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Privacy Policy

PRIVACY POLICY

Last updated on March 18, 2025

 

Wingderm Electro-Optics Ltd. (hereinafter referred to as “we” or “Wingderm®”) values the protection of users’ (“you”) personal information and privacy and wants you to understand how we collect, use, and publicly disclose information. This Privacy Policy outlines our privacy practices for the website www.wingderm.com and explains how we collect, use, store, share, and transfer your personal information when you use our services (such as our website, applications, content, and features) or interact with us online or offline, as well as the ways we provide for you to access, update, delete, and protect this information.

Please note that if a specific product we provide has a separate privacy policy or contains special provisions in the corresponding user service agreement, such a product’s privacy policy shall take precedence. For matters not covered in that product’s privacy policy and user service agreement, this policy shall apply.

Additionally, our online resources and services may also include links to third-party websites, mobile applications, or services. This Privacy Policy does not cover such content, and we are not responsible for the content, privacy practices, or data protection measures of websites or applications that are not owned or managed by Wingderm®. The inclusion of any links to such websites or resources in our products or services does not imply that we or our affiliates endorse them. Therefore, before providing any information to such third parties, we strongly recommend that you carefully review their privacy statements, policies, or terms to understand how they handle your personal information.

Please carefully read this Privacy Policy before using our services or providing us with your personal information.

This Policy will help you understand the following:

I.CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND THEIR PURPOSES

II.HOW WE USE COOKIE AND SIMILAR TECHNOLOGIES

III.HOW WE SHARE, TRANSFER AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION

IV.HOW WE PROTECT YOUR PERSONAL INFORMATION

V.HOW WE STORE YOUR PERSONAL INFORMATION

VI.HOW YOU REALIZE THE RIGHT TO MANAGE YOUR PERSONAL INFORMATION

VII.HOW WE PROTECT THE PERSONAL INFORMATION OF MINORS

VII.HOW WE UPDATE THIS POLICY

IX.HOW TO CONTACT US

 

I.Categories of Personal Information We Collect and Their Purposes

As a controller of personal information, we collect and process your personal information based on the principles of legality, legitimacy, and necessity, as outlined below.

  1. Information Automatically Collected and Used

When you visit our website, we and our service providers may automatically collect and use certain information through your browser, such as your computer type (Windows or Mac), screen resolution, operating system name and version, internet browser type and version, and other similar data. If you access our website via a mobile device, we may collect similar information, such as your device type and unique identifier. We collect such information to analyze website usage statistics for Wingderm®, troubleshoot issues, ensure service stability and cybersecurity, and conduct operational analysis to improve and optimize product interaction experiences.

  1. Personal Information You Provide When Using Our Products and/or Services

2.1 If you choose to receive our marketing and promotional information, we may collect and use the following personal information about you: your name, phone number, email address, age, country, city, and company, as well as information about your interactions with us, such as subscribing to or unsubscribing from marketing promotions or personal information you provide when participating in our events.

We may send you information about our products, services, events, and marketing activities via email, SMS, and other digital channels such as mobile applications and social media. If you no longer wish to receive our marketing emails or letters, please inform us and provide your name, email address, or mailing address. Additionally, you can opt out of receiving marketing information from us by following the unsubscribe instructions provided in such communications.

2.2 When you contact us through our telephone hotline, WeChat public account, email, or website, we may collect your communication/call records and content, as well as any contact information you provide, so that we can communicate with you, provide customer support, or record solutions and outcomes related to your inquiries.

When you apply for a position with us, for our legitimate human resources management purposes, we may collect different categories of personal data from you, depending on the requirements of the position you are applying for. These may include, but are not limited to, the following: your resume information such as name, gender, phone number, email address, photo, work experience, educational background, project experience, qualifications obtained, academic scores, and other information disclosed in your resume. We may also collect other personal information such as your ID card that you disclose to us during the recruitment process.

In general, we collect the above information directly from you. We may also obtain your personal data through third parties, such as recruitment websites, headhunting firms, or your referrers. Additionally, we may collect and use personal data that you have made publicly available on websites or social media platforms such as WeChat or LinkedIn.

If you provide us with any personal information about another individual, you represent that you have the legal right to do so and that you permit us to use such information in accordance with this Privacy Policy.

