CleanDesktop Privacy Policy

Last Updated: January 17, 2024

Effective Date: January 17, 2024

 

"CleanDesktop" refers to the client application, official website, and third-party applications provided by Kangaroo Office Limited and its affiliates (hereinafter referred to as "we") that are legally owned and operated under the name CleanDesktop.

 

As the operator of CleanDesktop, we recognize the significance of personal information to you. In accordance with applicable laws and regulations, we are committed to protecting your personal information and privacy. We have formulated this privacy policy and explicitly advise you to carefully read and understand it before using CleanDesktop and related services to make informed choices.

 

Summary

This privacy policy outlines how we handle personal information in various scenarios. When you activate or use CleanDesktop, we process relevant information to fulfill the functions and services you choose or to comply with legal requirements. You have the option to refuse the processing of certain information beyond what is necessary for CleanDesktop's basic functions and services. However, this may result in us being unable to provide corresponding functions or services. We will provide detailed explanations in the privacy policy, with important terms related to your personal information rights highlighted in bold for your special attention.

 

The following sections will help you understand how we collect, use, store, transmit, disclose, and protect personal information. It will assist you in searching, correcting, researching, supplementing, deleting, copying and transferring personal information. Important information regarding your personal information rights is highlighted in bold, please pay special attention.

 

I. Scope of Application

II. How We Collect and Use Your Personal Information

III. How We Use Cookies and Similar TechnologiesIV. How We Share, Transfer, and Publicly Disclose Your Personal Information

V. How We Protect Your Personal Information

VI. How You Manage Your Personal Information

VII. How We Handle Personal Information of Minors

VIII. How Your Personal Information Is Transferred Globally

IX. Revision and Notification of the Privacy Policy

X. How to Contact Us

 

I. Scope of Application

This policy applies to all products and/or services provided to you through various terminals (referred to individually or collectively as the "platform"), including CleanDesktop's official website and PC terminal. If a specific platform has unique personal information processing activities, we will provide explanations. If a platform has a separate privacy policy, that policy takes precedence; otherwise, this policy applies.

 

Please note that this policy does not apply to the following:

 

1. Information and/or services provided by third parties in our products and/or services or linked to third-party services (including third-party applications, websites, products, services, etc.), operated by third parties with their own personal information processing rules explained separately to you.

 

2. Other products and/or services not provided by CleanDesktop.

 

II. How We Collect and Use Your Personal Information

We collect and use your personal information for the following purposes:

 

(I) Account Registration and Login

 

1. Registration/Login: When you register or log in to our products and/or services, to facilitate a smooth registration/login process, you need to provide your email. Refusal may lead to registration/login failure.

 

2. Authorized Login: When you use a third-party platform (e.g., Facebook account) to authorize login, you authorize us to access relevant information under that third-party account (including nickname, avatar, subject to your authorization scope) for binding with the CleanDesktop account and improving your network profile information.

 

3. Profile Maintenance: You can choose to fill in your nickname and avatar, enhancing our ability to provide a more personalized experience. Failure to fill in this information does not affect your use of other functions of our products and/or services. When uploading/changing avatars, we request your permission and collect the uploaded/changed image information.

 

(II) Purchasing Products and Services

 

1. Ordering and Order Management

 

When purchasing goods/services, we need to collect the following personal information based on the type of goods/services: your device information, recipient information (including name, email, contact phone, invoice information; if the recipient is not you, you must ensure you have obtained the relevant authorization), transaction goods/services information, order number, order time, order amount, and your remarks. We collect this information to assist you in completing the purchase, ensure the security of your transaction, query order information, and provide customer service. Additionally, to help you understand and manage order information, we collect information generated during your use of our services.

 

2. Payment

 

To complete order payments and ensure transaction security, we need to collect your transaction amount, order time, order merchant, order number, payment method, payment account (Paypal account information or bank card account information), and payment status. We share some or all of this information securely with payment institutions (such as Paypal and other financial institutions).

 

3. Delivery

 

After successfully placing an order, to facilitate the smooth, secure, and accurate delivery of goods/services, third-party merchants unavoidably gain access to your recipient information. Simultaneously, for the purpose of providing after-sales and dispute resolution services, we may need to promptly learn and confirm the delivery progress and status. You agree that we may collect information related to delivery progress from the aforementioned entities.

 

(III) Safe Operation

 

To enhance the security of the services provided on the CleanDesktop platform, protect the personal and property safety of users, the public, or yourself from infringement, prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, and intrusions, and more accurately identify violations of laws, regulations, and CleanDesktop-related agreements, we may use or integrate the following information to comprehensively assess your account and transaction risks, perform identity verification, detect and prevent security incidents, and take necessary records, audits, analyses, and disposal measures in accordance with the law.

