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CLO-SET & CLO-SET CONNECT

Privacy Policy

Last updated: April 13, 2021


CLO Virtual Fashion, LLC and its affiliates (“CLO”) respects the privacy rights of its users and protects the personal information collected, stored and used in connection with our websites and services—including CLO (also known as “CLO3D,” accessible at https://www.clo3d.com/), Marvelous Designer (accessible at https://www.marvelousdesigner.com/), CLO-SET (https://style.clo-set.com/aboutus), online stores (including the CLO-SET CONNECT Store and the MD Store), CLOLLAB, CLO’s parent website (https://www.clovirtualfashion.com/), the CLO Enterprise user training website, and other services that may be developed, modified, combined, and/or newly offered through our websites from time to time (our "Services").

To further this commitment, we have adopted this Privacy Policy ("Privacy Policy") to guide how we collect, store, and use the information you provide us.

By setting up a CLO account, by using our Services, by using or downloading software made available by CLO, or by clicking the “I accept” button (or its equivalent), you are accepting the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not register for an account with CLO, download software made available by CLO, or otherwise access our Services.

We may modify this Privacy Policy from time to time. We will notify you of any revisions to this Privacy Policy by posting the latest version here and by indicating the Last Modified date at the top. You will be deemed to have agreed to any such modifications by your continued use of our Services after any such modification is posted. It is important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If you do not agree with the modifications, please discontinue use of our Services immediately.

We do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian and believe your minor child has provided us with personal information without your consent, please contact us as described in the “Inquiries” section below and we will take steps to delete such personal information from our systems.

Any data processed by or through the Services and qualifies as personally identifiable information or personal data under applicable law will be processed in accordance with such applicable law, our Privacy Policy, and our CLO-SET Terms of Service (“Terms”), on the lawful bases of Consent (e.g. your acceptance of our Privacy Policy), Legitimate Interest (e.g.. to ensure security and to ensure your compliance with this Agreement), and/or Performance of Contract (e.g. to deliver our Services as set forth in the Terms. Including the various end user license agreements).

1. Scope of Privacy Policy

This Privacy Policy describes CLO’s collection and use of personal information submitted and collected through our Services. Personal information includes any individually identifiable information about you, such as your name, address, telephone number, or e-mail address, and information concerning you collected and/or maintained in personally identifiable form.

Please be aware that websites with links to and from our Services may collect personal information about you. This Privacy Policy does not apply to, and cannot control the activities of, those other websites.

2. Information We Collect

We may collect and process the following data about you:

  1. • Personal information such as your name, address, telephone number, e-mail address, and credit card number when you register for an account with CLO, make sales inquiries, request support, or make a purchase or payment.
  2. • We collect certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, operating system, browser type, date/time stamp, and/or program or system error messages and other system information. We may combine this automatically collected log information with other information we collect about you to improve our Services, to improve marketing, analytics, or website functionality.
  3. • If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence.
  4. • We collect details of your use of our Services and the resources that you access. Such usage information includes information about how and when you access or use our Services.
  5. • User feedback, community discussions, chats and other interactions on our Services.
  6. • If you access our Services on your mobile telephone or other mobile device, including tablets, we collect mobile device identifiers, including MAC Address, and IP Address. Certain aspects of our Services will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, geo-location and any other information you choose to provide or allow us to access.
  7. • Contact information, Profile information (such as profile photo), other data you choose to give us.

Please keep in mind that when you voluntarily disclose personal information which is publicly viewable, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who views information (and what they do with information) you voluntarily post publicly.

3. How We Collect

CLO’s collects data from you when you provide it to us directly, such as via an online form or when you communicate with our customer support team. CLO and third parties also use certain technologies described below to collect data to deliver excellent experiences.

Cookies. Cookies are small text files placed on your device that can be recalled by a web server in the domain that placed the cookie. We use cookies for various purposes including to help recognize and remember you when you are logged into our Services so we can maintain your settings and preferences, analyzing the performance of our Services, maintain the integrity of our Services, and for other lawful bases. These cookies do not track your browsing activity on non-CLO websites.

