. This type of Aggregate Information enables us and third parties authorized by us to improve the content and operation of the Services.
- Third party data that you provide to us: In the course of using the Services you may also provide us with personal information about third parties: contacts, that we do not hold on our industry lists and which you may ask us to process on your behalf; information regarding KOLs that we do not hold and which you may ask us to process on your behalf. In this case, PARKLU is a Processor ( pursuant to GDPR or a “Service Provider” under the CCPA) of your Personal Information and you, as a User, are the Controller (pursuant to GDPR or a “Business” under the CCPA) as we store your KOL Information, but you decide and are responsible for what happens to this data.
- Cookies Information:
We use cookies and similar technologies in our PARKLU Services that help us collect other information. The PARKLU Services may also include cookies and similar tracking technologies of third parties, which may collect information about you via the Services and across other websites and online services. For more details about how we use these technologies, please see our Cookies Policy.
Our cookies might collect Personal Information (such as, IP address), but we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed some aspects of the PARKLU Services.
We use persistent cookies that help us remember your Information and settings when you visit them in the future so you will not have to login again. These cookies are kept no longer than 24 hours.
How Do We Use The Information Collected?
Any Personal Information, as well as any Customer’s data, will be processed by PARKLU in accordance with the Applicable Data Protection Laws. PARKLU will process Customer or User Data in accordance with Customer or User instructions, including any applicable terms in the Service Provider Agreement (and within the relevant data processing agreement), the General Terms of Use, and User's use of the PARKLU Services functionalities.
In particular, pursuant to the Applicable Data Protection Laws we are allowed to process Personal Information, as long as we have a ground under the law to do so. It also requires us to tell you what those grounds are.
In light of the above please note the following. When we process your Personal Information, we will rely on one of the following legal basis:
- - you have given your consent to the processing operations;
- - for the performance of a contract entered directly you, or with the relevant Customer, or to take steps at your request before entering into a contract, we are authorized to process your Personal Information;
- - to comply with our legal and regulatory obligations as set forth by the Applicable Data Protection Law;
- - for our legitimate interests or those of a third party (legitimate interest is when we have a business or commercial reason to use your Information, so long as this is not overridden by your own rights and interests.)
The list below explains how and why we use (process) your Personal Information for and our reasons for doing so:
| What we use your Personal Information for | Legal basis and purpose |
|---|---|
| Provision of the Services. Provide Users with our Services, facilitate interaction within the Services , and personalize Users experience. | For the performance of a contract or to take steps at your request before entering into a contract. |
| Communicate with our Users. Respond to User support requests while using the Services, keep track of a reliable User point of contact among Customer Accounts and obtain information as soon as a contact is leaving. We may also use User Account Information to send operational information about our Services to Users. We reserve the right to contact Users but only when we believe it is necessary, such as for account recovery, downtimes or security purposes. If you do not want to be contacted for such purpose, please email your Account Manager. Although we offer inside the Services several interfaces that might expose Users’ IP address - such as the activity history, we will not directly reveal user email addresses to external users (users not belonging to your company). | For the performance of a contract or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their Services. |
| Improve our Services and measure performance. Understand and keep improving our product in terms of usage information, such as the number and frequency of visitors to the Services features, scope and security needs. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify Users personally. In addition, third parties may share with us non-private, aggregated or otherwise non Personal Information about our Users that they have independently developed or acquired. We do not permit our third-party service providers to use the Personal Information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us. These providers do not collect any Personal Information or store IP addresses locally on their websites. | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you. |
| Security and Fraud Prevention. Detect or prevent fraud and spam/malware and security incidents, and unauthorised access to a User Account and provide information to Users regarding activity on their Account. | For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you. |
| Compliance. Satisfy any applicable law, regulation, legal process or public authorities or governmental request, and any other legal requirements, including complying with court orders, valid discovery requests or subpoenas, and other appropriate legal mechanisms. | To comply with our legal and regulatory obligations. |
| Enforcement. Enforce this Policy and other legal terms and policies, including investigation of potential violations. | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you. |
| Operate our Business. Provide information to our trusted agents and partners (“Agents”), including attorneys and accountants and other persons with whom we conduct business, and as otherwise specified in this Policy, to help us comply with legal, accounting, or security requirements based on our legitimate interests. Unless we tell our Users differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. Users hereby consent to our sharing of Personal Information with our Agents. | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you. |
| Disclosure Pursuant to Business Transfers. If we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, User Information would be one of the assets that is transferred or acquired by a third party. Users acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use User Personal Information as set forth in this Policy. | For our legitimate interests or those of a third party. |
| Information We Process Share With Your Consent. Except as set forth above, you will be notified when your Personal Information may be processed or shared for a specific purpose not listed in this Policy. | Where you have given consent. |
Is Information About Me Secured?
