Privacy
Policy of Wahlap Official Website
Updated
Date: June 24, 2024
Effective
Date: June 24, 2024
This
Privacy Policy of Wahlap Official Website (“Policy”) describes how Guangzhou Wahlap
Technology Co., Ltd. (“Wahlap
Technology” or “we”) processes
your personal information during your visit and use of Wahlap Official Website
(website: https://www.wahlap.com/en.html or through
other
means,
collectively “Wahlap Official
Website”), and the means we provide for you to access, correct, delete and
protect such personal information. We appreciate the importance of personal
information and privacy of our users (“you”).
We attach great importance to and implement relevant security measures to
safeguard your personal information in accordance with applicable laws and
regulations, as well as well-established industry security standards.
We
appreciate your trust in us and commit to protecting your personal information
in compliance with the following principles: principle of accountability,
principle of clear purpose, principle of opt-in and consent, principle of
minimization and necessity, principle of security confirmation, principle of
data subject’s participation and principle of openness and
transparency.
This
Policy helps you understand:
1.
How
Do We Collect
and Use Your Personal Information?
2.
How
Do We Share, Transfer and Publicly Disclose Your Personal
Information?
3.
How
Do We Store and Protect Your Personal Information?
4.
Your
Rights
5.
Protection
of Personal Information of Minors
6.
Notices
and Amendments
7.
Contact
Us
[Special
Notice] Prior
to visiting and using Wahlap Official Website, you should carefully read and
fully understand this Policy (contents
marked
in bolded font may have specific impact on your rights and interests so please
pay special attention).
Please note that by visiting and using
Wahlap Official Website, you are consenting to our processing of your relevant
personal information as described in this Policy.
If you have any question regarding this Policy, please contact us through
any
method set forth in Section 7 “Contact
Us” of this Policy.
Please
note that, this Policy shall not apply to products/services of third parties
(including your transaction counterparties, any third-party websites,
third-party service providers, etc.) which you access through Wahlap Official
Website. With respect to how your personal information is processed when you use
such third parties’ products/services, please refer to the privacy policies (or
any statements with similar nature) of such third parties. Please protect your
personal information properly and only provide it to a third party when
necessary.
1.
How
Do We Collect and Use Your Personal Information?
While
visiting and using Wahlap Official Website, you need or may choose to authorize
us to process
your personal information in/for the following
scenarios/purposes:
1.1.
To
Provide You with the Expanded Functions of Wahlap Official
Website
In
order to provide you with the expanded functions of Wahlap Official Website,
your authorization for us to collect and use relevant personal information
in/for the following scenarios/purposes is needed. You may choose not to grant
us such authorization, and as a result, you would not be able to take advantage
of our expanded services or intended functional effects but you can still enjoy
the basic functions of Wahlap Official Website.
(1) Contact
Us
When
you contact us, we need to collect necessary personal information for the
purpose of verifying your identity, which includes name, email,WhatsApp
or WeChat.
During the process of providing customer support, we may record and save the
content of communication, correspondence/conversation records and other relevant
information (including contact information you provide). If
you refuse to provide the above-mentioned information, we may not be able to
provide the services you need.
(2) To
Provide Security Assurance
To
improve the security of our services and better prevent and detect frauds and
Trojans, we may integrate your personal information that
we collect directly from you and
that we collect from our affiliates or partners either under your authorization
or otherwise permitted by law. Via overall consideration of various information
(such as your habits and information of your frequently used software), we
evaluate risks related to your account, including verifying your identity,
preventing, detecting and investigating possible security risks of frauds,
internet viruses and cyber-attacks, and activities in violation of our or our
affiliates’ agreements, policies or rules, so as to protect the legitimate
rights and interests of yours,
other users, us or affiliates, and we may record some Uniform Resource Locators
that we consider risky.
To
prevent our system from large-scale Distributed Denial-of-Service (“DDoS”) attack, we record IP address you
use to connect to the server for a short period (not more than 24 hours) in
order to distinguish legitimate users from attackers and implement blocking
measures against identified attackers. Your IP address will never be used for
any other purpose, shared with any third parties or stored on a long-term
basis.
