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CLOLLAB CONNECT Data Transfer Statement



Thanks for entrusting CLO Virtual Fashion, LLC and its affiliates (“CLO”, “we,” “our,” or “us”) with your information and data. Processing your information and data is a serious responsibility, and we want you to know how we’re handling it. 


All capitalized terms mentioned below have their definition in the CLO-SET Terms of Service (“Terms”) and our Privacy Policy, unless otherwise noted here.  This Statement incorporates the terms and conditions of the Terms and our Privacy Policy. 


The Short Version

If you consent to us transferring your data from CLOLLAB to CLO-SET CONNECT (collectively, the “Transfer”), we will transfer your data as this Statement describes. 


Of course, this Statement does not tell you everything you need to know about how we will process and use your data after the Transfer.  For such information, we encourage you to carefully review our Terms and Privacy Policy.  


For instance, as explained in our Terms: any Personal Data is processed in accordance with applicable laws on the lawful bases of Consent, Legitimate Interest, and/or Performance of Contract; while we presume all User Content to be Private User Content, Private User Content becomes Public  User Content if you Publicize your Content; and while you own your Raw Data, we own any Derived Data.

If you have any questions, please contact


What is the purpose of the Transfer? 

  • CLO-SET CONNECT (or “CONNECT”) is our latest effort to create the best possible experience for our global community of users.   
  • It will be a place where fashion creators can amplify their digital assets through an open marketplace, portfolio management tools, and networking solutions.   
  • We’d love to curate this new platform with all the user content that made CLOLLAB so great.  To do this, we’re asking for your consent in Transferring your data.


What categories of data are being Transferred? 

  • Portfolio. Only your portfolio name and collection will Transfer. 
  • ContentsOnly the name and description you provided for your contents will Transfer, along with any associated hashtags.  
  • ProfileOnly your Thumbnail, Name, Country, Contact Information, and CLOLLAB User Data will Transfer.   
  • Achievements.  If you have Badges showing your Power User or Competition Winner status, only such Badges will Transfer.  However, CLO-SET CONNECT's Badge feature is still under development. As such, the Transferred Badge data will be displayed  on CLO-SET CONNECT once the Badge feature development is completed in the near future. 


How was this data collected?  

  • The vast majority of the data was entered or uploaded by users (e.g. you) onto CLOLLAB directly.  
  • Other information—such as Badges or Points—were not directly entered onto CONNECT by users, but were granted by CLO based on user activity. 


Why does CLO need to collect this data and what will CLO use it for?  

  • We need this data to give proper attribution to your Items that may be Uploaded to pre-populate CONNECT.
  • We also need this data to encourage collaboration between our global user community on CONNECT. 
  • If your CONNECT data is aggregated and/or anonymized, we may use such data for research and analytic purposes, marketing and promotional purposes, and/or other commercial purposes pursuant to our Terms. 


Where will the data be stored and by whom?  

  • Currently, your CLOLLAB data is stored in a data center in China hosted by the following cloud service provider: Alibaba Cloud Computing Co. Ltd. 
  • Once Transferred, your CONNECT data will be stored in a data center in the United States hosted by the following cloud service provider: Amazon Web Services, Inc. 


What happens to the data once Transferred?  

  • Once Transferred, your data will be in Draft form on CONNECT – meaning, you will have the Upload any Items before they can be published on CONNECT. 
  • Once Transferred, your Items may be uploaded onto CONNECT as a View-Only Item.  Later on, you will be able to convert it into a Fee-Based Item. 


What happens if I decline consent to the Transfer? 

  • If you decline consent to the Transfer, you may obtain your CLOLLAB data by downloading your CLOLLAB portfolio at any time before March 30, 2021 (“Data Download Deadline”).
  • Your CLOLLAB data will be deleted from the Alibaba server on April 6, 2021 (“Data Deletion Date”).  
  • After the Data Download Deadline, you will not be able to access your CLOLLAB data.



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