We work hard to secure your Personal Information from unauthorized access to or unauthorized processing, alteration, disclosure or destruction of Personal Information we hold by taking appropriate Technical and Organisational Security Measures, having regard to the state of the technological development and the cost of implementing any measures where appropriate, for example, pseudonymisation and encryption of Personal Information. Processing operations as well as the security measures implemented take into consideration the risk of the processing and of the nature of the Personal Information. Organisational measures include restricting access to the Personal Information solely to authorised persons or third parties where duly authorized and instructed by us for the purposes of processing operation, and according to the ‘need to know’ principle.
Your Account Information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.
While we seek to protect Account Information to ensure that it is kept private by implementing the state of the art of the security measures, we cannot guarantee that no security breach occurs .Without prejudice to the above, please note that the servers that store your Personal Information have appropriate administrative, technical, and physical controls that are designed to safeguard your Personal Information, including industry-standard encryption technology.
In the event of a security incident, we will comply with our notification obligation pursuant to Applicable Data Protection Laws and to the extent required by relevant aws or as otherwise applicable, notify you and/or the relevant supervisory authority within 72 hours of becoming aware of it. This information can be provided in phases to facilitate fast and efficient reporting.
Where a breach is likely to result in a high risk to the rights and freedoms of individuals, we will notify those concerned directly with the following information:
- the nature of the Personal Information breach, where possible.
- The categories and approximate number of individuals concerned and the categories and approximate number of Personal Information records concerned.
- The name and contact details of the data protection officer or other contact point where more information can be obtained.
- A description of the likely consequences of the Personal Information breach.
- A description of the measures taken, or proposed to be taken, to deal with the Personal Information breach and, where appropriate, of the measures taken to mitigate any possible adverse effects.
If you have any questions or concerns regarding security using the PARKLU Services, please send a detailed message to privacy@parklu.com. We will make every effort to answer your concerns.
How Long Do We Conserve Your Personal Information?
PARKLU will retain User Data depending on the type of information, and the purpose for which it is used. In general, we will retain your Personal Information for the length of time reasonably needed to fulfill the purposes outlined in this Policy (including for as long as needed to provide you with the Services), unless a longer retention period is required or permitted by applicable law. And in any case in accordance with Users instructions and use of Services functionality.
We retain your Account Information for as long as your employer’s Account is active and thereafter unless your employer requests deletion of a particular User.
Who can access my Personal Information?
We might be required to disclose Users’ Personal Information in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process, or where it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or as evidence in litigation in which we are involved.
Moreover, in order to provide you the desired Service, User Personal Information might be shared with:
- Entities affiliated to PARKLU as part of the Launchmetrics Group. Please note that all the entities affiliated to the Launchmetrics Group executed reciprocal data processing agreements and standard contractual clauses pursuant to article 46 par. 2 lett. c) of GDPR to lawfully share and process Users' Personal Information.
- Sub-contractors engaged by us providing essential service (e.g. cloud providers, CRM, customer and billing support). Upon request we can provide you with the list of the subcontractors.s a general rule we engage subcontractors who share with us the same or equivalent degree of care when it comes to respect the right to privacy and personal data protection.