(3) To
Monitor the Operations of Wahlap Official Website and Conduct System Maintenance
and Management
Similar
with all other websites, we record and analyze weblogs
to monitor the operations of Wahlap Official Website, to identify the cause of
errors and troubleshoot errors, and to support the system maintenance and
management. A weblog will include the following contents: your IP address,
information about your browser and terminal equipment, specific access time,
specific pages visited and landing pages, access time, and information related
to browsing, searching, clicks, etc.
(4) To
Comply with Applicable Law
As
required by relevant laws and regulations, we store weblogs for the period
required by law.
1.2.
How
Do We Use
Cookies？
When
you visit and use Wahlap Official Website, we send small pieces of text called
cookies to your computer or mobile device.
We
use necessary cookies to provide you with essential functions
and services, including: improving features, routing traffic to and from web
servers, determining webpage-loading time, improving user experience and
conducting user statistics. These cookies are essential to the
operations of
Wahlap Official Website.
Most
web browsers automatically accept cookies, but usually
you
can block cookies by changing the settings of your browser.
You
can clear all cookies saved on your computer.
If
you do so, you may have to manually adjust some preferences every time you visit
Wahlap Official Website, and any information you have recorded previously will
be deleted, and it may also impact the security of the services you
use.
1.3.
Personal
Information
that We May Collect Indirectly
With
your authorization, we may collect
your personal information from third parties for the purposes such as verifying
identity, protecting account security, confirming transaction status as well as
providing you with customer support and resolving disputes. While collecting
personal information indirectly, we will comply with applicable laws and
regulations, agreements between Wahlap Technology
and third parties as well as your authorization, and we will use such
indirectly-collected personal information only after confirming the legality of
the information sources.
If
Wahlap Official Website needs to process personal information beyond the scope
of authorization and consent that you originally granted to the third-party
information sources, Wahlap Official Website will separately obtain your express
consent prior to processing such personal information.
1.4.
Exception
to Consent
You
are fully aware that, pursuant to applicable laws, we are not required to obtain
your authorization or consent when collecting and processing your personal
information in any of the following circumstances:
(1) if
the processing is necessary to fulfill statutory duties or obligations, such as
those directly related to national security, security of national defense,
criminal investigation, prosecution, trial and enforcement of
judgments;
(2) if
the processing is necessary to respond to public health emergencies or protect
the life, health and property safety of natural persons in emergency
situations;
(3) if
the processing is within a reasonable scope to conduct news reporting and public
opinion-based supervision, or other activities in the public
interest;
(4) if
the personal information processed is information that has been disclosed by the
individuals themselves or other personal information that has been lawfully
disclosed, and if the processing is within a reasonable scope and in accordance
with applicable laws; and
(5) other
circumstances as provided by applicable laws and
regulations.
2.
How
Do We Share, Transfer and Publicly Disclose Your Personal
Information?
2.1.
Sharing
In
the course of providing services to you at Wahlap Official Website, in certain
scenarios, we may need to collaborate with third parties (including affiliates
and non-affiliated third parties) in order to provide, secure and improve the
services you request; for this purpose, we may need to provide certain personal
information of yours to such third parties.
(1) To
Comply with Statutory Requirements.
We may share your personal information with others if it is required under
applicable laws and regulations, needed for litigation and dispute resolution,
specified in the relevant agreements or legal documents signed between you and
us, or ordered by administrative, judicial or other competent
authorities.
2.1.1.
Except
for the circumstances described above, we will further seek your express consent
or authorization before sharing your personal information with any other
company, organization or individual.
List
of Partners of Wahlap Official Website
In
the course of providing services to you at Wahlap Official Website, in certain
scenarios, we may need to collaborate with third parties (including affiliates
and non-affiliated third parties) to provide, secure and improve the services
requested by you and we may share certain personal information of yours with
such third parties to secure the successful delivery of
products/services.
|
Name
of the Third-Party |
Products/Services |
Personal
Information Involved |
Scenario |
Purpose |
Method
of Data Transfer |
Link
to the Privacy Policy or Company Website of the third party
|
|
WhatsApp |
Contact
customer |
WhatsApp
number |
After
the customer leaves their number, sales contact the
customer. |
Contact
customer |
Manual
entry |
Link
to company website: Link
to privacy policy: |
|
WeChat |
WeChat
number |
Link
to company website: Link
to privacy policy: https://weixin.qq.com/cgi-bin/readtemplate?lang=en_US&t=weixin_agreement&s=privacy&cc=CN&head=true |
We
will only share your personal information for lawful, legitimate, necessary,
specific and clear purposes. With respect to companies, organizations and
individuals with whom we share personal information solely for the purposes
stated in this Policy, we will execute
strict information protection and confidentiality agreements with them and
require them to comply with the agreements and implement relevant security
measures to safeguard your personal information.