Web Beacons. We also use “web beacons” to help deliver cookies and gather usage and performance data. Our website may include web beacons, cookies, or similar technologies from third-party service providers. By providing us with information about how you interact with our Services, these tools help us analyze and learn how to make our Services better and customize our communications with you. The following analytics technologies are in use: Google Analytics

Clear Gifs. We may also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. For this reason, these types of clear gifs are tied to personally identifiable information.

You have access to tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies. However, if you disable cookies, your ability to use some features or areas of our Services may be affected.

CLO and our partners, such as marketing partners and analytics providers, may use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used in analyzing trends, administering our websites, tracking users’ movements around the websites, and to gather demographic information about our user base as a whole. We use cookies for various purposes including our shopping cart, to remember users’ settings, and for authentication. Users can control the use of cookies by adjusting individual browser settings. However, if you reject cookies, you may still use our websites, but your ability to use some features or areas of our websites may be limited.

We may also use tools or third party analytical software to automatically collect and use certain non-personal information that does not directly enable CLO to identify you.

4. Use & Sharing of Information Collected

We use your personal information and non-personal information, both individually or combined together:

  1. • To help us manage, operate and deliver our Services to you
  2. • To improve your experience with our Services
  3. • To develop new products or services for you
  4. • To provide you with customer support
  5. • To communicate with you about our Services (unless you have not consented to allow us to use your information for these purposes)
  6. • For marketing and promotional purposes
  7. • For internal training purposes and statistical analysis
  8. • To keep our Services safe.

CLO does not sell or rent your personal information to third-parties for marketing purposes without your consent.

However, you hereby agree that CLO may, without seeking further your consent, share your personal information as follows:

  1. • With our affiliates to provide you our Services or information about other services and promotional materials.
  2. • With partners, vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Services are used, providing customer service, facilitating payments or conducting surveys. A list of subprocessors we use to support delivery of our Services is available at www.clo3d.com/subprocessors.
  3. • With other users of our Services in a way that is consistent with the functionality of our Services (e.g. your profile photo that you post on CONNECT).
  4. • if the ownership or control of all or part of our Services or their assets changes, with the new owner;
  5. • For other legitimate purposes

We will encourage our service partners to adopt and post privacy policies. However, the use of your personal information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.

In a business transaction, such as a merger, acquisition, dissolution (including bankruptcy), change of control, or a sale of all or a portion of our assets, customer information, including personal information, generally is one of the transferred business assets. In the event that CLO undergoes such transactions, including preparation of any of such transactions, we may share, disclose or transfer all of your information, including personal information, to the successor. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

Occasionally we may be required by law enforcement or judicial authorities to provide personal information to the appropriate governmental authorities. We will disclose personal information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.

5. Safeguards

CLO maintains appropriate safeguards that ensure the security, integrity, and privacy of the personal information we collect and store about our account holders. Personal information collected by CLO is stored in secure operating environments that are not available to the public and that are only accessible by authorized employees. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control (i.e., maintain data quality). Before we allow web users to access their personal information, for example, we verify their identity by requesting that they submit information such as their username and password. We also take reasonable steps to ensure that third parties to whom we transfer personal information provide sufficient protection of such data.

Your personal information may be transferred to, and stored at, a destination outside the country of your residence. It may also be processed by personnel of our affiliates and third party service providers who may operate outside the country of your residence. In such a case, we will take reasonable steps to require such third party in possession of your personal information to take commercially reasonable security measures to protect the information.

However, unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) the security, integrity and privacy of any and all information and data exchanged between you and us through our Services cannot be guaranteed; and (b) any such information and data may be viewed or tampered with in transit by a third party.

6. Links to Third Party Sites or Services

You should be aware that our Services may from time to time contain links to third-party sites, products or services. CLO is not responsible for the privacy practices or the content of such sites or services. If you are concerned about the privacy policy of a certain third party, we recommend that you read the privacy policy of the site or service to which you link before you submit any personal information.

