Chemical Compliance
Intelligence & Solutions
Privacy Policy
Last revised on January 14th, 2020
1. INTRODUCTION.

ChemLinked is an exciting unique platform for the chemical, food, cosmetic and agrochemical industry that focuses on regulatory issues in Asia Pacific Area, especially China. It provides regulatory news & event updates, expert articles, compliance guidance and regulatory/inventory databases as well as off-line compliance guidance. Together, these tools will keep you continually updated with chemical, food, cosmetic and agrochemical regulatory issues in Asia Pacific area and assist you to manage your responsibilities under the management systems of different regions.

Here are the two main types of information on ChemLinked:

Profile Information. Once you post your comments on ChemLinked such as News or Expert Articles, etc., your name will be accessible to the public.

Content publish. You can also write your articles on any issues or topics related to chemical, food, cosmetic and agrochemical regulations and share with other members or send them to our editorial team. Once accepted, your articles will be published on ChemLinked website, Newsletters, e-publications with a remuneration rewarded.

For the purpose of the General Data Protection Regulation (“GDPR”), the data controller is REACH24H Consulting Group China. The information and data you provide in connection with the registration of the ChemLinked services will be processed in accordance with the provisions of the GDPR.

We will comply with the GDPR. The GDPR states that the personal data We hold about You must be:

-  Used lawfully, fairly and in a transparent way.
-  Collected only for valid purposes that We have clearly explained to You and not used in any way that is incompatible with those purposes.
-  Relevant to the purposes We have told You about and limited only to those purposes.
-  Accurate and kept up to date.
-  Kept only as long as necessary for the purposes We have told You about.
-  Kept securely.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by means of a notice on our home page so that you may access and review the changes to this document in advance of your continued use of the service. If you object to any changes, you may close your account. By continuing to use the ChemLinked service after notice of changes has been sent to you or published on the ChemLinked website, you are consenting to the changes.

Please read this policy and send us questions, concerns and suggestions here

2. What ChemLinked’s Privacy Policy Covers:

Information We Collect About You and How We Collect It

By joining ChemLinked, you voluntarily and willingly provide ChemLinked Team in HangZhou, China, certain information, including personally identifiable information, which we collect in order to provide the Services. If you have any hesitation about providing information to us and/or having your information displayed on the ChemLinked website or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a member of the ChemLinked community; and, if you are already a member, you should close your account.

We collect your personal information in the following ways:

a)Registration
In order to become a User, you must provide us the following information to create an account: name, email address, country, and password. Without this minimal amount of information, you cannot create a ChemLinked account. Like other passwords, you should choose one that is known only by you. ChemLinked requests other information from you during the registration process, (e.g. company name, phone number, location, title, etc.) that ChemLinked uses to provide better, more customized services. You acknowledge that this information is personal to you, and by creating an account on ChemLinked, you allow others, including ChemLinked, to identify you and to allow ChemLinked to use your information in accordance with our User Agreement.

b)Customer Service
We collect information when you interact with ChemLinked’s helpdesk in order to accurately categorize and respond to customer inquiries and investigate breaches of our terms.

c)Cookies
Like most websites, we use cookies and web log files to track site usage and trends, to improve the quality of our service, to customize your experience on ChemLinked, as well as to deliver ChemLinked and third-party advertising to Users both on and off the ChemLinked site. A cookie is a tiny data file that resides on your computer, mobile phone, or other devices, and allows us to recognize you as a User when you return to the ChemLinked website using the same computer and web browser. You can remove or block cookies using the settings in your browser, but in some cases doing so may impact your ability to use ChemLinked. One type of cookie, known as a “persistent” cookie, is set once you’ve logged in to your ChemLinked account. The next time you visit the ChemLinked website, the persistent cookie will allow us to recognize you as an existing User so you will not need to log in before using the Services. In order to access or change any of your private information (like a credit card number) or to send a message to another User, however, you must log in securely again with your password even if your computer contains your persistent cookie. Another type of cookie, called a “session” cookie, is used to identify a particular visit to the ChemLinked website. Session cookies expire after a short time or when you close your web browser.