2.2.
Transfer
As
our business develops, our affiliates and we may be involved in mergers,
acquisitions, restructurings, transfers of assets or similar transactions. If any of the transactions involves
transfer of personal information, we will request the company or the
organization to which your personal information is transferred to continue to be
bound by this Policy, or we will request such company or organization to obtain
your authorization and consent again. Except for the circumstances described
above, we will not transfer your personal information without your express
consent.
2.3.
Public
Disclosure
We
will publicly disclose your personal information only under the following
circumstances and with the implementation of security measures that meet
industry standards:
(1)
Based
on your needs, we will disclose your personal information in the manner
expressly agreed to by you;
(2)
In
the event that public disclosure of your personal information is required under
applicable laws and regulations, or compulsory requirements of administrative
law-enforcement authorities or judicial authorities, we may publicly disclose
your personal information within the type and in the manner as required
thereby.
Please
note that, the information you voluntarily disclose or publicize when using our
services may involve personal information of yours or others. When using our
services, please consider prudently regarding whether or not to disclose or
publicize any information.
2.4.
Exceptions
to the Consent Requirement for Sharing, Transfer and Public Disclosure of
Personal Information
Except
for the circumstances described above, in the following circumstances, we are
not required to obtain your prior consent for providing or transferring your
personal information to any third party or publicly disclose your personal
information:
(1)
if
the sharing, transfer or disclosure is related to national security or security
of national defense;
(2)
if
the sharing, transfer or disclosure is related to public safety, public health
or significant public interests;
(3)
if
the sharing, transfer or disclosure is related to criminal investigation,
prosecution, trial and enforcement of judgment;
(4)
if
the personal information is needed for protecting your or other individuals’
life, property and other vital legitimate rights and interests, but it is
difficult to obtain your consent;
(5)
If
the personal information has been voluntarily disclosed to the public by
you;
(6)
If
the personal information was collected from information that has been lawfully
disclosed to public, such as lawful news reports, governmental
information-publicity, etc. (except for any sharing, transfer of disclosure that
you expressly refuse or that may harm your material interests);
and
(7)
Other
circumstances prescribed by law in which your authorization or consent is not
required. In accordance with applicable law, to the extent the information
shared, transferred or disclosed has been anonymized and we ensure that the
anonymized information cannot be restored and used to identify the data
subjects, we may process such information without further notifying you and/or
obtaining your consent.
3.
How
Do We Store and Protect Your Personal Information?
3.1.
Storage
of Personal Information
3.1.1.
How
long do we retain your personal information?
We
will only retain your personal information for the shortest period necessary to
achieve the purposes described in this Policy, unless there are mandatory
retention requirements set forth in applicable laws or regulations.
For
example, the Electronic Commerce Law of the People’s Republic of China requires
the e-commerce platform operators to retain information related to goods,
services, and any specific transaction for a period of at least three years from
the date on which the transaction is completed. We retain transaction-related
personal information for the longest of (i) the retention period needed for
completing transactions with you, maintaining the relevant transaction and
business records to prepare for your possible inquiries or complaints; (ii) the
retention period needed for ensuring the safety and quality of the services we
provide to you; (iii) the retention period you agree to; and (iv) the retention
period agreed upon in any other special agreement or required under applicable
laws and regulations.
Personal
information that are not transaction-related will be retained until the earlier
of (i) you exercise your right of deletion (please refer to section 4.2 of this
Policy); (ii) you close your account (please refer to section 4.3 of this
Policy); and (iii) Wahlap Official Website ceases its
operation.
After
the retention period expires, we will delete or anonymize your personal
information in accordance with applicable laws. When your account is closed for
any reason, we will process your personal information in accordance with the
applicable laws and regulations.
3.1.2.
Where
we store your personal information?
