Privacy Policy

This Policy applies to the services we provide to you via our official website. Please note that this Policy does not apply to services provided to you by third parties, such as third-party websites linked through our official website. You acknowledge that these services are provided to you independently by third parties, and that such third parties are solely responsible for processing your personal information in accordance with their own policies or user agreements.

We may formulate specific personal information protection policies, statements, notices, etc. (hereinafter referred to as "Specific Policies") for particular online or offline services or products. If there is any conflict between any other Specific Policy and this Policy, the Specific Policy shall prevail. Matters not covered by that Specific Policy shall be governed by this Policy.

"Personal information" refers to any information, recorded electronically or otherwise, that relates to an identified or identifiable natural person. Anonymized information is not considered personal information. "Sensitive personal information" refers to personal information that, once leaked or illegally used, may easily harm an individual’s dignity, or endanger their personal or property safety. When you use our website, we collect only the personal information necessary to provide the services you request, as described below. If you choose not to use a particular feature, we will not collect the information associated with it.

1. Browsing the Official Website

When you browse our official website on a computer or mobile device, we will collect the following information from you:

a) Technical information, such as your Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technical data from the device you use to access our website.

b) Usage information, such as how you use our website, products, and services.

2. Business Cooperation

When you apply for business cooperation with us, we collect your name, title, email, phone number, country/region, industry, company name, and specific cooperation requirements — so we can understand your needs and get in touch.

3. Applying for Positions

To apply for a position, you’ll need to submit your resume and register with your mobile number. We need to collect your identity data provided in your resume, such as your name, date of birth, gender, education, work experience, and contact details to get a preliminary understanding of your qualifications.

We also collect aggregated data — such as statistical or structural data. Aggregated data may be derived from your personal information, but is not considered personal information, as it does not directly or indirectly reveal your identity. If we combine or link aggregated data with your personal information in a way that identifies you, we will treat the combined information as personal information and handle it in accordance with this Policy.

Depending on the type of personal information and how it is collected, we may use your personal information for the following purposes:

1. To create an account;

2. To process and respond to questions and comments from you or your organization;

3. To send you information about products, services, or promotions that may interest you or your organization — but only with your separate, explicit consent. You may withdraw your consent at any time, and we will stop sending you such information;

4. To seek information and feedback from you or your organization, such as through surveys or questionnaires;

5. To conduct data analysis and research to optimize our official website and services;

6. To ensure your security while using our website;

7. For other purposes with your consent;

8. To comply with applicable laws, regulations, or national standards.

Please understand that under the following circumstances, in accordance with laws and regulations, we do not need to obtain your authorized consent to process your personal information:

1. Necessary for the conclusion and performance of a contract to which you are a party;

2. Necessary for us to perform statutory duties or legal obligations — such as those directly related to national security and national defense, criminal investigation, prosecution, trial and execution of judgment;

3. Necessary to respond to public health emergencies or to protect the life, health, or property of individuals in emergencies;

4. Processing personal information within a reasonable scope for public interest activities, such as news reporting or public oversight;

5. Processing personal information that you have made public, or that has been otherwise lawfully disclosed (e.g., through legitimate news reports or government disclosures), within a reasonable scope;

6. Other circumstances provided for by laws and regulations.

To keep our official website running properly, we may store small data files called cookies on your computer or mobile device. Cookies typically contain identifiers, site names, and some numbers and characters. They allow our website to store data such as your preferences. We do not use cookies for any purpose other than those described in this Policy. You can manage or delete cookies based on your preferences. For more details, please visit AboutCookies.org. You can delete all cookies stored on your computer, and most browsers can be configured to block them. However, in that case, you will need to manually adjust your user settings each time you visit our official website.

In addition to cookies, our official website utilizes other similar tracking technologies, such as pixel tags and SDKs (Software Development Kits).

These technologies help us measure website traffic, understand where our visitors come from, and analyze how they use the site — such as click heatmaps and visit duration. This allows us to improve our content and user experience.

We use third-party analytics services (such as Baidu Analytics and Google Analytics) to help us understand how users interact with our website. These service providers may place cookies on your device and process your data in accordance with their own privacy policies.

We only receive aggregated and anonymized statistics that cannot directly identify you (such as your name or phone number). This information is used solely to understand your behavior on our website and does not track your activity on other websites.

Depending on which version of our website you visit and use and where you are accessing it from, we store your personal information as follows:

If you visit and use the official website intended for users within China, the personal information we collect and generate within the People's Republic of China will be stored within the country;

If you visit and use the official website intended for users outside of China, the relevant personal information will be stored on overseas servers.

We keep your personal information only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable laws and regulations. If we stop operating the official website and related services, we will immediately stop storing your personal information and will notify you of this change by posting an announcement. At the same time, the personal information we store is deleted or anonymized.

（一）Sharing

We do not share your personal information with any company, organization, or individual, except in the following cases:

1. With your explicit consent, we may share your information with other parties;

2. We may share your personal information with third parties when required by law and regulations, in connection with legal claims or disputes, or in response to lawful requests from administrative or judicial authorities;

3. We may share your personal information when it is necessary to prevent harm to the rights, property, or safety of Westwell, our affiliates, partners, users, or the public, to the extent permitted by law;

4. Sharing your personal information with our affiliates. To facilitate our provision of services to you, we may share your personal information with our affiliates. However, we will only share the information that is necessary. Any affiliate that receives your information must either follow this Policy or adhere to its own policy that: (i) you have authorized and agreed to; and (ii) provides a level of protection that is essentially the same as this Policy.

