CLOOPEN Privacy Policy

Effective as of [July 25, 2025]

Published on [July 24, 2025]

 

CLOOPEN Group Holing Limited has always recognized data protection as an important issue for its stakeholders and understands the responsibility that comes with the processing of personal data. This Privacy Policy describes the privacy practices of CLOOPEN Group Holing Limited and its affiliates (together “CLOOPEN” or “we”) related to personal data collected, used, stored, and otherwise processed in connection with the portals, websites where this Privacy Policy is referenced (the “Sites”). It explains the rights and choices available to individuals with respect to their personal data.

Applicable Scope of this Privacy Policy

This Privacy Policy applies to the personal data CLOOPEN processes as a data controller, i.e., as the party that determines what personal data to collect online or offline and to what end.

This Privacy Policy does not apply to (i) personal data about CLOOPEN employees and candidates; and (ii) personal data that CLOOPEN processes on behalf of its customers or other third parties as specified in the applicable agreement.

For your convenience, hyperlinks may be posted on the Sites that link to other websites, services or apps that CLOOPEN does not own or control. This Privacy Policy is not applicable to them and CLOOPEN has no liability for the content of third-party websites, services or apps nor the personal data they collect. CLOOPEN encourages you to read the privacy policies of the other websites you visit and services or apps you use.

Contents of this Privacy Policy

This Privacy Policy provides information about:

  • The types of personal data CLOOPEN may collect about you;
  • How the personal data is collected;
  • The purposes and legal basis of processing your personal data (e.g. to comply with the law, for marketing purposes with your consent);
  • Your rights and choices about your personal data: depending on your jurisdiction, you may have legal rights associated with CLOOPEN’s processing of your personal data, including rights to access, correct, delete, transfer, or object to the processing of your personal data. Regardless of where you live, CLOOPEN will honor your request to opt-out of being contacted for marketing reasons;
  • How to contact us.

What Personal Data Is Collected and Processed by CLOOPEN

Personal data means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the natural person.

In any event, the personal data processed by CLOOPEN is limited to data necessary for the purposes described in this Privacy Policy.

Depending on the purposes detailed below, personal data processed by CLOOPEN includes:

  • Personal and business contact information such as first and last names, email address, and phonenumber, job title in your company, company name, country, your interests to our products, and other information you voluntarily choose to submit to us; and
  • Usage dataand device data such as, phone call recordings and phone call logs, online chat transcripts, email communication with us, IP and MAC addresses, logs on how you use the Sites, including data from cookies as described below.

Such personal data may be collected by CLOOPEN through the following means:

  • Directly from you through the Sitesor otherwise communicated; and
  • Automaticallythrough cookies or similar technologies.

 

The provision of personal data identified as mandatory is on a voluntary basis but is necessary for you to contact with us and provide the supports you request from us.

Please be aware that our Sites are not designed for children who are considered as minors under applicable data protection laws. If you are a minor, you are not allowed to visit or use the Sites. If CLOOPEN learns that it has collected personal data from a child, it will delete that information as quickly as possible.

Why Your Personal Data is Processed by CLOOPEN

CLOOPEN only uses your personal data as permitted by law. The legal bases and purposes of CLOOPEN processing of your personal data are described below:

With your consent.

  • to communicate with you, including when you request information related to our products and services, or interact with us through the Site, emails and other means, and more generally to manage CLOOPEN communication and marketing activities;
  • to ascertain your requirements and interests and provide you with the most suitable products and services;
  • to provide you with a personalized, interactive use of Sites and allow you to access all their features.

To provide you with services.

  • To provide the information you request from us;
  • To operate, maintain, administer and improve the Sites.

To pursue the following legitimate interests.

CLOOPEN process your personal data for purposes based on the following legitimate interests:

  • To improve your experience better understand your needs and interests, and personalize your experience with the Sites, including remembering your settings;
  • To enable CLOOPEN to manage its business relationships when you are acting on behalf of a CLOOPEN customer;
  • To protect the proprietary information of CLOOPEN;
  • To create anonymous data for analytics;
  • To protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity as well as for security and safety prevention.

CLOOPEN takes into consideration and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for purposes based on legitimate interests. Unless CLOOPEN has your consent or is otherwise required or permitted to do so by law, CLOOPEN will not use your personal data in circumstances where the impact on you outweighs its legitimate interests in processing your personal data.