Applicable
to the situation where Wahlap collects information abroad and stores it within
the territory of China
In
principle, any personal information collected by us will be stored within the
territory of the People's Republic of China. We will not provide any of your
personal information to any recipient outside of China without conforming to
applicable laws, regulations and regulatory requirements of China. Since Wahlap
Official Website provides its services through its resources and servers
deployed in multiple jurisdictions, subject to your consent, your personal
information may be transferred to or accessed from jurisdictions other than your
home country or region. These jurisdictions may have different data protection
laws, or may not have such law at all. In such cases, we will ensure that your
personal information is accorded the level of protection sufficiently equivalent
to that stored within the territory of the People’s Republic of China. For
example, we will obtain your consent to the cross-border transfer of personal
information, or implement security measures such as data de-identification prior
to the cross-border transfer of personal information.
3.1.3.
Termination
of Operation
In
the cases such as the termination of the operation of Wahlap Official Website,
we will notify you at least 30 days in advance in the forms such as push
notification or public announcement. Upon the termination of operations, we
will stop collecting your personal information and delete or anonymize your
personal information within a reasonable period of time in accordance with the
applicable laws and regulations.
3.2.
How
Do We Protect Your Personal Information?
3.2.1.
Data
Security Measures
To
protect the security of your personal information, we have implemented
industry-standard security measures to protect the personal information you
provide against any unauthorized access, public disclosure, use, modification,
damage or loss. We will take all reasonable and practical measures to protect
your personal information, for example:
(1)
Establishing
overall rules, management rules and technology standards of network and
information security; establishing data classification system, data security
management rules and data security development rules to manage and regulate the
transmission, storage and use of personal information;
(2)
Implementing
comprehensive data security control by signing confidentiality agreements with
individuals who have access to personal information and establishing monitoring
and audit mechanisms;
(3)
Using
state-of-the-art encryption technologies to protect your data security during
data transmission and storage; using reliable protection mechanisms to protect
data from malicious attacks;
(4)
Regularly
backing up data and establishing comprehensive data recovery system to cope with
accidental data loss or damage to ensure the durability and reliability of
data;
(5)
Establishing
an information security decision-making committee to assume responsibility for
network security protection; establishing an early-warning system in the
information system center to closely monitor the operation status of network
equipment on a 24x7 basis; and conducting regular tests and inspection on the
circuits, performance and security.
(6)
The
information system center will conduct inspections on and tests of network
equipment, server, operating system and application system at least once per
quarter;
(7)
Deploying
access control mechanisms to ensure that only authorized personnel can access
personal information and sensitive personal information, and personal
information will only be accessed when necessary; if it is necessary for a
specific person to process personal information beyond his or her authorization,
such over-authorization process shall be reviewed and approved by, and approval
record shall be kept by, the person responsible for personal information
protection in Wahlap Technology or the personal information protection agency;
and
(8)
Conducting
security and privacy trainings to enhance employees' awareness of the importance
of protecting personal information.
3.2.2.
Our
Data Security Capabilities
a.
Web
Application Firewall：
• Detecting
and preventing multiple types of cyber-attacks, including, among others, SQL
Injection, Cross-Site Scripting (XSS) and Cross-Site Request Forgery (CSRF), to
protect your data from unauthorized access or tampering;
• Conducting
real-time filtering and checking of data entering into and leaving Web
Applications, to identify and block malicious data and ensure that your data is
not damaged.
b.
DDoS
protection:
• Availability
protection: DDoS attacks are designed to render network services unavailable,
which might affect the availability of your data. The implementation of DDoS
protection measures, such as traffic filtering and load balancing, can ensure
that your network services are always available, thereby protecting the
accessibility of your data;
• Data
confidentiality: although DDoS attacks mainly aim at the availability of network
services, such attacks might affect the encryption and decryption operations in
the course of data transmission, which might lead to the leakage of sensitive
data. Through implementing end-to-end encryption and other security measures, we
can protect data confidentiality, even when facing DDoS
attacks;
• Data
integrity: DDoS attacks may cause network service interruption or packet
tampering, which may affect data integrity. Through implementing data integrity
check and verification mechanism, we can detect and correct the tampering data
caused by DDoS attacks timely and ensure that data integrity is not
affected;
• Attack
detection and response: through the implementation of DDoS attack detection and
response mechanism, we can detect DDoS attacks timely and respond with
corresponding measures. Such measures include real-time monitoring of network
traffic, identifying abnormal traffic patterns and automatically or manually
triggering defense mechanisms to mitigate the impact of DDoS attacks on data
security.
