Current version dated November 11, 2021

WPG Holdings, a Taiwan corporation, and its affiliates (collectively, “WPG”, “we”, “our” or “us”) values your privacy. We commit to protect your privacy with the highest level of security. To understand how we process your personal information, please read this Privacy Statement (hereinafter this “Statement”) carefully:

What is personal information?

Personal information means data that can be used to identify, or can reasonably be linked directly or indirectly to, an individual.Identification can be by the data alone or in conjunction with any other data in our possession. Examples of personal information include your name, birthdate, location, country of residence, photographs, email address.

Personal information we collect and the purposes of collection

We will use automatic or non-automatic methods permitted by the laws and regulations to process your personal information. The chart below outlines, by the business process involved, the types of personal information we collect under such process, the purpose of collection and processing, and how we process that the personal information. Most importantly, we describe how you could manage your personal information with us.

Cookies

We or our authorized service providers may use cookies and similar tracking technologies to collect personal information whenever you visit our websites, including the above-mentioned websites and the website of DaDaWant and WPG South Asia, with or without logging into an account. The information collected with these technologies helps us personalize your experience, prevent fraud and enhance the security of our websites and service. You could disable or decline some cookies for our websites and services. For more details of the collection and use of Cookies, please refer to our Cookie Policy.

Retention and deletion

We store your personal information within the following periods, whichever is longer:
a) within the duration necessary for fulfilling the above purposes and conducting relevant business;
b) within the period if we are required by applicable laws or regulations to retain the information; or
c) as long as necessary to assist with any governmental and judicial investigations, to initiate or defend legal claims or for the purpose of civil, criminal, or administrative proceedings.

Data transfers

Your personal information will be treated as strictly confidential and will be shared only with the categories of data recipients listed below. We will only share your data with third-party data controllers outside of the WPG Group with your consent, and you will have an opportunity to choose for us not to share your data.

We may disclose your personal information to the following recipients:
a) Our affiliated entities within our global group of companies and branches worldwide to provide you our services, for internal administration purposes, to detect and deal with data breaches, illegal activities, and fraud, and to maintain the integrity of our information technology systems.
b) Third party service providers whom we sub-contract to work on our behalf or for us and therefore may have access to your information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Statement, who perform functions such as information processing, auditing, credit reference, managing and enhancing customer data, providing customer service, logistics support, marketing support, informational systems technical support, to help us provide, analyze, and improve our services such as data storage, database management, web analytics, and improvement of our service features, and to assist us in detecting and dealing with data breaches, illegal activities, and fraud;
c) Our business partners to jointly provide you our services, including but not limited to credit card services and payment services.
d) Counterparties to merge or acquire all or a portion of WPG’s business assets where personal information may be transferred as one of the business assets of WPG.
e) Governments and/or government-affiliated institutions, courts, or law enforcement agencies, to comply with our obligations under relevant laws and regulations, enforce or defend our policies or contracts with you, respond to claims, or in response to a verified request relating to a government or criminal investigation or suspected fraud or illegal activity that may expose us, you, or any other of our customers to legal liability.
f) Third parties involved in a legal proceeding, if they provide us with a court order or substantially similar legal procedure requiring us to do so.

International data transfers

As note above, WPG may transfer your personal information to the abovementioned recipients who may be in countries other than the country in which you reside. Although these countries may have data protection laws that are different to the laws of the country you reside in, we ensure appropriate safeguards in place so that your personal information will remain protected in accordance with this Statement.

Data from Minors

WPG’s products and services are not designed nor intended to be used by children under 16 years of age. If children under the minimum age of the relevant jurisdiction must use WPG’s products and services, explicit parental consent must be provided and verified. If WPG is notified or discovers that data collected is from a child under the minimum age, WPG will take procedures to delete the information as soon as possible.

Your rights over your data

In accordance with applicable data protection laws, you may exercise the following rights over your personal information:
a) You may request to access your personal information or request a copy of your personal information, provided that your request will not adversely impact WPG or others’ interests and rights.
b) You may request WPG to supplement or correct your personal information, provided that you are able to provide a reasonable explanation.
c) You may request WPG to cease processing or erase your personal information, provided that WPG has no legal grounds to keep processing your personal information.

Security

We have implemented technical and organizational security measures to safeguard the personal information in our custody and control. Such measures include, for example, limiting access to personal information only to employees and authorized service providers who need to know such information for the purposes described in this Statement, as well as other administrative, technical and physical safeguards.
While we endeavor to protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

How to contact us

If you have any questions about this Statement or intend to exercise any of the above rights, please send your request to this email:[wpgh_privacy@wpgholdings.com].
For DADAGO’s visitors, you may also contact us by clicking “Online Service” > “Contact Us” on the website of DADAGO.

Changes to Statement

We may make amendments to this Statement when needed to reflect changes in our privacy practice. We will notify you of such amendment through our website or send the amendment to your email address. We encourage you to regularly review this Statement to understand how your data is handled.

