Program Overview

We welcome new and existing customers to join the Wagas Reward Program. WRP is our way of saying thank you to our loyal customers.

Registered members can earn WRP Points when purchasing full-priced products at participating Wagas, BAKER & SPICE, LOKAL and FUNK & KALE stores (excpet some airport stores) using Eligible Payment Methods. To earn WRP Points - register your WRP Account. To get your points, please scan the membership QR code on cashier and pay the bill. Points will automatically add into your account when using our Wolesong Platform to order. No points will be added when purchasing physical gift card, online gift card or topping up member e-wallet, points can only be added when using them. Please note, member points will not be permitted to add after any transactions.

All Member: Earn 1 point per every actual RMB spent.

Wagas reserves the right to remove points from your WRP Account if purchase that resulted in earning points is reversed for any reason, such as because of a dispute or a return of the purchased product.

The exclusive e-coupon for members will be pushed to the member account, you can order the products and tell the staff that you want to use the e-coupon, then finish the payment.

For the security of your WRP Account, each time you download e-coupons, please ensure that you are in a safe payment environment, you are solely responsible for the activity that occurs on your WRP Account. Please note that when you download e-coupons, for the ones requiring point redemption, WRP Points will be deducted immediately from your WRP Account and this action is irreversible. You are solely responsible for making sure that you read relevant e-coupon usage guidelines before downloading and use e-coupons before expiry. Points will not be refunded to you if the e-coupons remain unused pass expiry. In general, Membership Level e-coupons must be used within 30 days after downloading (or before promotion end date)( Please see the coupon for specific expiry date).

As described in more detail below, based on your Membership Level, you will be eligible to various e-coupons. The ability to download and use certain e-coupons is dependent on your current Membership Level. You may download a particular e-coupon multiple times depending on its usage guidelines. You may also use multiple e-coupons in one transaction as per usage guidelines. Points cannot be earned when using this e-coupon.

There are no membership fees associated with WRP. Points in your WRP Account are complimentary, have no cash value and will expire and be removed from your WRP Account one year after they are earned if not redeemed prior.

The points obtained during Jan.1 to Jun.30 of the year will expire on Jun.30 of the next year; Points earned during Jul.1 to Dec.31 of the year will expire on Dec.31 of the next year.

WRP has a constantly evolving list of member rewards. Wagas reserves the right to modify these member rewards at any time at its discretion and without obligation, except as described in the “Modification” section.

White Level

0-1,999 points

You automatically become a White Level member when you successfully register your WRP Account.

Orange Level

2,000-3,999 points

When you have earned at least 2,000 points (below 4,000) in your WRP Account within one Account Anniversary, you will have a complimentary upgrade from the White Level to the “Orange Level”.

Purple Level

4,000-7,999 points

When you have earned at least 4,000 points (below 8,000) in your WRP Account within one Account Anniversary, you will have a complimentary upgrade from the Orange Level to the “Purple Level”.

Silver Level

8,000-9,999 points

When you have earned at least 8,000 points (below 10,000) in your WRP Account within one Account Anniversary, you will have a complimentary upgrade from the Purple Level to the “Silver Level”.

Black Level

Above 10,000 points

When you have earned at least 10,000 points in your WRP Account within one Account Anniversary, you will have a complimentary upgrade from the Silver Level to the “Black Level”.

Membership Level Review

Each member will review the level on “Anniversary Review Date”.

1. White and orange level will remain the current level.

2. For purple level, if the new accumulated points reached 4,000 points or above in the last account anniversary, the purple level will be maintained; if not, it will be reduced to orange level.

3. For silver level, if the new accumulated points reached 8,000 points or above in the last account anniversary, the silver level will remain.; if not, it will be reduced to purple level.

4. For black level, if the new accumulated points reached 10,000 points or above in the last account anniversary, the level will remain black; if not, it will be reduced to silver level.

Modification

Wagas reserves the right to modify these terms and conditions at any time at its discretion and without obligation, except as described in this “Modification” section. Wagas will provide reasonable advance notice by posting a notice on on www.wagas.com.cn pri prior to modifying these terms and conditions, unless Wagas is unable to provide advance notice in order to comply with an applicable law, rule or regulation. It is your responsibility to review www.wagas.com.cn regularly for any changes to these terms and conditions.

If you use your My Virtual Card after the effective date of the modification stated in the notice that Wagas posts or sends by SMS, your first use of the My Virtual Card after that effective date will be your agreement to the modification. If you do not agree to a modification in such notice, you should use your e-coupons before the earlier of their expiration date or the effective date of the modification stated in the notice. Then you should stop using your My Virtual Card.

You should use your e-coupons before their expiration date. Please note that you cannot enjoy the benefits of your e-coupons without using the Wagas Reward Program.

Termination

Wagas reserves the right to terminate the Wagas Reward Program (either nationwide or in one or more cities within China) and/or these terms and conditions at any time at its discretion and without obligation, except as described in this “Termination” section. Wagas will provide reasonable advance notice by posting a notice on on www.wagas.com terminating the Wagas Reward Program, unless Wagas is unable to provide advance notice in order to comply with any applicable law, rule or regulation. It is your responsibility to review www.wagas.com.cn regularly to see whether the Wagas Reward Program has been or will be terminated.

