Wiwynn Corporation (hereinafter ¡§Wiwynn¡¨ or ¡§we¡¨) takes privacy and the rights of personal data owners seriously. Thus, in accordance with the privacy-related laws and regulations of each operation sites and the relevant requirements of the General Data Protection Regulation (GDPR), we have formulated the Privacy Policy (hereinafter referred to as the ¡§Policy¡¨) as the highest principle for implementation of privacy protection in order to protect and manage personal information and ensure that privacy will not be infringed. We are also committed to requiring all employees of our subsidiaries and joint ventures, as well as suppliers, contractors and external consultants to comply with the Policy.

The Policy may be amended from time to time due to the relevant regulations. Please pay close attention to our website to timely update the latest contents.

1.    Personal Data Categories

The Personal Data herein includes all personal data that can be used to directly or indirectly identify individuals. Each personal data may vary depanding on the purpose for which it is collected, but is not limited to the following:

(1)    Basic data such as name, gender, date of birth, address, phone number, email address, job location, job title, ID card/passport or other certificate numbers, picture of face and other non-public information directly related to personally identifiable information (eg. preferences of product, interests or browsing history etc.)

(2)    The data collected by Cookies on Wiwynn¡¦s website.

(3)    Candidates¡¦ education experience, qualification certificates and work experience.

(4)    Documents signed or expressed consent to during the contact with Wiwynn.

2.    Purpose of Personal Data Collection/Use

Wiwynn may collect and use your personal data for the following purposes in accordance with the relevant law:

(1)  For the purpose of providing products and services ¡V including but not limited to the matters related to signing contracts,

(2)  For the purpose of marketing communication ¡V including but not limited to updating our systems, processes and related information, communication and interaction, maintaining and updating contact information, improving or developing our products and services, and other related matters.

(3)  For the purpose of management ¡V including but not limited to supplier management, manpower management and related matters.

(4)  For the purpose of physical security ¡V including but not limited to access records of factories, monitor video records, system login, access and other related records.

(5)  For the purpose of legal compliance ¡V including but not limited to the investigation of legal cases, the prevention of crime, the assertion/exercise/defense of legal rights and related matters.

3.    Principle of Personal Data Collection

(1)    For different types/purposes of personal data collection, we will provide explanations and information with separate opt-in for each purpose. Also, we will itemize the rights for choice on your own and collect data after receiving consent. When you use Wiwynn¡¦s website or provide your personal data on your own when contacting Wiwynn, you agree to the terms and conditions of the Policy and also agree we collect and process your personal data in accordance with the Policy.

(2)    For the collection, processing and use the personal data, we continuously monitor and manage by the principle of not exceeding the specific purpose and not making secondary purpose.

4. Sharing of Personal Data

For legitime operating activities, we may provide personal data to the following parties:

(1)  The legitimate authorities including the legal competent authorities and those necessary for litigation, other legal proceedings or the investigating, detecting and preventing crime offenses.

(2)  The institutions using data by law and regulations (such as Wiwynn¡¦s subsidiaries and other business-related institutions.

(3)  The parties agreed by you (including but not limited to the following parties, such as the companies jointly marketing or sharing customer information with Wiwynn or the companies cooperating business with Wiwynn.

(4)  The accountants, auditors, attorneys and other experts providing consultant services, who already signed Non-disclosure agreement with Wiwynn.

(5)  If we engage a third-party supplier to process the Personal Data, the Processor will be subject to binding contractual obligations to:

l  only process the personal data in accordance with the purpose of our prior written instructions; and

l  establish mechanism to protect the security of personal data in compliance with requirements under applicable law and regulations.

5.    Retention Period of Personal Data

(1)  Unless otherwise agreed, we will retain the personal data within 5 years in principle or the period in accordance with the extinction of specific purpose for collection or the expiration of agreement term (the longer period will prevail).

(2)  We will perpetually delete, destroy or anonymously dispose the personal data after the expiration of above retention period.

