Wanbang Tye Official Website Privacy Policy

1.1 Personal Information You Provide to Us

1.2 To Provide You with Security Assurance

To enhance the security of your use of the services we provide and to more accurately prevent phishing website fraud and Trojan horse viruses, we may use or integrate your personal information, as well as information that our affiliates or partners have obtained with your authorization or are legally permitted to share. Based on factors such as your usage habits and frequently used software information, we will comprehensively assess your account and transaction risks. This includes identity verification, and the prevention, detection, and investigation of potential security risks such as fraud, network viruses, and network attacks, as well as actions that violate the agreements, policies, or rules of us or our affiliates. The purpose is to protect your legitimate rights and interests, those of other users, and ours or our affiliates', and to record links ("URLs") that we consider risky.

1.3 How We Use Cookies and Similar Technologies

Cookies and similar device identification technologies are commonly used on the internet. When you use our products/services, we may use related technologies to send one or more Cookies or anonymous identifiers to your device to collect, identify, and store information about your visit and use of our products/services. We use Cookies primarily to ensure the secure and efficient operation of our products and services, to help you enjoy a more convenient access experience, to improve our products and services, and to simplify the steps and processes for filling out forms. We will not use Cookies for any purposes other than those described in this Privacy Policy.

You can manage or delete Cookies based on your preferences. Most browsers accept Cookies automatically, but you can usually modify your browser settings to refuse Cookies according to your needs. Alternatively, you can also clear all Cookies saved within the software, but please note that you may consequently be unable to use certain features or services that rely on Cookies.

1.4 Statement on Exceptions

Please be fully aware that, in accordance with laws and regulations, we may collect your personal information without obtaining your authorization and consent under the following legally prescribed circumstances:

1. Where it is necessary for the conclusion or performance of a contract to which you are a party;
2. Where it is necessary for the performance of a statutory duty or statutory obligation, such as those directly related to national security, defense security, public security, and statutory duties or obligations related to criminal investigation, prosecution, trial, and enforcement of judgments;
3. Where it is necessary to respond to public health emergencies, or to protect the life, health, and property safety of natural persons in emergency situations;
4. Where personal information is processed within a reasonable scope for the purposes of conducting news reporting, public opinion supervision, and other activities carried out in the public interest;
5. Where personal information is processed within a reasonable scope in accordance with the provisions of the Personal Information Protection Law of the People's Republic of China, concerning information that individuals have disclosed themselves or that has otherwise been lawfully made public;
6. Other circumstances stipulated by laws and administrative regulations.

2.1 External Provision of Information

We treat your personal information with a high duty of care. Except where we have obtained your authorization and consent, or based on other lawful grounds in accordance with relevant laws and regulations, we will not provide your personal information to any other company, organization, or individual.

Some of the products/services we provide require the participation of third parties to complete. Therefore, we may provide certain portions of your personal information to our affiliates and/or third-party service providers or partners to ensure and optimize the products/services we offer you. We will strictly restrict and manage the external provision of personal information in accordance with the provisions of laws and regulations.

1. With your prior explicit consent or authorization.
2. To realize product/service functionality. In order to achieve product capabilities or provide services to you, we will provide your personal information to the following third parties:
   • Our Affiliates: We may share your information among affiliated companies that are under common management, control, or in which we hold significant interests, and such use is bound by the purposes stated in this Privacy Policy. If an affiliate changes the purpose for processing personal information, it will seek your authorization and consent again.
3. As required by applicable laws, regulations, administrative provisions, or judicial authorities. For example: Providing your information in accordance with laws, regulations, legal processes, or the requirements of competent administrative or judicial organs.
4. To handle disputes or controversies between you and others at your request.
5. Rights Protection: Where required or permitted by law, and when it is necessary to protect the interests, property, or safety of our Company, our affiliates or partners, you or other users, or the public from harm.
6. Researching New Projects and Services: In order to provide you with better services, we may explore and advance potential business cooperation projects with third-party partners. We may share certain portions of your personal information with potential business partners after appropriate processing, such as de-identification or anonymization.

2.2 Transfer

We will not transfer your personal information to any company, organization, or individual without obtaining your explicit consent.

In the event of transactions involving our company, such as mergers, acquisitions, divisions, dissolution, or asset transfers, if a transfer of your personal information is involved, we will inform you of the name and contact information of the recipient prior to the transfer. We will require the company, organization, or individual receiving your personal information to continue to be bound by this Privacy Policy. Otherwise, we will require that company, organization, or individual to seek your authorization and consent again.

2.3 Public Disclosure

We will comply with relevant laws and regulations and keep your personal information confidential. We will not proactively disclose your personal information that you have not made public yourself, unless required by laws and regulations or with your separate consent.