Without prejudice to the above, unless upon your specific consent or as otherwise required by Applicable Data Protection Laws, User’s Personal Data shall not be shared with any other organizations.
What Happens When There are International Data Transfers?
We are a global organisation, as such, we may share information about you within PARKLU offices and with affiliates and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Policy.
In some cases, we use suppliers located in various countries to collect, use, analyse, and otherwise process information on its behalf. It is our practice to require such suppliers to handle information in a manner consistent with our policies and Applicable Data Protection Laws. We commit to comply with any other legal requirements provided under any Applicable Data Protection Laws to transfer Personal Information to third countries.
Your Personal Information will be stored and processed in China (including Hong Kong), and may also be transferred to and processed in other jurisdictions, complying with all the necessary requirements as set forth within the Applicable Data Protection Laws to lawfully transfer User Personal Information across jurisdictions, in particular:
- Chinese data protection laws. By accessing and using your User Accounts you hereby grant your consent to transfer your Personal Information outside Chinese jurisdiction.
- Singapore data protection laws. Pursuant to article 10 of the Personal Data Protection Regulation 2021, by accessing and using your User Accounts you hereby grant your consent to transfer your Personal Information outside Singapore jurisdiction. Moreover, please consider that pursuant to articles 10 and 11 of the Personal Data Protection Regulation 2021 we took the appropriate steps to ascertain whether, and to ensure that, the recipient of your Personal Information is bound by legally enforceable obligations, by executing a contract.
- GDPR, or UK GDPR. We are making sure that any of these transfers are supported by the strict legal compliance of our suppliers to the GDPR and to UK GDPR. As applicable we will rely on European Commission Adequacy Decisions, or a UK Adequacy Regulation, or Standard Contractual Clauses (also called Model Clauses) to meet the GDPR/UK GDPR requirements. When necessary, compliance can be achieved if suppliers use an approved certification mechanism.
Notice for California Residents
The content of this section is aimed solely at providing California residents with relevant information under the California Consumer Protection Act (“CCPA”), and may be subject to change. It must be construed in addition and not in lieu of the full Policy.
The CCPA, which is effective as of January 1, 2020, regulates how we handle personal information of California residents and gives California residents certain rights with respect to their personal information.
When it provides the Services, PARKLU is both a “Business” and a “Service Provider” under the CCPA.
If you are a PARKLU customer, under the CCPA you are considered a “Business” and PARKLU is the “Service Provider” in most cases. As such, we are responsible for processing the Personal Information our Service captures on your Account and is stored on our servers.
Although we do not sell personal information in exchange for any monetary consideration, the CCPA defines a sale in a way that may include allowing third parties to receive certain combined Personal Information such as, depending on how you use the Services, when we are sharing device information (such as browser type and version, operating system, preference settings, unique device IDs and language and other regional settings) and identifiers (names, job titles, IP address, email address), commercial information (such as record of the Services purchased or demos requested), usage information and Internet activity such as browsing history (clicks, scrolling, browsing times and load times) or app usage, cookie information and customer feedback with website analytics companies and providers of customer relationship management, consulting, email, product feedback services and security and other operations vendors.
We do share Personal Information as necessary for certain business purposes, as defined by the CCPA (Cal. Civ. Code 1798.140(d)) and as described above and in the section “How Do We Use the Data Collected?” of this Policy.
California residents may opt out of the sale of their Personal Information. While PARKLU does not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. We wish to provide you with control over how your Personal Information is collected and shared. If you would like to opt out of PARKLU's use of your Information for such purposes (when considered as a sale), you may do so within the Services.
Additional disclosure:
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer:
- Identifiers (name or alias, online identifier, IP address, email address and cookies);
- Internet or other electronic network activity information (browsing history and time, search/click history, loads, browser type and version, operating system, preference settings, unique device IDs and language and other regional settings).