6.    Protection Mechanism of Personal Data

We will do our best to take reasonable measure to protect the security of your personal data (including but not limited to equipment security management and data security auditing mechanism, such as encryption mechanism, firewall etc).

We are not responsible for any content, products or services offered on any third-party websites. Links to third-party websites are provided for your convenience only. This Privacy Policy will not apply to any personal data that you provide to, or that is collected by, any third-party website operator. We are not responsible for the privacy practices or the content of those other websites.

7.    Claim/Request of Personal Data Owner

With respect to personal data, you have the right to claim/request under the legally premise:

(1)  Refuse to provide your personal data: However, if you choose not to provide your personal data, we may not be able to completely provide the relevant functions or services of our website.

(2)  The right to withdraw your consent: Withdraw your consent will not affect the legality of processing your personal data by Wiwynn on the basis of your previous consent. If there¡¦s other legal basis of the processing, we may continue to process your personal data.

(3)  Stop collection, processing and use.

(4)  Inquiries or requests for reading.

(5)  Provide copies.

(6)  Request for supplement, correction or deletion.

(7)  Under the reasonable and practicable premise, transfer your personal data to the information controller of designated third party in an usable or machine-readable form.

(8)  If You are the residents of the European Economic Area from within the European Union, based on the GDPR, you have the right to claim/request for restriction of processing and, to the extent possible, the right to request for transfer your personal data in an organized, generally usable or machine-readable form.

8.    Cross-border Transmission

(1)  Since Wiwynn is a multinational enterprise, there may be cross-border transmission and use of personal data between subsidiaries in different countries. Within the scope of not exceeding the original purpose of collecting, processing and using personal data and complying with the Policy, we will comply with this policy and the privacy and personal data protection laws and regulations applicable to the transmission area.

(2)  If we transmit your personal data from within the EU to outside the European Economic Area, and the country where the recipient is has not been certified by the EU for adequacy, we will sign EU standard clauses with the recipient to protect your rights of personal data.

9.    Management Mechanism of Personal Data

(1)  We have incorporated privacy rights and personal data protection into the scope of internal control and risk management of the enterprise, and has formulated the "WYHQ Internal Control System" as well as various internal control cycle operation rules to carry out related operations to reduce potential risks and impacts.

(2)  We adopt the zero-tolerance policy for privacy protection. If any employee violates the Policy, he or she will be punished in accordance with our relevant regulations and, depending on the severity of the case, we will seek compensation or pursue legal action in accordance with the law.

(3)  In order to ensure the implementation of the privacy protection system, the legal department is responsible for the formulation of the relevant system, and the audit department will examine the implementation status of the relevant mechanism.

(4)  We conduct annual internal audits to verify that the measures of personal data protection and related procedures comply with relevant laws and regulations and management systems.

(5)  Conduct regular training on privacy protection for all employees and keep training records.

10.Website Cookies

(1)  We collect your personal data in several ways. Most of the personal data we receive comes to us voluntarily from you who are interested in obtaining products and services from us or is collected by using technology. As you visit our website, our information technology (IT) systems may also collect passive information, including your Internet Protocol (IP) address, browser type, and operating system.

(2)  We also use cookies to gather information on the date and time of your visit. The session cookies are permanently lost when the browser closes. The persistent or perpetual cookies are contained in your device until you delete them manually or it reaches to the expiration date you set up for retention period.

11.Consultation, Reporting and Acceptance

(1)  If there is an incident or situation that may cause damage to your rights, or if you discover any possible violation of the Policy, please contact us at +886-2-6615-8888 or Legal@wiwynn.com . We will protect the identity and rights of the whistleblower by strictly protecting the relevant information of the whistleblower.

(2)  In the event of a personal data incident that results in a breach of your rights, we will immediately process and investigate the incident and notify you in an appropriate manner once it is identified. If you have any questions or suggestions about the Wiwynn Privacy Policy, please send an email to Legal@wiwynn.com .