（二）Transfer

We will not transfer your personal information to any other company, organization, or individual, except in the following cases:

1. With your explicit prior consent or authorization;

2. When required by applicable laws, regulations, legal procedures, or mandatory administrative or judicial requests;

3. As required under an agreement signed with you (including electronic agreements signed online or platform rules) or other legal documents;

4. As our business develops, we and our affiliates may engage in mergers, acquisitions, asset transfers, or other similar transactions. If such transactions involve the transfer of your personal information, we will require the new entity (company, organization, or individual) holding your information to continue to be bound by this Policy. Otherwise, we will require them to obtain your consent again.

（三）Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

1. With your explicit consent;

2. When required by law — for example, if compelled by laws, legal proceedings, litigation, or mandatory requests from government authorities.

We attach great importance to the security of your personal information. We use industry-standard security measures to protect the information you provide — helping prevent your data from unauthorized access, public disclosure, use, modification, damage, or loss. We will take all reasonable and practicable steps to safeguard your personal information.

1. Westwell has appointed a dedicated Personal Information Protection Officer, responsible for handling user personal information matters related to our products and services, planning and formulating company policies, and reviewing user agreements of our products and overseeing their working principles and data processing mechanisms.

2. We have conducted grading assessments for information security level protection and, in compliance with its requirements, have formulated the overall guidelines and security policies for information security, established a security management system covering hosts, data, applications, and administrative processes, set up an Information Security Management Committee and an Information Security Executive Committee, designated the System Platform Department as the functional unit responsible for product security management, clarified the responsibilities, division of labor, and skill requirements of security-related departments and positions, and established clear policies for employee onboarding and offboarding.

3. We encrypt identifiable sensitive personal information during both transmission and storage, using encryption that meets security requirements to ensure confidentiality. Our application system supports identity authentication, unique user ID check, and role-based access control. It utilizes the HTTPS security protocol for communication, sets a limit on maximum concurrent session connections, and can detect and trigger alerts if the system service level falls below a predefined minimum. On the server side, we deploy access control mechanisms, apply the principle of least privilege to staff who may have access to your personal information, and regularly review the list of authorized personnel and access logs. Our server operating and database systems require strong passwords. We use the SSH protocol for remote management, strictly limit the access permissions of default accounts, change default passwords, and maintain comprehensive audit logs covering all users.

4 . The servers that store users' personal information run on security-hardened operating systems. We audit and monitor account activity on our servers. If a publicly announced security vulnerability is reported in any server operating system we use, we will upgrade server security in time to ensure the security of all our servers and applications.

5. We regularly organize training for our staff on laws and regulations related to personal information protection to strengthen their awareness of user privacy protection.

6. We have developed a cybersecurity incident response plan and allocated sufficient resources to ensure its execution. We conduct training and drills on the emergency response plan every year. If our physical, technical, or administrative safeguards are ever compromised, we will promptly activate our emergency response plan to prevent the incident from escalating, report to the competent authorities as required by laws and regulations, and notify you of the incident, its potential impact, and the measures we have taken or will take — through reasonable and effective means such as push notifications or public announcements.

While using our website, you can access and manage your personal information as described below:

（一）Accessing and Correcting Your Personal Information

You may contact us to access or correct your personal information.

（二）Deleting Your Personal Information

You have the right to request the deletion of your account registration information under the following circumstances:

1. We illegally collected your personal information without your consent.

2. Our processing of your personal information violates laws or regulations.

3. We use or process your information in a way that breaches our agreement with you.

4. You no longer use our products or services.

5. We will stop providing services to you.

（三）Withdrawing Your Consent

Each of our business functions requires certain basic personal information to operate. You may give or withdraw your consent for the collection and use of additional collected personal information at any time. Your withdrawal of consent does not affect our processing of your information before the withdrawal, but we will no longer process it afterward.

（四）Account Cancellation

You may cancel your registered account at any time.

（五）Obtaining a Copy of Your Personal Information

Where technically feasible — for example, when compatible data interfaces are in place — we can also transfer a copy of your personal information directly to a third party you designate, upon your request.

Our official website, products, and services are for adults only. We do not intentionally or actively collect personal information from minors. If you are under 18, please do not use our website, services, or provide any personal information to us. If parents or other guardians, through lack of supervision or by explicit permission, allow a minor to use our services, this will be deemed as the parent's or guardian‘s consent to this Policy on behalf of the minor. If we find that we have collected personal information from a minor without their parent’s consent, we will delete that information as quickly as possible.

We may update this personal information protection policy from time to time. We will not limit your rights under this policy without your explicit consent.

We will provide prominent notice of any material changes to this policy. You can also check our official website for the latest version at any time.

Material changes referred to in this Policy include, but are not limited to:

1. Material changes in our service model. For example, the purpose of processing personal information, the types of personal information processed, and the way personal information is used;

2. Material changes in our ownership or control — such as a merger, acquisition, or restructuring — that results in a change of ownership;

3. Changes in the main entities to which personal information is shared, transferred, or publicly disclosed;

4. Significant changes in your rights regarding personal information processing and how you exercise them;

5. Changes in our responsible department for handling personal information security, its contact details, or the complaint handling channel;

6. When the Personal Information Security Impact Assessment report indicates a high risk.

Your continued use of our website following such changes and amendments will be deemed as your consent to the changes and amendments to this Policy.

If you have any questions, comments, or suggestions regarding this Policy, or if you find that we or our staff have violated this Policy, please contact us in the following ways:

Email: hello@westwell-lab.com

Address: Building D, No.155 Wuyi Road, Changning District, Shanghai, Shanghai Westwell Technology Co., Ltd.