Well-Link Mulan 2125 Privacy Policy

1. What Personal Data Do We Collect

During your utilization of our Service, we adhere strictly to applicable Data Protection Laws. We utilize your personal data for lawful purposes and ensure the security of such data. Based on the above assurances, we collect the following information pertaining to you:

a) Basic Account Data

If you are not registered, we will not be able to provide you with the full content of our Service. To use the full Service, you may be required to register or have an account on our application. In this case, we may ask you to provide us with certain personal data that can be used to contact or identify you, which serves the purpose of establishing communication and validating your identity. Such personal data empowers us to verify and authenticate your identity, effectively resolve any login complexities, and gain a deeper comprehension of your needs. Moreover, it aids us in customized introductions, product promotions, acquiring insights into prospective clientele, procuring timely and precise feedback on user experiences, and augmenting our Service. To this end, we may collect the required personal data as follows:

• Unique or online IDs (such as third-party IDs from Meta, Apple, Valve, Google and Microsoft)
• Usernames (such as names from Steam, Quest, Apple) and profile photo
• Email Address
• Internet Protocol address
• Geolocation: country and state

During the setup of your account, the account is automatically assigned a number (the "User ID") that is later used to reference your account without directly exposing personally identifying information about you.

We do not require you to provide or use your real name for the setup of a User ID.

b) Transaction and Payment Data

In order to make a transaction on our application (e.g. to purchase subscriptions for content and services we offer), you may need to provide recharge and consumption data of your IDs on our application to us to enable the transaction. Likewise, we may receive data from your payment service provider for the same reasons.

c) Usage Data

Usage Data is collected automatically when using our Service. To optimize the experience of using our Service and to understand how you access and use our Service, we collect your usage data records. We may use this data for graphical analysis, as well as to inform you about updated or upgraded services and features, to provide customer support, to inform you about new operational events, promotions and etc.

When you access or use our Service, we will collect the following information:

• Device information: The information about your device, hardware and software, such as device name, device manufacturer, device time zone, device model and version, device identifiers, operating system type and version, system attributes, carrier information, and version of Mulan 2125, SDK version, CPU architecture information, timestamp.
• Account information: Consumption records based on your use of our Service, including content or service information, account balance, consumption amount, recharge records, and other data.
• Log information: Your detailed usage of our Service and save them as relevant network logs. For example, the language used, Wi-Fi status, access time, use records and other information identifiers and other diagnostic data, content and services usage time, duration of content or service, performance data, crash data and etc. We derive a rough estimate of the state and country where you are located from your IP address, however we will not obtain further address details than the state.
• User account support information: Consultation records, fault reporting records and troubleshooting processes for user failure generated by your use of Service.

When we provide you with business functions or specific services, we will collect, use, store, provide and protect your personal data in accordance with this Policy; if we collect your personal data beyond this Policy, we will separately explain the scope and purpose of information collection to you, and collect your personal data necessary to provide corresponding Service after obtaining your consent.

2. How We Use Your Personal Data

In order to be able to provide satisfactory Service, we may collect, use, process and/or disclose your personal data for one or multiple purposes as described in this Policy, including the following purposes:

• To provide and maintain our Service, including monitoring the usage of our Service.
• To manage your account: To manage your registration as a user of the Service. The personal data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
• For the performance of a contract: The development, compliance and undertaking of the purchase contract for the contents or services you have purchased through the Service.
• For research and development purposes: To conduct research, analysis, and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our Service.
• To contact you: To contact you by email, or other equivalent forms of electronic communication, such as an application's push notifications regarding updates related to the functionalities, content or services, when necessary or reasonable for their implementation. To provide you with news, special offers and general information about other contents, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• To manage your requests: To attend and manage your requests to us.
• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our Service users is among the assets transferred.
• For compliance with legal and regulatory requirements: To respond to requests for information from public and governmental/regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes.
• For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, evaluating and improving our Service and your experience. To achieve any other incidental business purposes related to or in connection with the above.

