(A) This Notice

(B) Collection of Personal Data

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

• Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application or address book or contact list, audio recordings, your response to our surveys, your photographs or videos, or specific Personal Data you provided).
• Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visit from sales or marketing representatives, or at events we attend.
• Collaborations: We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
• App data: We collect or obtain Personal Data when you download or use any of our Apps.
• Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, Apps, products, or services.
• Content and advertising information: If you interact with any third party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

(C) Creation of Personal Data

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, Apps, products, or services, including where those data are collected from different devices.

(D) Categories of Personal Data we Process

We Process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name; and photograph(s).
• Demographic information: gender; date of birth / age; salutation; title; and language preferences.
• Contact details: correspondence address; shipping address; telephone number; email address; and social media details.
• Expertise: records of your expertise, professional history, practising details and qualification details, information about your experience, participation in meetings, seminars, advisory boards and conferences, information about your professional relationship with other individuals or institutions, language abilities and other professional skills;
• Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Purchase details: records of purchases and prices; shipping details; consignee name, address, contact telephone number and email address;
• Data relating to our Sites and Apps: device type; device hardware; device model; device resolution; operating system; browser type; browser settings; IP address; Internet Service Provider; mobile network carrier; language settings; dates and times of connecting to a Site or App; duration of usage of a Site or App; App usage statistics; App version; SR number (for App version); App settings; Firebase Cloud ID (FCM ID); advertising ID; clickstream data; referral URL; exit URL; other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information; and information about the way you use our Apps after you have installed and registered them (e.g. launch data, feature usage, page clicks, sign-in information, and feature vectors).
• Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

(E) Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases

• Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
• Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
• Establishment, exercise or defence of legal claims: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims; or
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

(F) Purposes of Processing and legal bases for Processing

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

(G) Disclosure of Personal Data to third parties

We disclose Personal Data to other entities within the Perfect Corp. group, for legitimate business purposes and the operation of our Sites, Apps, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:

• you and, where appropriate, your appointed representatives;
• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, consultants, lawyers and other outside professional advisors to Perfect Corp., subject to binding contractual obligations of confidentiality;
• third party Processors (such as payment services providers; shipping companies; etc., including Weibo, WeChat, and Shopify), located anywhere in the world, subject to the requirements noted below in this Section (G);
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. We request such third-party Processor to purge the Personal Data upon the termination of relationship and upon your request for deletion.

(H) International transfer of Personal Data

(I) Data security

(J) Data accuracy

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

(K) Data minimisation

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

(L) Data retention

(1) we will retain Personal Data in a form that permits identification only for as long as:

• we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or
• your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

plus:
(2) the duration of:

• any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and
• an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

and:
(3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

(M) Your legal rights

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, products, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(N) Terms of Use

All use of our Sites, Apps, products, or services is subject to our Terms of Service. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

(O) Direct marketing

(P) Details of Controllers

For the purposes of this Notice, the relevant Controllers are:

Alternatively, you may contact us using our online Contact Us page.

(Q) Analytics and Tailored Advertising

(R) Do Not Track

Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities. At this time, we do not respond to “do not track” signals. Consequently, third parties may indeed track and collect information about your online activities over time while navigating to, from and on our online Services, notwithstanding any “do not track” signals we may receive.

(S) California Consumer Privacy Act Disclosures

• Personal identifiers, including names, postal addresses, unique personal identifiers, IP addresses, and email addresses;
• Categories of personal information enumerated in Cal. Civ. Code § 1798.80(e), including telephone numbers;
• Protected classifications, including sex, gender, birthday, age, and national origin;
• Commercial information, including products or Services you have purchased, and your purchasing history;
• Internet or other electronic network activity information; and
• Biometric information (photos/videos if posted/videos on our Apps).

• Maintain or service customer accounts;
• Provide customer service;
• Process or fulfil orders and transactions;
• Verify customer information
• Provide advertising or marketing Services;
• Provide analytic services;
• Perform internal research for technological development;
• Ensure the quality and safety of services or devices;
• Improve the quality and safety of services or devices;
• Debugging to address impairments to operational functionality;
• Detect security incidents;
• Comply with applicable law and law enforcement requirements;
• Protect against malicious, deceptive, fraudulent or illegal activity;
• Prosecute those responsible for malicious, deceptive, fraudulent or illegal activity; and
• Defend against or bring legal action, claims and other liabilities.

• Data provided to us: We obtain Personal Information when it is provided to us (e.g., where you create an account, where you contact us via email or telephone, or by any other means, or when you upload photos and/or videos through our Apps, address book or contact list, audio recordings, your response to our surveys, or specific Personal Information you provided).
• Relationship data: We collect or obtain Personal Information in the ordinary course of our relationship with you (e.g., when you purchase any Products or Services from us).
• Data you make public: We collect or obtain Personal Information that you manifestly choose to make public, including via social media (e.g., hashtags, contents, communications, comments, photos, video, text, beauty products you tried on, beauty profile information, information on skin diary, acne detection data of your photos taken analysis of skin conditions and skin diagnostic results).
• App data: We collect or obtain Personal Information when you download or use any of our Apps.
  • -Device hardware.
  • -IP address.
  • -App version.
  • -Unique identifier for your device.
  • -Firebased Cloud ID (FCM ID), Advertising ID.
  • -Mobile network carrier, device model, locale, device resolution, and SR number (for App version).
• Site data: We collect or obtain Personal Information when you visit any of our Sites or use any features or resources available on or through a Site.
  • -(Date and time of the visit and duration of use of the Service.
  • -The IP of your device as well as your internet service provider.
  • -referral/exit URL.
  • -Clickstream data.
  • -Cookies and similar technologies.
  • -Information about your device including type of device, browser type and version, operating system.

