v.1

2024/01

"POMO NETWORK" is the application operated and managed by the Taiwanese company POMO Network INC. (hereinafter referred to as "the Company"). The Company places great importance on the privacy rights and data security of each user (hereinafter referred to as "you" or "user"). In accordance with the Personal Data Protection Act of the Republic of China (Taiwan) and this Privacy Policy (hereinafter referred to as "this Policy"), the Company collects, processes, and uses your personal data (referring to all information related to you that can be used to identify your individual identity, including but not limited to transaction data and other relevant information). Before using the service, please be sure to carefully read this Policy.

  1. Scope of Application
    1. This Policy applies to the personal data involved when you use this service or other applications integrated with or running concurrently with this service.
    2. For any independent websites or applications operated and managed by third parties that are linked through this service, the collection, processing, utilization, and protection of personal data are subject to the privacy policies of the third party or the respective website or application. The Company assumes no joint responsibility in this regard.
  2. Purpose of the Personal Data Collection
    1. For the purpose of providing this service, customer service, and customer management, the Company collects your personal data. The personal information you provide will be used for providing you with this service, contacting you, and conducting market research and analysis, among other purposes.
    2. The legal identification numbers of the specific purpose mentioned above, including the followings: 040 Marketing (including financial cross-selling business), 081 Legal transaction business for personal data, 090 Consumer, Customer Management and Service, 091 Consumer Protection, 098 Business and Technical Information, 135 Information (Communication) Services, 136 Information (Communication) and database Management, 148 Internet shopping and other electronic commerce services, 152 Advertisement or commercial behavior administration, 157 Investigation, statistics and research analysis, 176 Other natural persons based on the legitimacy of the purpose of the processing and use of personal information collected, 181 Other business operation in accordance with the business registration project or organization Prospectus, 182 Other Consulting and Consultant Services.
  3. Categories of Personal Data Collection
    1. The personal data collected by the Company includes the following scope:
      1. Information voluntarily provided by you that can identify you personally, such as: name, ID number, address, phone number, and account information for online platform applications.
      2. Financial information that can identify your financial status, such as: financial institution account numbers and names, credit card or debit card numbers, etc.
      3. Descriptive information about you, such as: age, gender, date of birth, etc.
      4. Your financial details, such as: payment methods, etc.
      5. Other technical data generated by your registration or use of the Company's products or services, such as: IP address, login times, product or service consumption records, etc.
    2. The categories of the aforementioned data, including legal identification numbers, are as follows: C001 Type for identifying individuals, C002 Type for identifying finance, C003 Type for identifying in government data, C011 Individual description, C021 Family, C032 Properties, C036 Lifestyles, C093 Financial deals, C102 Agreement or contract.
  4. Collection Methods of Personal Data

While providing services to you in the Republic of China (Taiwan), the Company collects your personal data through the following methods during its operational period:

  1. When you directly register as a user on this service, the Company obtains your phone number. If you connect to this service through third-party website accounts (such as Facebook, Google, LINE, Twitter), you agree that the Company collects your identity and other information on third-party website accounts, as well as information related to your social network.

  2. When you use this service, the Company automatically records relevant information about the device, browser, and applications (Apps) you use (advertising identifiers used to identify devices/browsers, browsing information obtained using Cookie or web beacon technology, device type, operating system, language/time zone settings, browser type, application version, etc.), as well as network information (telecommunication operator name, IP address, etc.), and location information. The use of Cookies is for tracking your activities on this service to facilitate various analyses and data collection by the Company. You can decide whether to allow the use of Cookie technology by configuring your computer, mobile device, or other internet devices. However, if you choose to disable Cookies, it may cause inconvenience or restrict certain functions when using this service.

  3. When you use this service, provide feedback, or participate in marketing activities and advertising programs offered by the Company, the Company will collect relevant personal data based on your actions. This includes but is not limited to communication addresses, contact phone numbers, ad-click records, and transaction records of products in marketing activities.

  4. Duration, Region, Recipients, and Methods of Personal Data Utilization:

    1. Duration of Utilization:

      The period during which the Company collects, processes, and uses personal data is determined based on relevant regulations (such as tax laws, commercial accounting laws, etc.), data retention periods stipulated by law, the necessary retention period for the Company's business operations, and the date you request to stop using the service account. The longer of these periods shall prevail.

    2. Region of Utilization:

      The Company limits the collection, processing, and utilization of personal data to within the territory of the Republic of China (Taiwan).

    3. Methods of Utilization:

      The personal data you provide will be processed digitally for purposes such as identity verification for using the Company's services, issuing Pomo Tokens, and analyzing consumption data. Within the scope of the collection purpose, your personal data will be processed and used. In addition, the Company will provide your personal data and your consumption records to the cooperative brands for marketing analysis and customer management.