 

1. Device Information: Based on specific permissions granted during platform installation and usage, we will receive and record device-related information such as device model, settings, unique device identifiers (software and hardware characteristics), device location information (e.g., IP address), network status information (e.g., BSSID), and installed application lists.

 

A unique device identifier will be generated when you first use the software, facilitating account security management, notifications, and operational activities.

 

2. Log Information: When using products or services provided by CleanDesktop, we automatically collect detailed usage information as part of network log storage, including actions like organizing files.

 

Please note that individual information mentioned above cannot identify specific individuals. After de-identification, this information may be used for internal research, statistical analysis, and forecasting, improving the content and layout of our platform and services, supporting business decisions, and enhancing our products and services.

 

(IV) Self-start or Associated Start Instructions

 

To ensure the application can receive client push notifications while running in the background and for the auto-start feature, the application requires self-starting capability.

 

(V) Marketing Notifications

 

To promptly inform you of CleanDesktop's promotional activities, we may periodically send emails to the email address you provided during registration, allowing you to receive the latest promotions from CleanDesktop.

 

(VI) Rules of Use

 

After collecting your personal information, we will strictly adhere to the following rules:

 

1. We will strictly comply with laws, regulations, and this privacy policy when using your personal information.

2. We will use technical means to encrypt and de-identify your personal information in accordance with the law.

3. When you deactivate your account, we will delete your personal information.

4. If we need to use your personal information for purposes not specified in this policy, we will seek your consent again.

 

(VII) Exceptions to Authorized Consent

 

According to relevant laws and regulations, collection of your personal information is not required to obtain your authorized consent in the following situations:

 

1. Necessary for the conclusion and performance of contracts where you are a party.

2. Necessary for the fulfillment of legal obligations or duties.

3. Necessary to respond to public health emergencies or protect the life, health, and property safety of individuals in emergency situations.

4. Implementation of news reporting and public opinion supervision for public interest within a reasonable scope in accordance with the law.

5. Processing of personal information that is voluntarily made public or already lawfully disclosed within a reasonable scope as stipulated by this law.

6. Other situations as stipulated by laws and regulations.

 

Please understand that the features and services we provide are continually evolving. If a certain feature or service is not mentioned in the above explanation and involves the collection of your information, we will inform you separately through page prompts, interactive processes, announcements, etc., to explain the content, scope, and purpose of information collection and seek your consent. If we cease operating the CleanDesktop platform or services, we will promptly cease ongoing personal information collection activities, notify you of the cessation through individual communication or announcements, and delete or anonymize the held personal information.

 

III. How We Use Cookies and Similar Technologies

 

To ensure the normal operation of the platform, we store small data files called Cookies on your computer or mobile device. Cookies typically contain identifiers, site names, and some numbers and characters. With Cookies, we can store your preferences and other data to help you avoid repetitive actions like filling in personal information. You can manage or delete Cookies according to your preferences. However, doing so will require you to manually change user settings each time you visit CleanDesktop, and the previously recorded information may be deleted, potentially affecting the security of the services you use.

 

IV. How We Share, Transfer, and Publicly Disclose Your Personal Information

 

(I) Sharing

 

We will not share your personal information with companies, organizations, and individuals outside the CleanDesktop platform service providers, except in the following cases:

 

1. Sharing with Explicit Consent: With your explicit consent, we will share your personal information with other parties.

2. Legal Sharing: We may share your personal information externally in accordance with legal regulations, litigation dispute resolution needs, or requests from administrative or judicial authorities.

3. Sharing with Affiliate Companies: CleanDesktop accounts are interconnected, but various platforms may be provided by different affiliate companies. Most of the products/services we provide cannot be completed individually. Therefore, for your convenience, we will share all the information collected in the first article of this policy with our affiliate companies. The use, processing, and collection of your information by affiliate companies are also subject to the purposes stated in this privacy policy. If affiliate companies need to change the processing purposes of personal information, they will seek your authorization again.

4. Sharing with Authorized Partners: We may entrust authorized partners of the following types to provide relevant services for you or represent us in performing functions. We will only share your information for legitimate, legal, necessary, specific, and clear purposes stated in this privacy policy. Authorized partners can only access the information needed to perform their duties and cannot use this information for any other purpose.