Additional Information for Residents in other Jurisdictions

WPG is a multinational group with companies and operations all over the world. Some of our businesses primarily operate in Taiwan and China. By using our services and providing us with your information, you acknowledge and understand that the transfer, storage and processing of your personal information may be performed in countries other than the country in which you reside. WPG may be required to supplement the Statement under the laws of other countries. If you are a resident of such other countries, you may find out more information about your privacy rights in the following parts.

Additional information for EU residents

When you are in the European Union, the European Regulation (EU) 2016/679, also referred to as the “General Data Protection Regulation” or “GDPR”, applies to the collection and processing of your personal information by WPG.

If WPG is not able to obtain a valid consent to process your personal information from you, WPG may still collect and process your personal information based on the following legitimate interests of WPG or a third party:
a) Implementation and operation of a group-wide organizational structure and group-wide information sharing;
b) Right to freedom of expression or information, including in the media and the arts;
c) Prevention of fraud, misuse of company IT systems, or money laundering;
d) Direct marketing to WPG’s existing clients;
e) Operation of a whistleblowing scheme;
f) Physical security, IT and network security;
g) Internal Investigations;
h) Proposed mergers and acquisitions

In the above circumstances, you may object to such processing based on the legitimate interests of WPG or a third party (except direct marketing), unless WPG has compelling legitimate grounds for the processing which override your interests, right and freedoms. You may also choose to opt out of direct marketing from WPG at any time; in such case, WPG will stop sending you marketing materials or personalized content without undue delay.

In addition to the right of objection and the rights described in the section “Your rights over your data” of this Statement, you also have the right to withdraw your consent to WPG’s processing of your data at any time, provided that the processing is based on your consent, and the right to transmit your personal information provided by you to another entity designated by you in a structured, commonly used and machine-readable format. However, WPG will refuse your request to transmit your personal information if the processing of such personal information is not based on your consent or a contract with you or is not carried out by automated means.

If WPG intends to transfer your personal information from EU to non-EU region, we will adopt appropriate measures such as the standard contractual clauses to safeguard your personal information and your privacy rights where the recipients are not located in countries subject deemed to have an adequate level of data protections by the European Commission.

WPG’s representative for GDPR purposes in the European Union is [WPG EMEA B.V.], with registered address in [Zekeringstraat 42, 1014BT Amsterdam]. If you have any concerns or any questions about your privacy rights, you may contact us by using the methods described in the section “How to Contact us” of this Statement or by communicating with our DPO (contact email setting up). If you are not satisfied with our response, you may contact the competent supervisory authority of your place of residence. In this link you can find the contact details of the supervisory authority in EU.

Additional information for Singapore residents

When you are in Singapore, the Singapore Personal Data Protection Act 2012 shall also apply to the collection, processing and use of your personal information by WPG. If the processing of your personal information is based on your consent, including your agreement to provide your personal information due to the contract between you and WPG, , you may have a right to withdraw your consent at any time by giving a reasonable notice to [wpgh_privacy@wpgholdings.com].

Additional information for South Korea residents

When you are in South Korea, the South Korea Personal Information Protection Act shall also apply to the collection, processing and use of your personal information by WPG. Even though your information is no longer needed for the purposes specified in this Statement, WPG may be required to keep your personal information in accordance with the applicable laws.

The deletion procedures and methods are as follows:
a) Deletion Procedure:WPG will delete personal information after the retention period is expired. The retention period is decided in accordance with the purpose of the collection and use or the legal requirements to retain personal information.
b) Deletion Methods: WPG will dispose of the personal information contained in documents or in paper form by way of physical destruction, such as shredding, of all such documents containing personal information. If the personal information is in electronic form, WPG will use appropriate tools or techniques to complete their deletion or exclude from further processing permanently and irreversibly.

You are entitled to exercise all the rights described in the Section “Your rights over your data” in this Statement. However, please note that WPG may charge a reasonable fee within the scope of the actual cost if you request for right of access.

Additional information for California residents

If you reside in California, the California Consumer Privacy Act will apply to the collection, processing and use of your personal information by WPG. If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we retain. You also have the right to request WPG to delete your personal information, subject to legal exceptions.

Please make your requests through the designated email address specified in the Section “How to contact us” in this Statement, or by the toll-free number: [888-WPG-8881]. If you authorize an agent to make requests on your behalf, please provide your agent a signed permission for him/her to make requests. Before responding to your requests, we may need to verify your identity or the identity of your authorized agent. We may contact you through the contact details you provide in your member account to confirm the authenticity of the requests. Therefore, please make sure your contact details are up-to-date. If WPG fails to verify your identity, we may refuse the requests you make. You also have a right not to receive discriminatory treatment by WPG for the exercise of your privacy rights.

For the personal information we have collected in the preceding 12 months, the source of the personal information and the purposes of collection, please refer to the section “Personal information we collect and the purpose of collection” in this Statement.

WPG does not sell your personal information.