For the purposes set forth above, our affiliates may be commissioned to process your data, provided that such affiliates comply with the terms in this Policy. Affiliates in this Policy shall mean an entity that directly or indirectly controls, is controlled by or is under common control with Well-Link.

3. How We Store Your Personal Data

When you access our Service, the locations of servers for our Service are distributed globally. In principle, the personal data we collect will be stored in United States. We will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Policy and any applicable laws and regulations.

Where required by law, we will only store your personal data as long as necessary to fulfill the purposes for which the personal data is collected and processed or where the applicable laws and regulations provide for a longer storage and retention period, unless deleted in accordance with your request or as otherwise required by law.

When we no longer need to use your personal data or you request to remove or delete it, we will delete it from our systems and records and/or take measures to anonymise it so that you cannot be identified (unless we need to retain your personal data to comply with legal or regulatory obligations with which we must comply). However, we will retain your personal data as long as necessary for applicable laws and regulations, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable Service.

4. How We Transfer Your Personal Data

In principle, the personal data we collect will be stored in United States. By using the Services, you authorize us to receive, process, transfer, and store your information in and to the United States as applicable. For a business purpose and after we perform our obligations under the law, your personal data may be transferred to, or be accessed from, the overseas jurisdictions of the country/region where you use the content or service. Where cross-border transfers of data are necessary, we will take reasonable steps to safeguard the privacy of your personal data. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal data. We will ensure that we provide a standard of protection to the personal data so transferred that is comparable to the protection under the applicable Data Protection Laws.

Your consent to this Policy followed by your provision of your personal data represents your agreement to such transfer.

We will comply with conditions under applicable Data Protection Laws to take appropriate steps to ensure that the overseas recipient is bound by legally enforceable obligations or specified certifications. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal data.

5. Who Do We Disclose Your Personal Data To

We may disclose your personal data to the categories of recipients we describe as follow, such as to provide our Service and to deliver advertisements. You acknowledge that you have foreseen the occurrence of such disclosure when you provide your personal data.

a) Affiliates and Subsidiaries

We may disclose your personal data to our affiliated companies as necessary for the purposes outlined in this Policy. All affiliated companies may only use your personal data in accordance with this Policy.

b) Competent Authorities

We may provide a certain portion of your personal data to governmental authorities as so requested according to applicable laws and regulations. Besides, we may disclose a certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary.

In addition, to be required by applicable laws and regulations, we reserve the right to disclose your personal data in the cases if we, in good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you.

c) Third-Party Provider

In order to provide, maintain and improve our Service to you, we may need to provide your personal data to third-party service providers to complete content or service orders, specific services including account login, payment, or the processing, analysing and/or storing of data. And we will require that any third-party service providers processing your personal data only do so on our behalf and for purposes consistent with this policy.

Besides, if we are involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different policy.

d) Enforcing our Rights

We may disclose your information as necessary to enforce our rights arising from any contracts entered into between you and use.

e) Necessary for Purpose

We may disclose your information as necessary to fulfill the purpose for which you provided it.

f) With Your Consent

We may disclose your information with your consent.

g) Other purposes

We may disclose your information for any other purpose disclosed by us and accepted by you when you provide the information.

6. How We Protect Your Personal Data

We are committed to maintaining the Privacy and integrity of your personal data no matter where it is stored. We take a range of technical and organizational data security measures to help protect it.

Even so, the transmission of data via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal data, we cannot guarantee the security of the data transmitted through our Service or otherwise via the internet. You must be aware of hacking, cyber-attacks, and other risks on the Internet. And you should always be diligent when it comes to the protection of your personal data.

7. Cookies and Similar Technologies

Cookies are text files that are placed on your device when a website is loaded on your browser. They are widely used to make websites work or work more efficiently, as well as to provide information to the owner of the site or to another site that recognizes that cookie. Our Service does not use these "cookies "explicitly.

8. Your Rights

You have certain rights in relation to the personal data we hold about you, subject to the applicable Laws and Regulations. We will respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us using the contact details under the "Contact and Complaint" heading below.