    4. Recipients of Utilization:

      The Company will not arbitrarily transfer your personal data to unrelated third parties or use it for other purposes. However, for the purpose of fulfilling the service and related obligations, the Company may provide your personal data to its affiliated companies, partners (including but not limited to collaborative brand partners of POMO NETWORK), relevant outsourced cooperating companies (including but not limited to providers of financial services and logistics services), and government agencies.

    The Company may also share aggregated non-personal data with third parties. "Aggregated non-personal data" refers to data about your personal information that has been grouped, collected, and rearranged, and no longer reflects or points to a specific, identifiable individual after processing.

  5. Right to Personal Data Autonomy

    1. Without violating relevant laws, once the Company confirms that the personal data belongs to you, you may contact the Company to exercise the following rights: (1) inquire, view, supplement, or correct personal data; (2) cease the collection, processing, or utilization of personal data; (3) delete personal data; (4) obtain a copy of personal data; or (5) stop receiving related advertisements/marketing activities. However, when you request a copy, the Company may charge necessary costs depending on the situation.
    2. If you are a "citizen or resident of the European Union, European Economic Area, or the United Kingdom," you can request the Company, in accordance with the General Data Protection Regulation (GDPR), to delete or modify the personal data already accessed (including incorrect, expired, or unnecessary personal data). You may also request the Company to transfer your personal data to another company or withdraw your consent for the Company to collect, process, or utilize your personal data at any time. If you want to learn more about data protection and personal data rights for "citizens or residents of the European Union, European Economic Area, or the United Kingdom," please refer to the websites of the European Data Protection Supervisor: https://edps.europa.eu/data-protection/ or the Information Commissioner's Office in the UK: https://ico.org.uk https://ico.org.uk.

  6. Security Protection of Personal Data

    1. This service is equipped with various information security devices, such as firewalls and antivirus systems, as well as necessary security measures and risk management mechanisms. Strict measures are taken to protect your personal data, and designated personnel are responsible for overseeing information security implementation.
    2. For Company employees who require access to your personal data, specific usage permissions are set with confidentiality obligations to ensure maximum protection of your personal data.
    3. In cases where it is necessary to entrust other vendors to jointly provide this service, the Company will strictly require them to comply with confidentiality obligations. When outsourcing vendors assist in collecting, processing, and utilizing your personal data, the Company will fulfill its responsibility for supervision and management.
    4. Despite the Company's best efforts to protect your personal data, it cannot guarantee that personal data will be 100% immune from illegal interception, transmission, or intrusion by third parties. In the event of such incidents, the Company will promptly notify you and initiate relevant contingency measures and evidence preservation.
    5. Please safeguard your personal data, account, and password to prevent unauthorized access. If you discover unauthorized use of your account or any other security issues, please notify the Company immediately.
    6. The Company will not disclose any of your personal data to third parties without your consent, except in the following circumstances:
      • In response to formal requests from courts, public prosecutors, police agencies, or legal requirements, the Company may provide necessary personal data content to relevant government authorities.
      • As explicitly provided by law.
      • To prevent imminent danger to your life, body, freedom, or property.
      • Cooperating with public authorities or academic research institutions for statistical or academic research based on public interest, and the data has been processed or collected in a way that cannot identify specific individuals according to the disclosure method of the provider.
      • Necessary for identification, contact, or legal action when you may harm or hinder the rights of others or cause harm to any person.
      • In the interest of your rights.
      • In the event of the Company being merged or assets being acquired by another third party, resulting in a transfer of operational control, relevant details will be announced. All or part of your information owned by the Company may also be transferred to a third party under conditions of operational control transfer, but the third party will continue to abide by the relevant regulations of this Policy regarding personal data.
      • When linking to third-party independently operated websites or applications through this service, if you agree to the third party collecting, processing, or utilizing your personal data, the protection of personal data is subject to the privacy policy of the third party, and the Company assumes no joint obligation.

  7. Revision and Effectiveness of this Policy

    1. The Company will periodically update this Policy in accordance with legal requirements and the development of its business, and will announce changes promptly. If you do not agree with any terms of this Policy or the content of any modifications, please cease using the service immediately.
    2. If you have any questions regarding this Policy or wish to exercise your rights related to personal data, please contact the Company's customer service team at: [email protected]

  8. Governing Law & Jurisdiction

    1. This Policy shall be interpreted and supplemented by the Taiwanese law.
    2. All disputes arising under this Policy shall be submitted to the Taipei District Court in Taiwan as the court of first-instance jurisdiction.