Gtech Digital Co., Ltd(“Gtech CN”) is an e-commerce solutions provider that develops e-commerce and omni-channel software on behalf of customers, as well as providing services to help customers execute their e-commerce strategies and e-commerce operations.
Although we encourage you to read this entire Privacy Statement, this is a summary of some of the more important aspects of the Privacy Statement:
  • Each Offering may include its own specific privacy policy. You should carefully read the privacy policy of any Offering before accessing or using that Offering.
  • We may collect both Personal Data and other information from you through a variety of sources, including Personal Data we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as Subsidiaries, publicly available information sources (including information from your publicly available social media profiles), and other third parties.
  • We will not use or share your Personal Data except as described in this Privacy Statement.
  • The failure to provide us with your Personal Data may interfere with our ability to conduct business with you, such as purchasing Offerings or process your transactions.
  • Where applicable, we honor opt out instructions from you for certain uses of your Personal Data under this Privacy Statement, such as, for example, when you opt out of receiving marketing email communications from us or request us to delete your Personal Data. However, by opting out of receiving marketing email communications you will not receive information about incentives and sales promotions.
  • We use appropriate technical and organizational controls to secure and protect your Personal Data, but we cannot ensure or warrant that your Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities.
The principles of Gtech CN with respect to the processing of Personal Data are as follows: (1) Personal Data will be processed fairly and lawfully, (2) Personal Data will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) Personal Data collected by Gtech CN will be adequate, relevant, and not excessive in relation to the purposes for which it is collected, (4) Personal Data collected by Gtech CN will be accurate and, where necessary, kept up to date to the best of our ability, (5) Personal Data will be protected against unauthorized access and processing using appropriate technical and organizational security measures and controls; and (6) Personal Data collected by Gtech CN will be retained as identifiable data for no longer than necessary to serve the purposes for which the Personal Data was collected.

If Gtech CN engages in the processing of Personal Data for purposes other than those specified in this Privacy Statement, Gtech CN will provide a notice of these changes, the purposes for which the Personal Data will be used, and the recipients of Personal Data.
Collection of Information
Gtech CN does not collect any Special Categories of Personal Data about you unless required by law (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, and sexual orientation).
Gtech CN collects your Personal Data as follows:
Information You Provide Voluntarily. We may collect Personal Data directly from you when you voluntarily provide it to us. For example, when you communicate with us over the telephone or through the Website by way of email, online chat, web form, or online account registration to obtain access to Offerings, register for an event or training, sign up for marketing, promotional, or informational emails or communications, purchase an Offering, ask questions, attempt to resolve any issues related to the Website or Offerings, submit a job application, or submit feedback and comments.

The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Data.
Information that We Collect Automatically. When you visit our Website, we may collect certain information automatically from your Device. In some countries, including countries in the European Economic Area, this information may be considered Personal Data under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, your Media Access Control (MAC) Address, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and Other Website Usage Information” below.
From Other Users. We may receive Personal Data about you from other users of the Website when they provide information to us. For example, we may receive information when they communicate with you or with us through the Website.
From Third-Party Providers. Gtech CN may also obtain Personal Data from third parties that have obtained or collected information about you and that have the right to provide that Personal Data to us. Gtech CN will only obtain this Personal Data where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us. For example, if you register for the Website using a third-party service or through a third-party website or service, the information you provide to that third-party will be provided to us to establish your account on the Website. We may also contract with third parties that are in the business of providing information to businesses such as ours to verify certain information about you or obtain information. We may use the Personal Data about you we receive from a third-party outside of the Website in accordance with the terms we establish with that third-party and within the limits of the law. We may also obtain Personal Data at trade shows or events where you have attended and provided your consent to collect your Personal Data. We may also obtain Personal Data from publicly-available sources such as open government databases or other data in the public domain.
Cookies and Other Website Usage
A “cookie” is a small text file that is stored on a user’s Device. Cookies allow us to collect information such as browser type, time spent on the Website, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Website.