 

Types of Authorized Partners and Main Purposes of Authorization are listed as below:

 

4.1 Specific Functions: When collaborating with software service providers, smart device providers, or system service providers to offer you services, we may collect relevant device information (such as hardware model, operating system version, International Mobile Equipment Identity (IMEI), network device hardware address (MAC), network status information (BSSID)), and application information (such as software installation list-related information). After de-identification, this information may be provided to the aforementioned providers to facilitate the realization of specific functions.

 

4.2 Product Analysis: To analyze the usage of our services and enhance user experience, statistical data on product usage (crashes, flashbacks) may be shared with third parties. This data is difficult to identify with other information to recognize your personal identity.

 

(II) Transfer

 

We will not transfer your personal information to any company, organization, or individual except in the following cases:

1. With your explicit consent, we will transfer your personal information to other parties.

2. In cases of mergers, acquisitions, or bankruptcy liquidation involving the transfer of personal information, we will require the new entity holding your personal information to continue adhering to this privacy policy. Otherwise, we will request the new entity to obtain your authorization again.

 

(III) Public Disclosure

 

We will only publicly disclose your personal information in the following cases:

1. After obtaining your explicit consent.

2. Based on legal disclosure: In situations where legal procedures, litigation, or government regulatory agencies mandate disclosure, we may publicly disclose your personal information.

 

(IV) Exceptions to Obtaining Prior Consent for Sharing, Transfer, and Public Disclosure of Personal Information

 

Prior consent is not required for sharing, transferring, or publicly disclosing your personal information in the following situations:

1. Related to national security or defense security.

2. Related to public safety, public health, significant public interests.

3. Related to judicial or administrative law enforcement for crime investigation, prosecution, trial, and judgment execution.

4. Difficult to obtain the individual's consent but necessary to protect significant legal rights such as life and property.

5. Personal information voluntarily made public by the individual.

6. Collection of personal information from legally disclosed information, such as through lawful news reporting, government information disclosure, and other channels.

 

V. How We Protect Your Personal Information

 

1. We have implemented security measures that comply with industry standards to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. We will take all reasonable measures to protect your personal information, including using encryption technology to ensure data confidentiality, deploying trusted protection mechanisms to prevent malicious attacks, and implementing access control mechanisms to ensure only authorized personnel can access personal information.

 

2. Retention Period: We retain your personal information for the necessary and shortest period required to provide our products and/or services. For example, when you use our registration/login function, we need to collect your email. During your use of this function, we need to continuously retain your email to provide the function to you normally and ensure the security of your account and system.

 

After you voluntarily delete personal information, deactivate your account, or exceed the necessary storage period, we will delete your personal information, except as otherwise required by laws and regulations (e.g., the "E-commerce Law" stipulates a minimum retention time of three years for commodity and service information and transaction information from the completion of the transaction). For example, the "Network Security Law" requires the retention of relevant network logs for no less than six months according to regulations.

 

Our determination of the necessary storage period for personal information is primarily based on the following criteria: (1) maintaining relevant transaction and business records to address possible queries or complaints; (2) ensuring the security and quality of services we provide to you; (3) whether you agree to a longer retention period.

 

3. We only allow employees and partners who need to know this information to access personal information and have set strict access control, permission approval processes, and monitoring mechanisms for this purpose. We also require all personnel who may have access to your personal information to fulfill corresponding confidentiality obligations. If a third party fails to fulfill confidentiality obligations, they may be held legally responsible, and we may terminate the cooperation.

 

4. In the unfortunate event of a personal information security incident, we will inform you according to legal requirements: the basic situation of the security incident and possible impacts, measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and your remedial measures. We will notify you of the event-related information through email, push notifications, etc. If it is difficult to inform individual information subjects one by one, we will adopt reasonable and effective methods to announce it. At the same time, we will report the disposal of personal information security incidents to regulatory authorities as required.

 

VI. How You Manage Your Personal Information

 

We highly value your rights as the subject of personal information and strive to protect your control over your personal information. We provide various ways for you to conveniently and securely manage privacy settings and personal information, ensuring the security of your personal information.

 

(I) Query, Correct/Modify, and Delete Your Personal Information

 

You can query and manage your personal information through various paths within our products:

 

1. Personal Information: You can use CleanDesktop - Personal Center to query, correct/modify your personal information, including your profile picture and nickname.

 

2. Account Information: You can use CleanDesktop - Personal Center - Account Security to query or change the email and third-party accounts associated with your account.

 

3. Order Services: You can use CleanDesktop - Personal Center - Order Records to query your orders.

 

4. If you discover errors in the personal information we process about you, you have the right to submit correction/modification requests through our customer service or other channels, demanding corrections/modifications. However, for security and identity verification reasons, you may be unable to modify certain initial registration information submitted during registration.