In the course of serving advertisements or optimizing the Services to our Users, we may allow authorized third parties to place or recognize a unique cookie on your browser. Any information provided to third parties through cookies will not be personally identifiable but may provide general segment information (e.g., your industry or geography, career field, or information about your professional or educational background) for the enhancement of your user experience by providing more relevant advertising. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. ChemLinked does not store unencrypted personally identifiable information in the cookies.

d) Log files, IP Addresses and Information about Your Computer
Due to the communications standards on the internet, when you visit the ChemLinked website we automatically receive the URL of the site from which you came and the site to which you are going when you leave ChemLinked. Additionally, advertisers receive the URL of the page you were on when you click on an ad on ChemLinked. ChemLinked also receives the internet protocol (“IP”) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, email patterns, your mobile device (including your UDID). ChemLinked may also receive location data passed to it from third-party services or GPS-enabled devices that you have enabled. Also, as described above in Sections 1.3. and 1.4., The link between your IP address and your personally identifiable information is not shared with third parties without your permission, except as described in Section 2.9 (“Compliance with Legal Process”), below.

Uses of personal information

a) Consent to ChemLinked Processing Information about You
By providing information to us for the purposes of creating your User account, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and ChemLinked’s User Agreement that allow ChemLinked to process information about you. Supplying information to ChemLinked, including any information deemed “sensitive” by applicable law, is entirely voluntary on your part. You have the right to withdraw your consent to ChemLinked’s collection and processing of your information at any time, in accordance with the terms of this Privacy Policy and the User Agreement, or by closing your account, but please note that your withdrawal of consent will not be retroactive.

b) ChemLinked Communications
As described in the User Agreement, we will communicate with you through email, notices posted on the ChemLinked website, or through other means available through the service, including mobile text messages. We may send you a series of emails that help inform new Users about the features of the Services, and we will also send you service messages relating to the functioning of the Services. We may also send you messages with promotional information directly or on behalf of our partners, unless you have opted out of receiving promotional information.

You can change your email address and contact preferences at any time by logging into your account. If you wish, you can also opt-out of receiving promotional emails by sending a request to ChemLinked customer service through our helpdesk.

Please be aware that you cannot opt-out of receiving service messages from ChemLinked.

c)User Communications
Many communications you initiate through ChemLinked will list your name in the header of the message (e.g. an inquiry sent to the helpdesk or comments posted in Expert Article section).

d)Customized Content
We use the information you provide to us (or to third parties with whom ChemLinked offers combined services) to customize your experience on our website.

e)Sharing Information with Third Parties
ChemLinked takes the privacy of our Users very seriously, and we do not sell, rent, or otherwise provide your personally identifiable information to third parties, except as described in this policy. We will also not share other personal information not published to your profile or generated through engagement with other ChemLinked services without your explicit consent or to carry out your instructions (for example, to process payment information) unless, disclosure is reasonably necessary in our opinion to: (1) comply with legal process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Agreement; (3) respond to claims of a violation of the rights of third parties, whether or not the third party is a User, individual, or government agency; (4) respond to customer service inquiries; or (5) protect the rights, property, or personal safety of ChemLinked, our Users or the public.

Content distributed through ChemLinked’s sharing features and third-party integrations may result in displaying some of your information outside of ChemLinked. For example, when you post content to ChemLinked that is open for public discussion, your content, including your name as the contributor, may be displayed in search engine results.

We may provide aggregated anonymous data about the usage of the Services to third parties for purposes that we deem, in our sole discretion, to be appropriate, including to prospective advertisers on ChemLinked.

f)Polls and Surveys
Polls and Surveys may be conducted by ChemLinked, ChemLinked Users or third parties. As a User, you may be invited to participate in polls and surveys from the ChemLinked website. Your selections may be random, or it may be based on your non-personally identifiable information, such as job title, geography, company size and/or industry. Whether or not you decide to participate in a poll or survey is completely up to you.

We may use third parties to deliver incentives to you to participate in surveys or polls. If the delivery of incentives requires your contact information, you may be asked to provide personally identifiable information to the third party to fulfill the incentive offer, which will only be used for the purpose of delivering incentives and/or verifying your contact information. It is up to you whether you provide this information, or whether you desire to take advantage of an incentive.