Generally, the cookies that are used on the Website can be broken down into the following categories:
  • Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website or use a shopping cart.
  • Analytical/performance cookies. These cookies are used to analyze how the Website is used and to monitor its performance, which allows us to improve your experience in using the Website. These cookies help us to tailor the content of Website to reflect what users find most interesting and to identify when technical issues with the Website arises. We may also use this data to compile reports to help us to analyze how the Website is used, what the most common issues are and how we can improve the Website.
  • Functional/tracking cookies. These cookies enable us to recognize repeat visitors to our Websites. By matching an anonymous, randomly generated identifier, a tracking cookie keeps track of where a user of our Websites came from, what search engine they may have used, what link they clicked on, what keyword they used and where they were in the world when they accessed the Website. By monitoring this data, we can make improvements to our Website.
  • Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
  • Session cookies. These cookies are used 'in-session' each time you visit and then expire when you leave a Website or shortly thereafter: they are not stored on your Device permanently, do not contain any Personal Data and help by minimizing the need to transfer Personal Data across the internet. These cookies can be deleted, or you can refuse to allow their use, but this will hamper the performance and your experience in using the Website. These cookies also take time stamps that record when you access the Website and when you leave the Website.
  • Persistent Cookies. This type of cookie is saved on your Device for a fixed period (sometimes for a few hours, sometimes for a year or longer) and is not deleted when the browser is closed. Persistent cookies are used where we need to remember who you are for more than one browsing session. For example, this type of cookie can be used to store your language preferences, so that they are remembered for the next visit to the Website.
You can choose to accept or decline cookies. Many of our Websites include cookie banners that allow you to proactively choose the types of cookies you prefer. Additionally, most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. However, please be aware that if you disable or reject cookies, some features and services on our Websites may not work properly because we may not be able to recognize and associate you with your account(s). In addition, the Offerings we provide when you visit us may not be as relevant to you or tailored to your interests.

A “web beacon” (also known as a clear pixel or pixel tag) includes an electronic image imbedded in the Website interface that allows us to recognize when you visit that area of the Website. These may also be used in connection with some Website pages and HTML-formatted e-mail messages to, among other things, track the actions of Website users and e-mail recipients, measure the success of our marketing campaigns, and compile statistics about Website usage and response rates.

Please note that the use of cookies or these other tracking technologies by Gtech CN’s third-party service providers is not covered by this Privacy Statement. Gtech CN does not have access or control over third-party cookies. Gtech CN’s service providers may use persistent cookies for advertising and retargeting purposes. We may tie the information gathered from third-party cookies to Gtech CN’s users’ Personal Data, and we will use the combined information in accordance with this Privacy Statement.
Use of Information
Gtech CN may use your Personal Data for a variety of purposes (the “Purposes”), including to:
• Register you as a new customer;

• Provide, maintain, and improve the Website and our Offerings, including to operate certain features and functionality of the Website;

• Understand user preferences to enhance users’ experience with Gtech CN and its Subsidiaries, contractors, and business partners;

• Research and analyze the effectiveness of the Website and the marketing, advertising and sales efforts of Gtech CN, its Subsidiaries, contractors, and business partners;

• Collect account receivables owed by customers of Gtech CN;

• Process orders, deliveries and payments made through the Website;

• Develop additional Offerings;

• Process job applications;

• Comply with a legal obligation or respond to lawful requests by public authorities (including national security or law enforcement requirements);

• Manage our everyday business needs;

• Enforce compliance with our Terms of Use and applicable law;

• Prosecute and/or defend a court, arbitration or similar legal proceedings;

• Communicate directly with you by sending you newsletters, surveys, promotions and special offers or information about new products and services on an ongoing basis in accordance with your marketing preferences. You can unsubscribe from our marketing communications at any time by clicking “Unsubscribe” at the bottom of the email or by contacting us using the “Questions and Contact Information” details below.

• Communicate directly with you by phone to respond to customer service inquiries or comments through the Website, social media or otherwise, to discuss issues relating to your account or the Website, and to provide customer support.