7. Your Rights Related to Personal Information and Access to Personal Information

You have certain rights regarding your personal information, subject to local data protection laws. These may include the following rights:

  1. • to access your personal information held by us (right to access);
  2. • to rectify inaccurate personal information and ensure it is complete (right to rectification);
  3. • to erase/delete your personal information to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
  4. • to restrict our processing of your personal information (right to restriction of processing);
  5. • to transfer your personal information to another controller to the extent possible (right to data portability);
  6. • to object to any processing of your personal information carried out on the basis of our legitimate interests (right to object). Where we process your personal information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
  7. • not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites; and
  8. • to the extent we base the collection, processing and sharing of your personal information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

To exercise your rights, please contact us at [email protected] We try to respond to all legitimate requests within thirty (30) days and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than thirty (30) days, taking into account the complexity and number of requests we receive.

CLO makes good faith efforts to enable you to review, update or correct your personal information in our possession. In order to do so, please log into your account or contact [email protected] If you contact us, we will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request. Please note that even if personal information is changed or deleted according to your request, CLO may still retain some of your personal information to resolve disputes, enforce CLO user agreement(s), and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Services.

8. Retention; Deactivated or Terminated Accounts

Please be aware that even after your account is terminated or deleted, some or all of your information may still remain visible to others. A request to delete and/or terminate your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able nor are we obligated to remove any of your information from a third party provider or platform. Moreover, please be aware that even after you delete your account or your account is terminated, your information may not be deleted in its entirety from our servers and servers of the third party with whom such information have been shared

When you sign up for an account with CLO, CLO retains personal information you store on our Services for as long as your account is in existence or as long as we need it to provide you our Services. If you delete your account, we will initiate deletion of this information after 30 days, but please note: (1) there might be some latency in deleting this information from our servers and back-up storage; (2) a request to delete and/or terminate your account will not result in the removal of information collected and already put in aggregate form; (3) we are not able nor are we obligated to remove any of your information from a third party provider or platform; and (4) we may retain your information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

9. Opting Out

If at any time you wish to opt out of having your personal information shared with third parties and/or receiving information from CLO (via e-mail or postal mail) about new products, services, or promotions, you can do so by adjusting your account settings, by clicking “unsubscribe here”, “manage your preferences”, or their functional equivalent, or by emailing us at [email protected]

10. International Privacy Practices

The CLO-SET Service is provided through and managed on servers located and operated within the United States. By using and accessing our Services, residents and citizens of countries and jurisdictions outside of the United States agree and consent to the transfer, storage and processing of your information on servers located in the United States.

Specifically, CLO-SET leverages a data center in the United States hosted by Amazon Web Services, Inc. (AWS).. On May 22, 2018, AWS incorporated the AWS GDPR Data Processing Addendum (DPA) into its online Service Terms.

This means that you can rely on the terms of the AWS GDPR DPA which will apply automatically from May 25, 2018 whenever we use the AWS services to process Personal Data under the GDPR, including the transfer of Personal Data outside of the European Economic Area (“EEA”).

The AWS GDPR DPA includes the EU Model Clauses and the Standard Contractual Clauses to enable the transfer of data outside of Europe. The AWS GDPR DPA applies automatically whenever we require it to comply with the GDPR. More details can be found at https://aws.amazon.com/blogs/security/aws-gdpr-data-processing-addendum/.

11. Inquiries

If you have any questions or wish to file a complaint, please feel free to email us at [email protected]

12. Impressum/Imprint

U.S. Office:
CLO Virtual Fashion LLC
16 E. 34th Street, 18th Floor,
New York, New York 10016

Limited liability corporation registered in Delaware.
Chief Executive Officer: Simon Jihong Kim
Federal Employer Identification Number (EIN): 46-5088515

Contact Information
P: +1 646 653 9323
E: [email protected] (quickest mode of contact due to COVID office closures)

Korean Office (Parent Company/Global HQ):
CLO Virtual Fashion, Inc.
17-4 Dosan-daero 8-gil,
Gangnam-gu, Seoul, 135-811, Republic of Korea

Business Registration Number: 105-87-27625
Contact Information
P: +82-2-6405-1283
E: [email protected]

German Office:
CLO Virtual Fashion, GmbH
c/o wework,
Oskar-von-Miller-Ring 20, 80333 Munchen

Tax ID Number: DE309314245
Amtsgericht München HRB Number: 229717

Contact Information
P: +49 89 9545 7319
E: [email protected]