2.4 Exceptions to the Requirement of Obtaining Consent for Sharing, Transfer, or Public Disclosure

Please be fully aware that, in accordance with laws and regulations, we may share, transfer, or publicly disclose your personal information without obtaining your prior authorization and consent under the following legally prescribed circumstances:

1. Where it is necessary for the conclusion or performance of a contract to which you are a party;
2. Where it is necessary for the performance of a statutory duty or statutory obligation, such as those directly related to national security, defense security, public security, and statutory duties or obligations related to criminal investigation, prosecution, trial, and enforcement of judgments;
3. Where it is necessary to respond to public health emergencies, or to protect the life, health, and property safety of natural persons in emergency situations;
4. Where personal information is processed within a reasonable scope for the purposes of conducting news reporting, public opinion supervision, and other activities carried out in the public interest;
5. Where personal information is processed within a reasonable scope in accordance with the provisions of the Personal Information Protection Law of the People's Republic of China, concerning information that individuals have disclosed themselves or that has otherwise been lawfully made public;
6. Other circumstances stipulated by laws and administrative regulations.

4.1 Exercising Your Rights

You may exercise your rights, including the rights to access, correct, delete, and manage your authorizations, by contacting us using the methods provided in the "Contact Us" section.

4.2 Responding to Requests

We generally do not charge a fee for reasonable requests. However, we may charge a certain cost fee for requests that are repeated multiple times or exceed reasonable limits, depending on the circumstances. We may decline requests that are manifestly unfounded or repetitive, require disproportionate technical effort (e.g., developing new systems or fundamentally changing existing practices), risk the legal rights of others, or are highly impractical (e.g., concerning information stored on backup tapes).

Notwithstanding the above, in the following circumstances, we may be unable to comply with your request:

1. Where it is necessary for concluding or performing a contract with you;
2. Where it is necessary for us to fulfill our legal obligations as stipulated by laws and regulations;
3. Where it is directly related to national security or national defense security;
4. Where it is directly related to public security, public health, or major public interests;
5. Where it is directly related to criminal investigation, prosecution, trial, or execution of judgments;
6. Where it is necessary to protect the life, health, or property-related legal rights and interests of you or other individuals in an emergency situation;
7. Where personal information is processed within a reasonable scope for the purpose of news reporting and public opinion monitoring carried out in the public interest;
8. Where there is sufficient evidence showing that you have subjective malice or are abusing your rights;
9. Where personal information is processed within a reasonable scope in accordance with the Personal Information Protection Law of the People's Republic of China, concerning information you have made public yourself or that has been otherwise lawfully disclosed;
10. Where responding to your request would seriously harm the legitimate rights and interests of you or other individuals or organizations;
11. Where trade secrets may be involved;
12. Other circumstances stipulated by laws and regulations.

5.1 Data Protection Measures

We attach great importance to the security of your personal information and have implemented reasonable and feasible security protection measures consistent with industry standards to protect your information from unauthorized access, disclosure, use, modification, damage, or loss. For example, we use encryption technologies to enhance the security of personal information; data exchanged between your browser and our servers is protected by SSL protocol encryption, and we provide the secure HTTPS protocol for browsing; we employ trusted protection mechanisms to prevent malicious attacks on personal information; and we deploy access control mechanisms to endeavor to ensure that only authorized personnel can access personal information. We regularly conduct information security and privacy protection training courses to strengthen employees' awareness of the importance of protecting personal information.

5.2 Security Certifications

Our critical systems have undergone assessment and filing for the National Information Security Level Protection (Class 3) certification, and have also obtained internationally recognized security certifications such as ISO/IEC 27001, ISO/IEC 27701, ISO 37301, and TISAX. We have established effective coordinated communication mechanisms with regulatory authorities and third-party assessment institutions to promptly resist and address various information security threats, providing all-around safeguards for your information security.

5.3 Security Incident Response

In the unfortunate event of a personal information security incident, we will immediately establish a leadership team for emergency response, activate contingency plans to prevent the incident from escalating, and notify you promptly as required by laws and regulations. This notification will include: the basic circumstances of the security incident and its potential impact, the measures we have taken or will take to address it, recommendations for steps you can take to mitigate risks, and the remedial measures available to you. We will inform you of the incident details via email, letter, phone call, push notification, or other methods. If it proves difficult to notify each individual affected, we will issue a public notice through reasonable and effective means. Simultaneously, we will proactively report the handling of the personal information security incident to the relevant supervisory authorities as required.

5.4 Special Note

The internet is not an absolutely secure environment. We strongly advise you to use secure methods and complex passwords to help us ensure the security of your account. If you discover that your personal information has been compromised, especially if your account or password has been leaked, please contact us immediately using the methods provided in the "Contact Us" section so that we can take appropriate measures.

We also ask for your understanding that, due to technological limitations and the potential existence of various malicious means, it is impossible to guarantee 100% security of information in the internet environment, even after we have done everything in our power to enhance security measures. We will strive to ensure the security of the personal information you provide to us.

5.5 Privacy Protection Philosophy and Implementation Oversight

We have embedded privacy protection principles into our product design in accordance with industry best practices. Specifically, we have appointed Privacy Compliance Officers who are integrated into business lines to ensure that privacy protection is incorporated into every stage—including business planning and design, product or system development, design, and verification—with these requirements managed digitally.

We have also established a "Three Lines of Defense" model, comprising self-inspections by business units, audits conducted by a dedicated privacy compliance team, and internal and external audits, creating a closed-loop management system for measurement, inspection, and auditing.