Unless explicitly requested, please refrain from sending or disclosing any sensitive personal information while using our services. Sensitive personal information refers to data that, if leaked or illegally used, could result in harm to an individual’s dignity, personal safety, or property. Examples include social security numbers, information regarding race or ethnicity, religious or philosophical beliefs, health or medical conditions, sexual life or sexual orientation, undisclosed criminal background information, specific identity information, financial accounts, tracking data, personal information of minors under the age of 16, or biometric or genetic data used for unique personal identification.

II.HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES

To ensure the normal and efficient operation of the website and provide you with a better browsing experience, we may use Cookies or similar technologies to collect your information when you visit our webpages. Cookies will help you call your information on subsequent visits to our website, simplify the process of entering personal information (such as one-click login), and enhance data security. We will not use Cookies for any purpose other than those described in this Privacy Policy.

 

You can modify the Cookies settings in your browser at any time to manage your preferences. You have control over managing or deleting Cookies. You can clear all Cookies stored on your computer or mobile device and have the right to accept or reject Cookies. Most browsers automatically accept Cookies, but you can usually modify your browser settings to reject Cookies according to your preferences. Additionally, you can delete all Cookies stored within the software. However, doing so may prevent you from fully experiencing certain convenient and secure features of our services. In most cases, we cannot directly identify your identity from the information collected through these technologies. If you have any questions regarding our use of Cookies or similar technologies, you may contact us using the information provided in the “How to Contact Us” section.

Ⅲ. HOW WE SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR PERSONAL INFORMATION

We will not share, transfer and publicly disclose your personal information with any other companies, organizations or individuals except Wingderm®.

In the event of merger, acquisition or bankruptcy liquidation of this product and/or service provider, or other situations involving merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will inform you of the name and contact information of the recipient, and require the new recipient who holds your personal information to continue to be bound by this Policy. If the recipient changes the original purpose or method of processing, we will require them to obtain your renewed authorization and consent.

We will only share your personal information for legal, legitimate, necessary, specific, and explicit purposes and will only share the minimum amount of personal information required to provide the services. In accordance with applicable laws, this Privacy Policy, and contractual agreements, we may share your personal information with our affiliated companies or third-party service providers to assist us in providing certain services, such as website hosting, IT support and related infrastructure services, cloud services, order fulfillment, customer service, email delivery, auditing, and other services. When your personal information is transferred to our affiliated companies or service providers in other countries, we will implement strict confidentiality agreements and other security measures to protect your personal information.

You fully acknowledge that in the following circumstances, we may process, share, transfer, or publicly disclose your personal information without obtaining your prior authorization or consent: (i) it is related to our performance of obligations under laws and regulations;(ii) it is directly related to national security or national defense security;(iii) it is directly related to public safety, public health or vital public interests;(iv) it is directly related to criminal investigation, prosecution, trial and judgment enforcement, etc.;(v) it is difficult to obtain your consent but the purpose is to protect vital legitimate interests about life and property for you and others;(vi) personal information has been publicly disclosed by you;(vii) personal information is collected from legally and publicly disclosed sources, such as legitimate news reports and government publications; (viii) it is necessary to enter into a contract with you upon your request; (ix) it is necessary to ensure the security and stable operation of our products and/or services, such as detecting and handling malfunctions

Please be aware that, under applicable laws, sharing or transferring de-identified personal information—where the recipient cannot restore or re-identify the original data subject—does not constitute the sharing, transfer, or public disclosure of personal information. The storage and processing of such data will not be subject to prior notice or consent from you.

IV.HOW WE PROTECT YOUR PERSONAL INFORMATION

To ensure the security of your information, we strive to implement physical, electronic, and administrative security measures that meet industry standards, establish reasonable systems, management regulations, and processes, and adopt confidentiality agreements to comprehensively protect your personal information, which aim to prevent unauthorized access, disclosure, use, modification, damage, or loss of your personal information. We use trusted security mechanisms to protect data from malicious attacks; implement access control mechanisms to ensure that only authorized personnel can access personal information; enforce confidentiality agreements with data handlers to maintain data security; and conduct security and privacy protection training sessions to enhance employees’ awareness of the importance of personal information protection.

Please be aware and understand that the Internet is not an absolutely secure environment. If you become aware of any unauthorized access or disclosure of your personal information, please contact us immediately using the details provided in this Privacy Policy, so we can take appropriate action.