3.2.3.
You
acknowledge and understand that the
Internet is not an absolutely secure environment and that we will endeavor to
ensure and guarantee the security of any information you send to us. If our
physical, technical or administrative safeguards are destroyed, resulting in
unauthorized access, public disclosure, tampering with or damage to the
information which damages your lawful rights and interests, we will bear
corresponding legal liability.
In
the meantime, we strongly encourage you to take necessary actions to assist us
in ensuring the security of your account, including without limitation to
properly protect your account information, not to disclose any such information
to any third party, setting and using complex passwords, using your account in a
secure manner, not to use the services of Wahlap Official Website via other
transaction tools. If you note that your personal information, in particular
your account or password, has been leaked, please
contact us through any
method set forth in Section 7 “Contact
Us” of this Policy
so that we can take appropriate action. When using Wahlap Official Website, you
will inevitably disclose your personal information to us. Please implement the
aforementioned measures to prevent your information from being stolen or subject
to cyber-frauds.
3.2.4.
Security
Incident
In
the unfortunate event of a personal information security incident, our
information system center will immediately implement protection measures,
activate the emergency reaction plan and report to the information security
decision-making committee to prevent the security incident from exacerbating. We
will, in accordance with applicable laws and regulations, promptly inform you of
the basic information and possible impact of the security incident, actions we
have taken or will take in response thereto, suggestions for risk prevention and
reduction action you may take on your side, and remedial measures for you. We will notify you of the incident in a
timely manner by email, letter, telephone, push notification and other means.
Where it is difficult to inform each subject of personal information, we will
make an announcement in a reasonable and effective way. Meanwhile, we will also
report the resolution of the personal information security incident to the
competent regulatory authorities.
4.
Your
Rights
You
shall have the following rights to your personal information. Pursuant to the
applicable laws and regulations, under special circumstances, unless otherwise
arranged by you, your close relatives may exercise the following rights to your
personal information for their own legal and legitimate
interests.
4.1.
Accessing
and Correcting Your Personal Information
Unless
otherwise restricted by laws or regulations, you have the right to access your
personal information.
If you would like to exercise your data access right, you may manage your
information by sending an email to our email address (pii@wahlap.com). We will
respond to your request within 10 business days. If you would like to revoke
your authorization, please send an email to us again.
4.2.
Erasing
Your Personal Information
You
may send a request to us to erase your personal information under the following
circumstances:
(1)
If
our processing of the personal information violates laws or
regulations;
(2)
If
our processing of the personal information is in breach of our agreement with
you;
(3)
If
you no longer use Wahlap Official Website’s services or have closed your
account;
(4)
If
we no longer provide you with the services of Wahlap Official
Website.
If
we decide to act on your request for erasure, we will also notify the entities
that have obtained your personal information from us and request them to
promptly erase such information, unless continuous retention of your personal
information by the said entities is otherwise permitted by law, or the said
entities have obtained your authorization independently.
After
you erase your information from our services, we may not immediately erase the
corresponding information in our backup system, but will erase the information
when the backup is updated.
4.3.
Closing/deregistering
Your Account
You
may close/deregister your account at any time by sending an email to our email
address (pii@wahlap.com). We will not impose any unreasonable conditions or
additional requirements that will increase your obligations during the account
closing/deregistration process. After you close/deregister your account, unless
otherwise required by laws, regulations or applicable national standards, we
will promptly delete or anonymize your personal information. If we need to
retain certain personal information for the purpose of compliance with the
applicable laws, regulations or applicable national standards, we will not use
such personal information in our daily business operation.
4.4.
Copy
of Personal Information
You
have the right to obtain a copy of your personal information. If you would like
to obtain a copy of the personal information we collect from you, you may
contact us via any
method set forth in Section 7 “Contact
Us” of this Policy.
We will respond to your request within 10 business days. To the extent permitted
by law and feasible from a technical perspective, upon your request, we will
provide you with a copy of your personal information or transmit a copy of your
personal information directly to a third party you
designate.