To protect the security of your account and your personal data, we may ask you to provide certain additional information before we respond to your requests. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.

a) Right of Access

You may have the right to access your personal data that we hold about you, i.e.,(i) information whether your personal data is collected or disclosed, (ii) categories of your personal data which has been collected or disclosed, (iii) categories of sources from which your personal data is collected, (iv) business or commercial purpose for collecting or disclosing your personal data (if any); and (v) you have the right to require us to provide a duplicate of your personal data undergoing processing.

b) Right to Rectification

If your personal data is inaccurate or incomplete, you may have the right to request for rectification of your inaccurate personal data according to applicable laws and regulations. Please contact us, and we will do so after verification.

c) Right to Erasure

You may have the right to request the deletion of your personal data if the reason why we collect your personal data does not exist anymore, or if there is another legal ground for its deletion. Upon receipt of a verifiable request from you, we will delete your personal data from our records. In certain specific cases, we may voluntarily delete or anonymise your personal data or cease any unnecessary processing of it.

You acknowledge and agree that as a result of deleting your account, you will lose access to our Service, including the account information, subscriptions, and other related data linked to such account, and lose the possibility to access other services through the account.

d) Withdraw

If we have collected and processed your personal data with your consent, you can withdraw your consent in accordance with applicable laws. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent. In many circumstances, we need to use your personal data in order for us to provide you with the services that you require. If you do not provide us with the required personal data, or if you withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the services that you require.

9. Age Limits and Children Protection

Our Service is not directed at children under the age of 17. We do not knowingly collect personally identifiable information from anyone under the age of 17. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 17 without verification of parental consent, we may take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from your parent or legal guardian, we may require your parent's or legal guardian’s consent before we collect and use that information.

10. Contact and Complaint

If you have any questions about this Policy or our rules for handling your personal data, or if you would like to submit questions or comments, please contact us at: Email: developer@well-linktech.com.

11. Changes

We may periodically modify, adjust, or revise the terms of this Policy from time to time due to changes in our Service or updates in applicable laws and regulatory requirements. We will not substantially reduce your rights under this Policy without your express consent.

If we make any material changes to this Privacy Policy, we will post the updated Policy here and notify you in accordance with relevant legal requirements.

By continuing to use our Service you acknowledge that you have read and understood how we process your personal data according to the updated Privacy Policy.

12. Additional Information for Users from California

The CCPA grants California residents certain privacy rights regarding the personal data we collect. We are committed to respecting these rights and complying with the CCPA. The following explains these rights and our practices with respect to them.

• Right to Know. Under the CCPA you have the right to request that we disclose to you what personal data we collect, use, disclose, and sell about you, and the reason why we collect, use, disclose, and sell such data.
• Right to Request Deletion. You also have the right to request deletion of personal data that is in our possession, subject to certain exceptions. Please note that your request to delete data may impact your use of our service in some cases, and we may decline to delete information for reasons set forth in this Privacy Policy or as permitted by the CCPA.
• Other Rights. The CCPA also gives California residents the right to opt-out of the sale of their personal data, and to limit the use and disclosure of sensitive personal information. We do not sell personal data and have not done so in the past 12 months. You also have a right to receive notice of our practices at or before the collection of your data, and the right to ask us to correct inaccurate data that we have about you. Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.
• Exercising Your Rights. The primary means of accessing, managing or deleting your personal data is through the application. If you are unable to access or delete data, you can also contact us using the contact details provided in "Contact and Complaint" of this Privacy Policy.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

13. Data Rights of European Residents:

The laws of the United Kingdom and the European Economic Area and other territories provide their residents with certain data protection rights. If you are resident of the United Kingdom or the European Economic Area, these are your rights:

• The right to access - You have the right to request we provide you with copies of your personal data. We may charge you a small fee for this service.
• The right to rectification - You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we to complete information you believe is incomplete.
• The right to be forgotten - You have the right to request that we erase certain types of personal data (see Right to Erasure above).
• The right to restrict processing - You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing - You have the right to object to we' processing of your personal data, under certain conditions.
• The right to data portability - You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.