To comply with law

  • To comply with lawful requests and legal process such as to respond to subpoenas or requests from government authorities as detailed hereinafter.

How Long Your Personal Data is Retained

CLOOPEN does not store your personal data for more time than necessary and only as long as required to fulfill the purposes set out above. Retention periods may vary depending on the data categories and the processing activities. To determine the appropriate retention period for personal data, CLOOPEN considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which CLOOPEN processes your personal data and whether CLOOPEN can achieve those purposes through other means, and the applicable legal requirements:

  • where you gave your consent, until you withdraw it;
  • where CLOOPEN has entered into an agreement with you, as long as the agreement is into force plus the applicable local statutes of limitations;
  • where CLOOPEN has a legitimate interest in using your personal data, for a limited period of time appropriate to ensure a fair processing of your personal data or until you object to CLOOPEN’s use of your personal data, subject to CLOOPEN’ compelling legitimate grounds for continued processing which override your interest in objecting or for the establishment, exercise or defense of legal claims;
  • where CLOOPEN is required to comply with a legal obligation, the retention period will be determined according to the applicable law;
  • Where your personal data is required to assert or defend against legal claims, CLOOPEN will retain your personal data until the end of the relevant retention period or until the claims in question have been settled.

At the end of the retention period, your personal data will be deleted or anonymized using process and methods in accordance with applicable data protection standards.

With Whom CLOOPEN May Share Your Personal Data

CLOOPEN does not rent or sell information but may share your necessary personal data for certain business purposes with the following categories of organizations:

  • Within CLOOPEN group: CLOOPEN may need to share your personal data within our group for purposes consistent with this Privacy Policy (e.g., to provide you with customer supports).
  • With your employees. CLOOPEN may share your personal data with your employees for purposes providing our products and servicesto you.
  • With CLOOPEN trusted partners 
    • CLOOPEN business partners

CLOOPEN may share your personal data with CLOOPEN business partners such as resellers assigned to you to provide you with appropriate offers.

  • Third parties acting on CLOOPEN behalf

CLOOPEN may engage third party companies and individuals where necessary and share your personal data with them in the course of the services that they render to CLOOPEN, to administer and provide the services on CLOOPEN’ behalf (such as customer support, hosting, email delivery and database management services). These third parties will use your personal data only as directed by CLOOPEN and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your personal data for any other purposes.

  • With third parties to comply with applicable laws: CLOOPEN may, depending on the applicable law, disclose some of your personal data to government or law enforcement officials or private parties, (a) if CLOOPEN believes in good faith that such disclosure is reasonably necessary to comply with legal process (for example, a warrant, a subpoena, or other court order), (b) enforce the terms and conditions that govern your use of our Sites, (c) protect the rights, property, or safety of CLOOPEN, CLOOPEN’s customers, or the public and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. CLOOPEN will review the requests to make sure they satisfy applicable laws. If a request asks for too much information, CLOOPEN will try to narrow it, and if possible, will object to producing any information at all.
  • With third parties to serve or protect CLOOPEN legal and business interests: CLOOPEN may transfer or otherwise share some or all of its business or assets, including your personal data, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, or a change of control or a total or partial liquidation of CLOOPEN, in which case CLOOPEN will make appropriate efforts to require the recipient to honor this Privacy Policy.

International Data Transfers

When accessing the Sites, please note that through your continued use of it, if you are located in a different country than [Hong Kong] where the datacenter hosting our Sites are deployed, you consent to the transfer of your personal data to [Hong Kong] where privacy laws may not be as protective as those in your jurisdiction may. 

Please note we do not restrict where you may access to our Sites, you and your employee shall be responsible for compliance with all applicable laws and regulations regarding such international data transfer. We may use commercially reasonable efforts to provide necessary assistance to you.

Under certain scenarios, our engineers and staff in China may need to access parts of your personal data that is hosted in [Hong Kong] for the purpose of providing the customer supports your request. If such access is granted, we will ensure the relevant requirements under applicable laws, if any, are appropriately met.   