• Deliver advertising to you, including to help advertisers and publishers serve and manage ads on the Website or on third-party sites, and to tailor ads based on your interests and browsing histories. Please see the section on Cookies and Other Website Usage Information for additional information related to such advertising and your related controls;

• Monitor and record your call, emails and text messages, social media messages and other communications (as permitted by local law) in relation to your dealings with us;

• Comply with our contractual or legal obligations to share data with credit reference agencies, fraud prevention agencies and law enforcement agencies;

• Compile aggregated statistics about the operation and use of our Website and to better understand the preferences of the visitors of our Website; and

• Other Purposes: To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
We may combine and enhance the Personal Data we collect about you with other information we receive from third parties.

We may also use the Personal Data we collect about you through the Website to generate anonymized, aggregated data. When we do so, we ensure that the anonymized, aggregated data is no longer personally identifiable and may not later be used to identify you. This will include, by way of example, storing the anonymized, aggregated data separately from any Personal Data.

Change of Purpose. 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Information Sharing
We may disclose your Personal Data as follows:

Vendors. Gtech CN may share Personal Data about you with the third-party vendors that make Offerings available through us. For example, we may share your Personal Data with a third-party vendor if you purchase or access an Offering through us, or an Gtech CN reseller or distributor, and that vendor requires verification of an Offering purchase in order to register that Offering. We may also share your Personal Data with a third-party vendor if that vendor co-sponsors a marketing activity with us to verify your participation in the marketing activity.

Resellers and Distributors. Gtech CN may share your Personal Data with the resellers and distributors that purchase Offerings available through the Website. For example, we may share your Personal Data if you purchase or access an Offering through a reseller or distributor, and that reseller or distributor leveraged our reseller tools and services.

Third-party Service Providers. Gtech CN may provide your Personal Data to third-parties that provide services to assist us with the Website and with achieving the Purposes. For example, these third parties may include providers of customer service, payment processing, email and messaging support, hosting, management, maintenance, information analysis, offering fulfilment or delivery, or other services we may receive on an outsourced basis. We will require that these third parties use your Personal Data only as necessary for such reasons and protect your Personal Data consistent with this Privacy Statement and applicable law. A list of third-party service providers is available upon request.

Subsidiaries and Business Units. Gtech CN may share your Personal Data with our Subsidiaries, regardless of whether these entities share the Gtech CN brand. We may also share your Personal Data with other business units that also offer products or services under the Gtech CN brand or one of our other brands. Our Subsidiaries and business units will use your Personal Data we share with them in a manner consistent with this Privacy Statement.

Other Users. Gtech CN may share your Personal Data with other users when you elect to interact with those users (or request that we communicate with them on your behalf) through the Website. This may include facilitating communications with other users or enabling posting of Personal Data to areas of the Website accessible by other users. You should be aware that any Personal Data (or other information) you provide in these areas may be read, collected, and used by others who access them.

Law Enforcement and Safety. Gtech CN may share your Personal Data with any competent law enforcement, regulatory, government agency, court, other governmental officials, or other third-party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

Sale or Acquisition of Assets. If Gtech CN transfers ownership or control of any portion of Gtech CN or the Website to an actual or potential buyer, whether in the context of an acquisition, merger, reorganization, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may transfer your Personal Data to that actual or potential buyer, provided that the use of your Personal Data by that third-party remains subject to applicable law.

Others. We may share your Personal Data with any other person with your consent to the disclosure.

We may also share aggregated, anonymized data with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information we collected through your use of our Website. If we are required under applicable law to treat such information as Personal Data, then we will only disclose it as described above.

Gtech CN does not sell your Personal Data to third parties.
Other Important Privacy Information
Security of Personal Data. Gtech CN uses appropriate technical and organization controls and measures to secure and protect your Personal Data from unauthorized loss, misuse, and disclosure, such as strong user access controls, segmented network architecture, and comprehensive employee policies and training. Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be 100% secure. As a result, while Gtech CN attempts to protect all Personal Data, Gtech CN cannot ensure or warrant that Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network. Gtech CN will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable foreign, federal, state, and local laws) stored by or for us, in accordance with applicable laws.

Legal Basis for Processing Personal Data (EEA and UK Visitors Only). If you are a visitor from the European Economic Area or the United Kingdom, our legal basis for collecting and using the Personal Data information described above will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only (i) where we need the Personal Data to perform a contract with you (such as to fulfill your purchase of an Offering), (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third-party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services and Offerings to you, and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests, and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

If we collect and use your Personal Data based upon your consent, the consequences of denying or withdrawing consent will be made known at the time your consent is provided.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided under the “Questions and Contact Information” heading below.