4.5.
Complaint/
Report
You
have the right to lodge a complaint/report to Wahlap Official Website. You may
initiate a complaint/report by contacting us via any
method set forth in Section 7 “Contact
Us” of this Policy.
We will accept and process such complaint/report within 10 business
days.
4.6.
Responding
to Your Above Requests
For
security purposes, you may be required to provide a written request or otherwise
prove your identity. We may ask you to verify your identity prior to processing
your request.
In
principle, we will charge no fees for processing your reasonable requests.
However, we may charge certain fees at cost for responding to repeatedly raised
requests or unreasonable requests. If we decide not to respond to your request,
we will notify you of our reasons for the non-response. If you have any further
objection, you may lodge a complaint via
any
method set forth in Section 7 “Contact
Us” of this Policy.
If
fulfillment of your request is apparently difficult or would result in
unreasonably high costs, we suggest that you please consider other options to
protect your legitimate rights and interests.
5.
Protection
of Personal Information of Minors
Wahlap
Official Website is directed to adults only and we do not knowingly collect
personal information of minor under the age of 18 or “minors” as defined by laws
of the jurisdiction where the individual resides. If you are a minor, please do
not attempt to fill out our forms or send any personal information about
yourself to us. If we collect a minor’s personal information based on consent of
the minor’s parents, we will only use or publicly disclose the information as
permitted by law, with the express consent of the minor's parent or legal
guardian, or as necessary to protect the minor.
If
we become aware that a minor has provided us with his/her/its personal
information without the prior and verifiable consent of the minor's parent or
legal guardian, we will take steps to promptly erase such information as soon as
possible.
If
you believe that we may have collected personal information about a minor in
your custody without your consent, please
contact us via any
method set forth in Section 7 “Contact
Us” of this Policy
and we will erase such information.
6.
Notices
and Amendments
To
provide you with better services, our business may change from time to time, and
this Policy will be adjusted accordingly. We will not reduce any of your right
under this Policy without your express consent. We will update this Policy from
time to time and post it to this page, and please visit our website to keep
abreast of the latest version of this Policy. In the above circumstances, your
continuous use of our services constitutes your agreement to accept and be bound
by the revised Policy.
We
may provide more conspicuous notices in case of material changes (including,
with respect to certain services, we will notify you of specific changes to this
Policy through website announcements or even pop-up
windows).
Material
changes referred to in this Policy include, but are not limited
to:
(1)
Material
changes in our service model, e.g., the purpose of processing personal
information, types of personal information processed and methods of using
personal information;
(2)
Significant
changes in our ownership structure and organizational structure, e.g., change in
ownership due to business adjustment, bankruptcy, mergers and acquisitions,
etc.;
(3)
Changes
in the primary recipient(s) of sharing, transfer or public disclosure of
personal information;
(4)
Material
changes to your rights to participate in the processing of user information and
the method of exercising such rights;
(5)
When
there is any change in the department responsible for personal information
security, our contact information or channels for lodging
complaints;
(6)
When
the personal information security impact assessment report indicates a high
risk.
We
will also file the historical versions of this Policy on a special page of our
website for your reference.
7.
Contact
Us
You
may contact us in the following ways and we will respond to your
request.
(1)
You
may contact us using the online contact information provided on Wahlap
Technology’s website (e.g., http://www.wahlap.com);
(2)
You
may contact us through our email (pii@wahlap.com);
(3)
You
may contact Wahlap Technology using the customer service number (+
86-20-39226222);
(4)
You
may also send letters to the following address:
Wahlap
Technology, Room H1, 143 Yingxing East Road, Donghuan Street, Panyu District,
Guangzhou City, Guangdong Province, China, 511450.
Normally,
we will respond to you within 10 business days. If you are not satisfied with
our reply, particularly if you believe that your legitimate rights and interests
have been impaired by our processing of your personal information, you may also
seek resolution by commencing litigation at a court with proper
jurisdiction.
Addendum:
For Users in Certain Jurisdictions
1.
