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.

(1) 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 laws 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 provides protection equivalent to this Policy.

(2) 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 agreements signed with you 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 holding your information to continue to be bound by this Policy. Otherwise, we will require them to obtain your consent again.

(3) Public Disclosure

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

1. With your explicit consent;

2. When required by law, 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 matters related to user personal information involved in our products and services, planning and formulating company policies, reviewing user agreements for our products, and supervising the operating principles and information processing mechanisms of our products.

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

3. We encrypt identifiable sensitive personal information during transmission and storage. The encryption strength complies with security requirements to ensure data confidentiality. Our application systems provide functions such as identity authentication, unique user identification verification, and role-based access control. We use the HTTPS security protocol for communication, set limits on maximum concurrent session connections, and can detect and generate alerts when system service levels fall below predefined minimum thresholds. We deploy access control mechanisms on our servers, apply the principle of least privilege to employees who may access your personal information, and regularly review authorized personnel lists and access records. Our server operating systems and database systems require strong passwords. We use the SSH protocol for remote management, strictly restrict default account permissions, change default passwords, and maintain comprehensive audit logs covering all users.

4. The server systems storing users' personal information run on security-hardened operating systems. We conduct account audits and monitoring of server operations. If security vulnerabilities are publicly announced for any server operating systems we use, we will promptly upgrade server security to ensure the safety of all server systems and applications.

5. We regularly provide our employees with training 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 implementation. We conduct annual training and emergency response drills based on this plan. If our physical, technical, or administrative safeguards are compromised, we will promptly activate our emergency response procedures to prevent the incident from escalating, report the incident to competent authorities as required by applicable laws and regulations, and notify you of the basic details of the incident, potential impacts, measures already taken, and planned measures through reasonable and effective methods such as push notifications or public announcements.

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

(1) Accessing and Correcting Your Personal Information

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

(2) Deleting Your Personal Information

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

1. We collected your personal information without your consent in violation of applicable laws.

2. Our processing of your personal information violates applicable laws and regulations.

3. We use or process your personal information in breach of our agreement with you.

4. You no longer use our products or services.

5. We stop providing services to you.

(3) Withdrawing Your Consent

Each business function requires certain basic personal information to operate. You may grant or withdraw your consent for the collection and use of additional personal information at any time. Your withdrawal of consent does not affect any processing activities carried out before the withdrawal, but we will no longer process your personal information after your withdrawal.

(4) Account Cancellation

You may cancel your registered account at any time.

(5) Obtaining a Copy of Your Personal Information

Where technically feasible, such as when compatible data interfaces are available, we may transfer a copy of your personal information directly to a third party designated by you upon your request.

Our official website, products, and services are intended for adults only. We do not intentionally or actively collect personal information from minors.

If you are under 18 years old, please do not use our website, services, or provide any personal information to us.

If parents or other guardians, due to lack of supervision or by explicitly allowing minors to use our services, permit minors to use our website or related functions, such use will be deemed as the parent or guardian's consent to this Policy on behalf of the minor.

If we discover that we have collected personal information from a minor without obtaining verifiable consent from their parent or guardian in advance, we will take reasonable steps to delete such information as soon as possible.

We may update this Personal Information Protection Policy from time to time. We will not restrict your rights under this Policy without your explicit consent.

For material changes to this Policy, we will provide prominent notice. You may also visit our official website at any time to view the latest version of this Policy.

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

1. Material changes to our service model, such as changes to the purposes of personal information processing, types of personal information processed, or methods of using personal information;

2. Material changes in our ownership or control, such as ownership changes resulting from mergers, acquisitions, or restructuring;

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

4. Significant changes to your rights regarding personal information processing and the ways in which you exercise those rights;

5. Changes to the responsible department handling personal information security, contact information, or complaint channels;

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

Your continued use of our website after such changes and amendments will be deemed as your acceptance of the updated Policy.

If you have any questions, comments, or suggestions regarding this Policy, or if you believe that we or our employees have violated this Policy, please contact us through the following methods:

Email: hello@westwell-lab.com

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