What Are Your Rights with Respect to Your Personal Data

Depending on the applicable data protection laws, you may have some or all of the following rights with regard to your personal data:

  • access your personal data;
  • obtain a copy of your personal data stored by CLOOPEN;
  • request the rectification, completion, update or erasure of your personal data;
  • restrict processing;
  • object to specific processing of your personal data if that processing is based on legitimate interests;
  • data portability; and
  • If the processing of your personal data is based on your consent, you have a right to withdraw that consent at any time (e.g. opt-out or unsubscribe from marketing communications).

You may exercise your rights by submitting your request to us by sending emails to marketing@cloopen.ai . 

Depending on the scope of the request, and if permitted under applicable law, CLOOPEN may charge a reasonable fee to cover costs incurred in connection with such request. CLOOPEN may deny access to your personal data in limited circumstances in accordance with applicable laws and regulations.

CLOOPEN may request specific information from you to confirm your identity or process your request. Applicable laws may require or permit CLOOPEN to decline your request but in all cases, CLOOPEN will provide you with an explanation of its position, subject to legal restrictions.

How We Protect Your Personal Data

CLOOPEN maintains appropriate technical and organizational measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction during transmission and once in its possession.

CLOOPEN only allows employees and other authorized personnel who need to know your personal data to access relevant information. CLOOPEN also requires all personnel who may have access to your personal data to comply with their corresponding confidentiality obligations.

However, while CLOOPEN strives to protect your personal data, in light of the inevitable risks linked to the Internet, CLOOPEN cannot guarantee full protection against any leak.

It is important for you to exercise caution to prevent unauthorized access to your personal data. In the event of a data security incident, we will promptly notify you in accordance with the applicable data protection laws, the notification may contain the basic information and possible impact of the security incident, the disposal measures we have taken or will take, and the risk mitigation suggestions, etc. We will notify you of the security incident by email, letter, telephone call, push notification, etc. When it is difficult to notify every end-user one by one, we will adopt a reasonable and effective way to publish an announcement.

Cookies and Similar Technologies

Cookies used by CLOOPEN

In order to improve your browsing experience on our Sites, CLOOPEN uses cookies or other similar technologies that may process your personal data.

Depending on the features you use, CLOOPEN uses different types of cookies:

  • Strictly necessary cookies are always used; as they are essential for you to properly use the Sitesand cannot be switched off. For example, they allow you to save your personalization settings (choice of language).
  • Functional cookies are used in order to improve the performance of the Sites, to provide you with optimized features and a more personal experience by collecting information when you use the Sites. Functional cookies also include analytics and performance cookies that are used to collect information about the traffic to our Sites. The information gathered may include the number of visitors to our Sites, the websites that referred you to our Sites, the pages you visited on Sites, what time of day and duration you visited you Sites, whether you have visited our Sites before, and other similar information. CLOOPEN uses this information to help operate Sites more efficiently, to gather broad demographic information and to monitor the level of activity on Sites.

Disabling Cookies

You can remove or reject functional and advertising cookies at any time through the cookies banner. However, if you do not accept certain cookies, some functionalities and features of the Sites may not function properly, and you may experience some inconvenience in their use. For example, CLOOPEN may not be able to recognize your computer or other device, and you may need to log in every time you visit our Sites.

How You Can Contact Us 

CLOOPEN is committed to ensuring the privacy of personal data: You can contact the CLOOPEN by sending email to marketing@cloopen.ai if:

  • you have any questions about this Privacy Policy;
  • you encounter any issue when having access to your personal data or related to your rights as described above;
  • you believe that CLOOPEN is not complying with the applicable local data protection laws;
  • you have a reason to believe that the security of your personal data has been compromised or misused.

Changes to Privacy Policy

CLOOPEN reserves the right to modify and update this Privacy Policy at any time in accordance with CLOOPEN requirements and circumstances, or where required by applicable laws and regulations. CLOOPEN encourage you to periodically review this page for the latest information on its privacy practices. If major changes occur to this Privacy Policy, CLOOPEN may inform you via email or another manner that CLOOPEN believes reasonably likely to reach you. This may include posting a specific announcement on our Sites.

Any modifications to this Privacy Policy will be effective upon CLOOPEN posting of the new terms and/or upon implementation of the new changes in the Sites.

 

CLOOPEN Group Holing Limited

28-11, Q Sentral, Jalan Stesen Sentral 2, 50470 Kuala Lumpur (Asia Pacific Center)