Under the CCPA, you have the following rights:
- Right to Know and Access: You have the right to request that we disclose to you the (i) categories of Personal Information we collect, use, or share, (ii) purposes for which the Personal Information is collected or used by us, (iii) categories of sources from which we collect the Personal Information, and (iv) information about our data practices;
- Right to Delete: You have the right to request that we delete the Personal Information we currently hold about you. If you ask us to delete some or all of your information that is needed to provide the Service to you, you may no longer be able to access or use the Services.
- Right to Equal Service: We will not discriminate against you for exercising any of these rights.
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 115 E 23rd Street, Floor 6, New York, NY 10010, USA. The request should attest to the fact that you are a California resident, and provide a current California address.
If you have additional questions about this section or how to exercise your rights under the CCPA, please contact us at privacy@parklu.com. The CCPA allows California consumers to designate an authorized agent to exercise their rights under CCPA. If we receive a request from an agent, then we have the right to verify that you indeed want to take the action requested by the agent and will do so by contacting you directly.
How do I Review or Change my Personal Information?
If you would like to review or change your Personal Information, we will deal promptly and appropriately with any inquiries unless we have to keep that information for legitimate business or legal purposes. However, if your requests are deemed to be excessive or complex a small fee may be charged and a time-period extension may apply.
You can contact us at: privacy@parklu.com or directly reach out to your Account manager.
How Can I Delete My Account?
Should you ever decide to delete your Account, you may do so by emailing privacy@parklu.com or your Account manager. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.
Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion may remain stored by us for the period of time needed for us to conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
Your Rights under applicable Data Protection Laws
Under the Applicable Data Protection Laws, Users have the right to ensure:
- that they have been adequately and transparently informed about the processing activities;
- we process Users’ Personal Information fairly and lawfully.
- Users’ Personal Information are accurate.
- Users’ Personal Information are secure.
In particular, Users can:
- ask confirmation of whether, and where, a Controller is processing Personal Information;
- ask us to provide details of the Personal Information we hold on you (information about the purposes of the processing, the categories of Personal Information being processed, the categories of recipients with whom the Personal Information may be shared, and obtain a copy of the Personal Information being processed (see the contact information below);
- know how long we keep your Personal Information;
- exercise their rights to erasure, to rectification, to restriction of processing and to object to processing, or to complaint to relevant authorities;
- obtain information regarding the source of the Personal Information if the Personal Information were not collected directly from them; and
- obtain information about the existence of, and an explanation of the logic involved in, any automated processing that has a significant effect on you or other data subjects.
To exercise any of these rights, please contact us at privacy@parklu.com or by mail to Park Lu - 18/F, Suite D, High Block, H Code, 45 Pottinger Street, Central, Hong Kong - Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
What Happens When There Are Changes to this Policy?
Although most changes are likely to be minor, PARKLU will occasionally update this Policy to reflect user and customer feedback about the Services changes and clarifications will take effect immediately upon their posting. PARKLU encourages you to periodically review this Policy and associated Notices to be informed of how we are protecting your information and check for any changes. We have the sole discretion to modify this Policy and the Notices. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the homepage of the PARKLU Services.
How to contact us?
If you have any questions or comments regarding this Policy or our privacy practices using the PARKLU Services, please send us a detailed message to privacy@parklu.com. We will make every effort to resolve your concerns. You may also contact us by postal mail or email at:
If you are a resident of or have your principal place of business in China:
Launchmetrics/PARKLU
Attention: Legal - Privacy
Email：privacy@parklu.com
18/F, Suite D, High Block, H Code,
45 Pottinger Street, Central,
Hong Kong
You may also contact our Data Protection Officer at: dpo@launchmetrics.com.
Launchmetrics Services
If you use the Launchmetrics Services, the following privacy policy provides additional information about the Launchmetrics Cloud.
English Version Controls
Non-English translations of this Privacy Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.