• Registration details: We collect or obtain Personal Information when you use, or register to use, any of our Sites, Apps or services (e.g. your name, gender, date of birth, email address and password for creating your account, user name, postal address, telephone number, photograph posted/uploaded by you).
• Information about the way you use our Apps after you have installed and registered them (e.g. launch data, device data, feature usages, page clicks, sign-in information, and feature vectors)
• Content and advertising information: If you interact with any third party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Information from the relevant third party provider of that content or advertising.
• Third party information: We collect or obtain Personal Information from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

The purposes for which we disclose personal information are described in more detail in Section (G) above.

(T) Consumer Rights under the California Consumer Privacy Act

• The categories of Personal Information we collected about you.
• The purposes for which the categories of Personal Information collected about you will be used.
• The categories of sources for the Personal Information we collected about you.
• The categories of third parties with whom we share Personal Information.
• Our business or commercial purpose for collecting Personal Information.
• The specific pieces of Personal Information we collected about you.
• The categories of Personal Information we have disclosed for a business purpose.

Verifiable consumer requests to know may be submitted through one of the following methods:

• Call us toll free at (855) 650-0393
• Or by email at: [email protected]

Right to Request Deletion of Personal Information. Consumers have the right to request that we delete any Personal Information that we have collected from them. However, we are not required to comply with a request to delete where it is necessary for us to retain the Personal Information in order to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with legal obligations.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Verifiable consumer requests to delete may be submitted through one of the following methods:

• Call us toll free at (855) 650-0393
• Or by email at: [email protected]

The procedure and method of Personal Information destruction are as follows.

• Destruction procedure

You can delete or request to delete your Personal Information by managing your membership and click to delete your Personal Information. Once you click to delete your Personal Information, your Personal Information will be deleted and removed from the cloud storage permanently.

• How to destroy

Following by the aforementioned destruction procedure, we will confirm if your Personal Information has fully destroyed and removed from the cloud storage. We do not keep your Personal Information recorded and stored in paper documents or hardware devices.

Right to Non-Discrimination. Consumers have the right to be free from discrimination when they exercise their Consumer rights under the CCPA, and should you exercise those rights we cannot:

• Deny you goods or services.
• Charge you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level of quality of goods or services.
• Suggest that you may receive a different rate for goods or services or a difference level or quality of goods or services.

Authorized Agent. Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with a signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.

(U) California’s “Shine the Light” Law

Under California’s “Shine the Light” law, California residents are entitled to ask us for a notice describing what categories of personal customer information Perfect Corp. shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident, and would like a copy of this notice, please submit a written request to [email protected]

(V) Illinois Biometric Information Privacy Act (BIPA)

(W) Contact Us

If you have questions or concerns with respect to our Privacy Policy, you may contact us at [email protected]

(X) Definitions

• “App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
• “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
• “Biometric Information” includes both “biometric identifiers” and “biometric information” as defined in the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.
• “California Resident” means (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the state for a temporary or transitory purpose.
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• “EEA” means the European Economic Area.
• “GDPR” means the General Data Protection Regulation (EU) 2016/679.
• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:
  • Personal identifiers,
  • Categories of personal information described in Cal. Civ. Code § 1798.80(e);
  • Characteristics of protected classifications under California or federal law;
  • Commercial information;
  • Biometric information;
  • Internet or other electronic network activity information;
  • Geolocation data;
  • Audio, electronic, visual, thermal, olfactory, or similar information;
  • Professional or employment related information;
  • Education information; and
  • Inferences for use in creating a consumer profile.
• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• “Relevant Personal Data” means Personal Data in respect of which we are the Controller.
• “Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. A business does not sell personal information when:
  • A consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party, provided the third party does not also sell the personal information, unless that disclosure would be consistent with the provisions of this title. An intentional interaction occurs when the consumer intends to interact with the third party, via one or more deliberate interactions. Hovering over, muting, pausing, or closing a given piece of content does not constitute a consumer’s intent to interact with a third party;
  • The business uses or shares an identifier for a consumer who has opted out of the sale of the consumer’s personal information for the purposes of alerting third parties that the consumer has opted out of the sale of the consumer’s personal information;
  • The business uses or shares with a service provider personal information of a consumer that is necessary to perform a business purposes if both of the following conditions are met:
  • The business has provided notice that information being used or shared in its terms and conditions consistent with Section 1798.135 of the CCPA; and
  • The service provider does not further collect, sell, or use the personal information of the consumer except as necessary to perform the business purpose; or
  The business transfers to a third party the personal information of a consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business provided that information is used or shared consistently with Sections 1798.110 and 1798.115 of the CCPA.
• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
• “Services” means any and all services we provide, including (but not limited to) services relating to our Apps, Sites, products or services, and similar items from our licensors and other third parties.
• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
• “Site” means any website operated, or maintained, by us or on our behalf.

YOU UNDERSTAND AND AGREE THAT, BY ENTERING INTO THIS PRIVACY POLICY, YOU WAIVE THE RIGHT TO GO TO COURT OR TO PARTICIPATE IN A CLASS OR REPRESENTATIVE ACTION.