European
Union
Some
of our existing or potential users are located in the European Union. For these
existing or potential users, we will disclose the following in accordance with
the privacy policy requirements set forth in the General Data Protection
Regulation (“GDPR”):
1.1
Personal
Information Collected and Processed by Us; Legal Basis
If
you are a user located in the European Union, the definition of “personal
information” will be subject to Article 4 “Personal Data" of the GDPR. Personal
data refers to any information relating to an identified or identifiable natural
person; an identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person. We operate and sell the
relevant products and services through Wahlap Official Website. We are the
controller of your personal data under the GDPR.
When
processing your personal data, we process your personal data in accordance with
the legal bases permitted under the GDPR. These bases may include: processing is
necessary for the performance of a contract with you (for example, to provide
you with a service or product you request, to identify and authenticate you so
that you can use the website); processing is necessary for compliance with legal
obligation (for example, to comply with a mandatory disclosure requirement of a
law enforcement authority); processing is necessary for your legitimate
interests (for example, to manage your account relationships, to ensure the
security of services, to communicate with you regarding our products and
services); and processing is based on your consent (for example, placing
cookies, sharing end-user data with third parties for the purposes of providing
you with reservation, order placement and management, etc.). Please refer to our
disclosure in Sections 1 and 2 of the Policy for details.
1.2
Opt-in
Use of Cookies and Other Tracking Technologies
We
do not use cookies or similar tracking technologies to track or process your
personal information, unless they are strictly necessary cookies.
1.3
Rights
of Personal Data Subjects.
When
you use our services, we provide you with the following rights. We may restrict
your rights where applicable laws or regulatory requirements allow or require us
to do so, for example: (a) exercising your right would have a negative impact on
the privacy of others; (b) for the purpose of protecting our legitimate rights
and property; or (c) your request is impractical.
Ÿ
Right
of access and right to erasure: Subject to certain exceptions, you may request
to access or erase your personal data. Erasure of personal data may result in
closing of your account, including all information therein and related
thereto;
Ÿ
Right
to rectification, right to object, right to restriction of processing and right
to data portability: You may rectify or update your personal data, object to our
processing of your personal data, request that we restrict processing of your
personal data, or request that your personal data be provided to another data
controller;
Ÿ
Withdrawal
of Consent: If we collect and process your personal data based on your consent,
you may withdraw your consent at any time. Withdrawal of your consent will not
affect the legality of our process activities prior to the withdrawal, and will
not affect the processing of your personal data that is based on legal basis
other than your consent;
Ÿ
Right
to lodge a complaint: If you believe we have infringed your legitimate rights or
interests or breached the Policy, you may lodge a complaint in accordance the
approach set forth in section 4.5 of the Policy. In addition, you may lodge a
complaint to a data protection authority regarding our collection and use of
your personal data. You can find a list of local authorities responsible for
data protection in the European Union and their contact details at https://edpb.europa.eu/about.
If
you wish to enforce your rights under applicable law, please contact us via the
contact details set out in Section 4 (“Your Rights”) of the
Policy.
1.4
Processing
Outside the European Union
The
servers of Wahlap Official Website are located outside the European Union. When
you access or use our services, your personal data may be processed at or
transferred outside the European Union, including mainland China and Hong Kong,
China. We transfer such personal data in accordance with Article 49(1)(b) of the
GDPR for the purpose of providing our services to you in accordance with our
agreement(s) with you. The aforementioned country or jurisdictions may not
provide the same level of data protection as that offered under the laws of your
home jurisdiction. If you do not wish your personal data to be transferred to,
processed or maintained outside the country or jurisdiction in which you reside,
you shall immediately stop visiting or using Wahlap Official Website. For
further details about these transfers and the safeguards we use to facilitate
such transfers, please
contact us via
any method set forth in Section 7 “Contact Us” of the
Policy.
2.
United
States
Some
of our existing or potential users are located in the United States. With
respect to these existing or potential users, we make the following disclosures
in accordance with the privacy policy requirements of state laws of some states
of the United States (e.g., the California Consumer Privacy
Act):
2.1
Categories
of Personal Information We Collect
Please
refer to Section 1 of the Policy for the personal information we collect and
process when you use the services of Wahlap Official Website. If you are a
resident of the state of California, please refer to below for a summary of the
personal information we have collected in the last twelve (12) months, in the
categories as established and defined by the California Consumer Privacy Act, as
amended and pursuant to its successor statutes (collectively, the “CCPA”) [see California Civil Code
§1798.140 (o)]:
Ÿ
Identifiers:
name, email, WhatsApp, WeChat, IP address of and indirect, identifiable
identifiers associated with your device;
Ÿ
Commercial
information: information relating to your browsing, searching, clicking,
etc.;
Ÿ
Internet
or other electronic network activity information:
web logs (including your IP address, browser information, terminal device
information, specific visit time, specific pages visited, landing pages and the
visit duration, etc.), and the complaints or service requests lodged by you
through electronic means;
Ÿ
Audio
information: records of complaints or service requests you lodge by way of voice
messages.