Accuracy. It is your responsibility to provide Gtech CN with accurate Personal Data. Except as otherwise set forth in this Privacy Statement, Gtech CN shall only use Personal Data in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, Gtech CN shall take reasonable steps to ensure that Personal Data is accurate, complete, current and relevant to its intended use.

Retention Period. We retain Personal Data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with an Offering you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

If you are a resident of the European Union or the UK, all the Personal Data related to you and received and stored by Gtech CN are erased after 5 years, save for any Personal Data in documents and files we must keep for a longer period under applicable laws. For example, we cannot erase personal data appearing on VAT invoices before we can delete the invoices from our systems.
Your Data Protection Rights. You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the contact details provided under the “Questions and Contact Information” heading below.

• In addition, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us using the contact details provided under the “Questions and Contact Information” heading below.

• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Questions and Contact information” heading below or access our preference center.

• Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

• You have the right to complain to a data protection authority about our collection and use of your Personal Data.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Preference Center. Many of our Subsidiaries utilize a preference center that allow you to opt out or opt down to receiving messages and communications from us. You can select or unselect your communication preferences at any time through the web form provided by that Affiliate.

Children. The Website is intended solely for use by individuals 18 years of age and older and thus is not directed to children under 18 years of age. Gtech CN does not knowingly solicit or collect Personal Data from children under 18 years of age.

Do Not Track. Certain web browsers and other devices you may use to access the Website may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the Website does not respond to "Do Not Track" signals. We do not modify your experience on the Website or modify the Personal Data we collect from you through the Website, based on whether such a preference is indicated.

Your California Privacy Rights. The California Consumer Privacy Act grants California residents certain rights in regards to our collection of their personal information. These rights include:

• The right to be informed of (1) what personal information is collected, (2) the categories of sources from which personal information is collected, (3) the business or commercial purpose for collecting or selling personal information; (4) the categories of third parties with whom we share personal information; and (5) the specific pieces of personal information we have collected about the consumer;

• The right to request deletion of their personal information that has been collected; and

• The right to opt out of the sale of their personal information.

To opt-out of the sharing of your personal information to third parties for direct marketing purposes or otherwise exercise your rights under this section, please contact us using the contact details provided under the “Questions and Contact information” heading below.

Sensitive Information. Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through this Website or otherwise to us. In those cases where we may request or invite you to provide sensitive personal data, we will do so with your express consent.

Third-party Websites. In addition to providing access to Offerings, the Website may include links to other websites and web services. This Privacy Statement does not apply to those websites and services and the privacy practices of those websites and services may differ from those described in this Privacy Statement. If you submit Personal Data to any of those other websites or services, your Personal Data is governed by the privacy policies applicable to those websites and services. Gtech CN encourages you to carefully read the privacy policy of any website or web service you visit.

Compliance. Gtech CN will use a self-assessment approach to verify compliance with this Privacy Statement and periodically verify that the Privacy Statement is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

If you believe that your Personal Data has been processed or disclosed in violation of this Privacy Statement, Gtech CN encourages you to raise any concerns using the contact information provided in this Privacy Statement using the contact details provided under the “Questions and Contact information” heading below. Gtech CN will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Data.

Revisions. Gtech CN may from time to time revise this Privacy Statement in its sole and absolute discretion to reflect changes in our business practices. If we revise this Privacy Statement, we will notify you by posting the updated Privacy Statement on this Website or by sending you a notification by email. Changes to the Privacy Statement will become effective and will apply to the information collected starting on the date Gtech CN posts the revised Privacy Statement on the Website. If we are required by applicable data protection laws to seek your consent to any changes in use of your Personal Data described in our updated Privacy Statement, then we will do that.
Questions and Contact Information
If you have any questions or concerns about this Privacy Statement, the privacy practices of Gtech CN, our collection or use of your Personal Data, or you wish to access or delete your Personal Data, please contact us at: privacy@gtechdigi.com.