We will not disclose any personally identifiable information to any third parties in connection with the conduct of any polls or surveys. Your consent to use any personally identifiable information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it.

g)Comments and other Services
If you post comments on ChemLinked (expert articles or regulatory/inventory database sections, etc.), you should be aware that any personally identifiable information you choose to provide there can be read, collected, or used by other Users of these forums, as well as Platform Developers and other third parties, and could be used to send you unsolicited messages. ChemLinked is not responsible for the information you choose to submit in these forums. Also, some contents in ChemLinked may be public and searchable on the internet. You can delete your posts on ChemLinked at any time. However, please note that ideas you post and the information you share may be seen and used by other Users, and ChemLinked cannot guarantee that other Users have not made copies of or use the ideas and information that you share with others on ChemLinked.

h)Testimonials and Advertisements Placed through ChemLinked Ads Service
If you provide any testimonials about the ChemLinked Services or place advertisements through the ChemLinked Ads, we may post those testimonials and examples of advertisements you place in connection with our promotion of these services to third parties. Testimonials and advertisements may include your name and other personal information that you have provided.

i)Compliance with Legal Process
It is possible that we may need to disclose personal information, profile information and/or information about your activities as a ChemLinked User when required by subpoena or other legal processes, or if ChemLinked has a good faith belief that disclosure is necessary to (a) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) to enforce the User Agreement, to investigate and defend ourselves against any third-party claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property or personal safety of ChemLinked, our Users, employees, or others.

j)Disclosures to Others as the Result of a Change in Control or Sale of ChemLinked
We may also disclose your personal information and other information you provide to another third party as part of a sale of the assets of ChemLinked, a subsidiary or division, or as the result of a change in control of the company. Any third party to which ChemLinked transfers or sells ChemLinked’s assets will have the right to continue to use the personal and other information that you provide to us.

Your Rights Regarding Your Information and Accessing and Correcting Your Information

(a) Rights to Access and Control Your Personal Data
We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile. We offer you settings to control and manage the personal data we have about you.

For personal data that we have about you:
-  Delete Data: You can ask us to erase or delete all or some of your personal data.
-  Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
-  Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data.
-  Right to Access and/or Take Your Data: You can ask us for a copy of your personal data.

(b)Closing Your Account
You can close your account through the ChemLinked customer service site. If you close your ChemLinked account, we will remove your name and other personally identifiable information from our publicly viewable database. If you close your account, we have no obligation to retain your information, and may delete any or all of your account information without liability. Some information you have shared with others, or that other Users have copied, may also remain visible. ChemLinked disclaims any liability in relation to the deletion or retention (subject to the terms herein) of information or any obligation not to delete the information. ChemLinked does not control when search engines update their cache, which may contain certain public profile information that has since been removed from ChemLinked’s publicly viewable database.

(c)Memorializing Accounts
If we learn that a User is deceased, we may memorialize the User’s account. In these cases, we may restrict profile access, remove messaging functionality, and close an account if we receive a formal request from the User’s next of kin or other proper legal requests to do so.

Your Obligations

As a User, you have certain obligations to other Users. Some of these obligations are imposed by applicable law and regulations, and others have become commonplace in user-friendly communities of like-minded members such as ChemLinked:

Any violation of these guidelines may lead to the restriction, suspension or termination of your account at the sole discretion of ChemLinked.

Your Obligations

a)Children and Minors
Children under the age of 18 are not eligible to use our service.

b)Changes to this Privacy Policy
We may update this Privacy Policy at any time, with or without advance notice. In the event, there are significant changes in the way we treat your personally identifiable information, or in the Privacy Policy document itself, we will display a notice on the ChemLinked website or send you an email, so that you may review the changed terms prior to continuing to use the site. As always, if you object to any of the changes to our terms, and you no longer wish to use ChemLinked, you may close your account. Unless stated otherwise, our current Privacy Policy applies to all information that ChemLinked has about you and your account.

Using the ChemLinked Services after a notice of changes has been sent to you or published on our site shall constitute consent to the changed terms or practices.

Data Retention Periods

ChemLinked will retain your information for so long as your account is active or as needed to provide you services, except in the case of our professional plugin impression data, which we de-identify after 12 months. If you wish to close your account, you may do so here. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce this Agreement.

Security

In order to help secure your personal information, access to your data on ChemLinked is password-protected, and sensitive data is protected by SSL encryption when it is exchanged between your web browser and the ChemLinked website. To protect any data you store on our servers, ChemLinked also regularly audits its system for possible vulnerabilities and attacks. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of any information you transmit to ChemLinked. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other Users of ChemLinked are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

Questions on data privacy and the right to be informed

If you have questions or comments about this Privacy Policy, please contact us here or mail us at: contact@chemlinked.com

ChemLinked, REACH24H Consulting Group China

Attn: Legal Department, Privacy Policy Issues, 14th Floor, Building 3, Haichuang Technology Center, Hangzhou,

China (311121)