 

5. In the following situations, you can directly request the deletion of your personal information, except for data anonymization or as otherwise stipulated by laws and regulations:

 

   (1) The purpose of processing has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose.

   (2) We cease to provide products and/or services, or the retention period has expired.

   (3) You withdraw your consent.

   (4) We violate laws, regulations, or agreements in processing your personal information.

 

If we decide to respond to your deletion request, we will also notify third parties who have obtained your personal information from us to promptly delete it, unless otherwise stipulated by laws and regulations, or these third parties have obtained your authorization. After you delete information from our services, we may not immediately delete the corresponding information in the backup system but will do so when updating the backup.

 

(II) Change or Withdraw the Scope of Your Authorized Consent

 

Each business function requires some basic personal information to be completed. However, if you wish to withdraw consent for us to collect, use, and disclose additional personal information, you can inform customer service or contact us through the contact information in this policy. We will process your request and stop collecting, using, and disclosing your personal information within a reasonable time after receiving your message or notification.

 

Please understand that some services/functions require the processing of your personal information to be realized. Therefore, if you withdraw your consent/authorization for us to process your information, it may affect your use of the corresponding services/functions but will not affect your use of other services/functions. Additionally, withdrawing your consent/authorization does not affect activities conducted based on your consent/authorization before withdrawal.

 

(III) Account Cancellation

 

You can cancel your CleanDesktop account through the following methods:

 

1. Online Cancellation: You can go to CleanDesktop - Personal Center - Account Security - Account Cancellation to cancel your account.

2. Customer Service Cancellation: You can contact our customer service to cancel your account.

 

After you cancel your account, the content, information, data, and unused assets under that account will be inaccessible and unrecoverable. We will stop providing products or services, and, based on your request, we will delete your personal information, except as otherwise stipulated by laws and regulations.

 

(IV) Responding to Your Requests

 

To ensure security, when you assert the above rights, you may need to provide a written request or prove your identity in other ways. We will process your request after verifying your identity. In general, we will respond within [15] days. For reasonable requests, we do not charge fees in principle, but for repeated requests beyond a reasonable limit, we may charge reasonable fees. We may refuse requests for information not directly related to your identity, unreasonably repetitive information, or requests that require excessive technical means (such as developing a new system or fundamentally changing existing practices), pose risks to the legitimate rights and interests of others, or are impractical. In these cases, we may refuse your request.

 

In the following situations, we may be unable to respond to your request as required by laws and regulations:

 

1) Related to national security or defense security.

2) Related to public safety, public health, significant public interests.

3) Related to criminal investigation, prosecution, trial, and execution of judgments.

4) There is sufficient evidence that the data subject has subjective malice or abuses rights.

5) Responding to your request would cause serious harm to your or other individuals' legitimate rights and interests.

6) Involves trade secrets.

 

VII. How We Handle Personal Information of Minors

 

Our products, websites, and services are only intended for adults, and minors (as referred to in this policy, specifically those under the age of eighteen) are not allowed to create their own user accounts. If we discover that we have collected personal information from a minor, we will make efforts to promptly delete the relevant personal information of the minor.

 

VIII. How Your Personal Information Is Transferred Globally

 

In accordance with legal regulations, we store user personal information collected within the United States. We do not transfer the above information overseas. In cases where it is necessary to transfer information overseas, we will assess and verify in accordance with relevant national laws, and only proceed with your separate consent.

 

IX. Revision and Notification of the Privacy Policy

 

(I) To provide you with better services, CleanDesktop and related services will be updated and changed from time to time. We will timely update this policy, and such updates constitute a part of this policy with equivalent effect. However, without your explicit consent, we will not reduce the rights you enjoy under the currently effective policy.

 

(II) After updating this policy, we will release the updated version on CleanDesktop and inform you of the updated content through notifications, announcements, or other appropriate means before the updated terms take effect, allowing you to understand the latest version of this policy promptly.

 

(III) If the types of changes to this policy involve changes in the processing purposes, processing methods, or types of personal information processed, we will obtain your consent again. If you do not agree with the updated policy, you have the right and should immediately stop using our products and/or services. If you have any doubts about the updated policy, please contact us promptly through the contact information provided in this policy.

 

X. How to Contact Us

 

(I) If you have any questions, opinions, or suggestions regarding this policy or your use of our services, we have set up the email service@kangaroooffice.com for such matters. You can contact us through this email, with the email subject indicating "Data Issues + Feedback User ID," providing your complaint content and relevant materials.

 

(II) We will promptly review the issues involved and respond to you within 15 working days after verifying your user identity.