We
generally do not collect the protected categories, biometric information or
education-related information of our users.
2.2
Categories
of Personal Information Disclosed to Third Parties
The
circumstances in which we provide your personal information to third parties are
described in Section 2.1 of the Policy. If you are a resident of the state of
California, please refer to below for a summary of the above-mentioned
information in the categories as established and defined by CCPA [see California
Civil Code §1798.140(o)]:
Ÿ
Identifiers:
name, email, WhatsApp, WeChat;
Ÿ
Internet
or other electronic network activity information:
the complaints or service requests lodged by you through electronic
means;
Ÿ
Audio
information: records of complaints or service requests you submit by way of
voice messages.
2.3
Storage
of Personal Information
If
permitted or required by law, we will retain your personal information for such
period of time as necessary to serve the purposes stated in the Policy to enable
your continued use of Wahlap Official Website.
2.4
No
sale of personal information.
We
have not sold and will not sell any
personal information of any users, as those terms are defined under the
CCPA.
2.5
Your
Personal Information Rights
If
you are a resident of the state of California, you have the following rights to
your personal information; however, your rights are subject to certain
exceptions. For example, we cannot disclose certain personal information if such
disclosure would create a substantial, articulable and unreasonable risk to the
security of personal information, your account with us or our network system. To
exercise your right of access and right to delete, please refer to Section 4
(“Your Rights”) of the Policy. To
confirm your identity, we may ask you to verify personal information that we
have on file for you or provide other documentation that identifies you to be
whom you claim to be. If we are unable to verify your identity based on the
information we have on file, we may ask you to provide us with additional
information, which we will use solely to verify your identity and for security
or fraud prevention purposes.
Ÿ
Right
against discrimination. You have the right not to be discriminated against while
exercising any of your rights described in this Section. We will not
discriminate against you for your exercises of your right of access or right to
delete;
Ÿ
Right
of access. You have the right to request us to present in writing the
information we collect or disclose about you, the corresponding business
purposes and the sources of such information. You have the right to request a
copy of certain personal information we collect about you during the 12 months
before your request;
Ÿ
Right
to delete. Subject to certain exceptions, you have the right to ask us to delete
any personal information we collect or retain about you;
Ÿ
Right
to Opt-out of personal information selling. You have the right not to have your
personal information sold. We have not sold and will not sell any
personal information of any users as those terms are defined under the CCPA.
Only
you or a person duly authorized by you to act on your behalf can make a
verifiable consumer request for your personal information as a California
consumer. If you use an authorized agent to submit such requests, we will
require either written evidence that the authorized agent is authorized to act
on your behalf or a copy of a power of attorney granting that
authority.
In
addition, California’s “Shine the Light” law permits residents of California to
request from us information about certain personal information we disclose to
third parties (please refer to California Civil Code §1798.83(e)(6) for a list
of categories of personal information). You may submit a disclosure request no
more than once per year at no charge, via any
method set forth in Section 7 “Contact
Us” of the Policy.
However, we will not share any personal information protected under the “Shine
the Light” law with third parties or affiliates for their direct marketing
purposes.
Our
disclosure above about our collection and processing of personal information by
reference to the GDPR and the relevant laws of the United States is solely for
the purpose of better protecting your personal information. Our disclosure above
shall in no circumstance be interpreted as we acknowledge that the GDPR and/or
the relevant laws of the United States are applicable to the business activities
of Wahlap Official Website or our processing practices. Whether the GDPR and/or
the relevant laws of the United States are applicable to the business activities
of Wahlap Official Website or our processing activities shall be assessed by
legal professionals in the relevant jurisdictions on a case-by-case basis, in
accordance with applicable laws.