V.HOW WE STORE YOUR PERSONAL INFORMATION

  1. Location where information is stored

Personal information collected and generated within China will be stored in China, except where applicable laws permit cross-border transfers. Your personal information may be stored and processed in countries where we or our service providers operate. By using our services or granting us authorization (where legally required), your personal information may be transferred to a country outside your place of residence.

When your personal information is transferred to our affiliates or third parties in other countries, we will complete the required procedures in accordance with applicable laws and regulations and adopt appropriate contractual and other measures to protect your personal information.

  1. Time limit for storage

We will retain your personal information for the minimum period necessary to achieve the processing purposes set forth in this Policy during your use of our products and/or services, while also complying with legally mandated retention periods where applicable. Once the retention period expires, we will delete your personal information or anonymize it in accordance with applicable legal requirements.

VI.HOW YOU REALIZE THE RIGHT TO MANAGE YOUR PERSONAL INFORMATION

We highly value your concerns regarding personal information and strive to protect your rights to access, correct, delete, and withdraw consent for your personal information. This ensures that you have full control over your privacy and security. Your rights include:

  1. Access and Correction of Your Personal Information

Except as otherwise required by laws and regulations, you have the right to access and correct your personal information at any time.

  1. Deletion of Your Personal Information

You may request the deletion of your personal information under the following circumstances: (1) If our processing of personal information violates laws or regulations; (2) If we collect or use your personal information without obtaining your consent; (3) If our processing of personal information seriously violates our agreement with you.

If we decide to comply with your deletion request, we will also notify entities as possible that have obtained your personal information from us and request them to delete it in a timely manner, unless otherwise required by laws and regulations or those entities have obtained your independent authorization.

After you or we assist in deleting the relevant information, due to applicable legal and security technology constraints, we may not be able to immediately remove the information from our systems. However, we will securely store your personal information and restrict any further processing until deletion or anonymization can be achieved.

  1. Change the scope of your authorization or withdraw your authorization.

Please understand that certain business functions require some essential personal information to operate. If you withdraw your consent or authorization, we will no longer be able to provide you with the corresponding services, nor will we continue processing the related personal information. However, your decision to withdraw consent or authorization will not affect any previous processing of your personal information based on your prior consent.

  1. Get a copy of your personal information.

You have the right to obtain a copy of your personal information. If you wish to receive a copy of the personal information we have collected, you may contact us at any time. Subject to relevant legal provisions and technical feasibility, we will provide you with a copy of your personal information upon request.

  1. Respond to your above request

If you wish to exercise your rights, you may contact us using the methods provided in this Privacy Policy. For security reasons, we may require you to submit a written request or provide proof of identity. We will respond to your request within 15 days after receiving your feedback and verifying your identity.

We will not charge fees in principle for your reasonable request. However, for requests that are repeated multiple times or exceed reasonable limits, we will charge a cost-based fee depending on the circumstances. We may also refuse requests that are unreasonably repetitive, require too many technical effort (e.g., it is necessary to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are impractical (e.g., backing up information stored on tape is involved).

VII. HOW WE PROTECT THE PERSONAL INFORMATION OF MINORS

Our Services are not directed to individuals under the age of 16 (or the applicable age in your country), and we request that these individuals not provide personal information through our website. If your child has submitted personal information and you would like to request its deletion, please contact us by info@wingderm.com. upon verification, we will delete such data from our records as requested by the parent or guardian.

VIII.     HOW WE UPDATE THIS POLICY

We may periodically update this Privacy Policy to reflect changes in legal, technical, or business requirements. Without your explicit consent, we will not reduce the rights you are entitled to under this Privacy Policy. We will post any changes to this Privacy Policy on this page. You can check the “Last Updated On” section at the top of this Privacy Policy to see when it was last revised. By continuing to use our services or contacting us through Wingderm®’s various channels, you indicate your acceptance of the updated Privacy Policy.

IX.HOW TO CONTACT US

If you have any questions or concerns about how we handle your personal information or this Privacy Policy, particularly if you believe that our processing of personal information has infringed upon your legal rights, you may contact us via:

Contact Information: info@wingderm.com

In general, we will respond to your inquiry within 15 days after receiving your request and verifying your identity, except as otherwise required by applicable laws and regulations. If circumstances cause a delay in our response, we will promptly notify you and provide an estimated response date.