Wagas may also terminate your WRP Account if you fail to comply with your obligations under these terms and conditions or you use your WRP Account in a manner that violates any applicable law, rule or regulation.If Wagas terminates your WRP Account, you will no longer have anypoints or e-coupons in your WRP Account or to be able to use your WRP Account. Since all benefits are complimentary, you will not be entitled to any refund in connection with any points or e-coupons.

Consent to Contact

Note that, by clicking “Submit” below, you are agreeing that Wagas, its affiliates or vendors may from time to time send you WRP Communications. If you do not wish to receive WRP Communications, you should not click “Submit”. Your agreement to receive WRP Communications does not limit any of the types or purposes of contact that you have consented to through the Terms of Use and/or Privacy Policy.

Governing Law, Dispute Resolution

Any dispute arising from or in connection with the Wagas Reward Program shall be submitted to Shanghai International Economic and Trade Arbitration Commission for arbitration.

Definitions

“Account Anniversary” means, for the WRP Account you create, each 12-month anniversary of the date when your 1st post-registration in store purchase occurred.

“China” means, for purposes of these terms and conditions, the People’s Republic of China, excluding Hong Kong, Macau and Taiwan.

“Eligible Payment Methods” means cash, bank debit cards, bank credit cards, personal checks, and such other payment methods as Wagas may designate from time to time as being eligible to result in the recording of purchases to WRP Accounts. “Eligible Payment Method” will not include redemption of e-coupons, physical coupons, prepaid cards, gift cards, gift certificates, in-kind exchanges, use of a credit issued to resolve a dispute or for any other reason, or any other payment methods (including those listed in the preceding sentence) that Wagas may designate from time to time as not being eligible to result in the recording of purchases to WRP Accounts.

“WRP Account” means a Wagas Reward Program Account.

“My Virtual Card” means the QR code on ‘my virtual card’ page, refreshed when placing your order, the screenshot is invalid.

“WRP Communications” means communications by e-mail, mail to your mailing address, telephone or mobile phone by WRP, its affiliates or vendors:

(i) contemplated by the terms and conditions (including the benefits described above);

(ii) related to your WRP Account and/or the Wagas Reward Program;

or (iii) targeted exclusively to some or all of the customers with WRP Accounts.

“Purchase” means a purchase of full-priced Wagas, BAKER & SPICE, LOKAL and FUNK & KALE goods in the amount of at least 1 Chinese Yuan using Eligible Payment Methods at participating stores in China.

“Terms of Use and/or Privacy Policy” means those terms of use and/or privacy policy that govern wagas.com.cn.

Wagas Privacy Policy

At Wagas, we strive to do everything we can to respect the trust customers have in our brand our commitment to your privacy is no exception. We are committed to protecting and safeguarding consumer privacy.

The information covered by the Policy includes, but not limited to, the personal information collected through the services available on our website located at www.wagas.com.cn, and the Wagas Reward Program, the personal information collected from the communication and exchange platform built on the application of network and mobile technology (e.g. social media).

1. Types of Information We Collect and How It Is Used

Wagas only gathers personal information, such as, first and last names, phone numbers and birthdays, when voluntarily submitted by you.

2. Sharing of Personal Information

Wagas may share personal information within the Wagas Family. The Wagas Family includesWagas and our affiliates. Any use of this information by the Wagas Family will comply with this Policy.

3. Security of Personal Information

Wagas takes proper administrative measures and technical means to protect the security of your personal information and prevent them from unauthorized search, disclosure and loss, leakage, damage and distortion. Wagas, the Wagas Family member, employees of Wagas Family, business partners of Wagas and all third parties who are permitted to collect your personal information pursuant to this Policy, are required to comply with the duty of confidentiality.

4. Changes to our Privacy Policy

This privacy policy is effective as of May 2015. From time to time, it may be necessary for Wagas to change this privacy policy. We suggest that you check periodically for the most up-to-date version of our privacy policy. The Chinese version of this Policy shall prevail in case of any discrepancies between the Chinese and English versions.

Effective Date: [Aug,1,2019]

Chapter references

This Policy sets out:

I. How we collect and use your personal information by wagas

II. How we apply Cookie technology or Beacon technology by wagas

III. How we store and protect your personal information by wagas

IV. How we entrust, share, transfer and disclose your personal information

V. How to access to and control your personal information

VI. Statement of liabilities to third parties

VII. Security

VIII. Liability

IX. Special provision on right to privacy of minors

X. Cross-border transfer of personal information

XI. Scope of and amendments to this Policy

XII. Severability

XIII. Definitions of keywords in this Policy

We, Wagas Group. (Hereinafter referred to as “we”, “our” or “wagas”) respect and protect your privacy. wagas acts as the controller of your personal data which it will obtain directly from you as the data subject, and has implemented numerous technical and organizational measures intended to ensure the most complete protection of personal data processed through our website, products and services. This Policy explains the way wagas collects, uses and stores your personal information and what rights you have under wagas Privacy Policy (Hereinafter referred to as “This Policy”), when you browse our website or use our products and services. wagas shall strictly follow this Policy. Wagas hereby undertakes to you as set out below in this Policy. If you would like to have more detailed information, please refer to the corresponding chapters in accordance with the index above.

1. We explain the type and usage of your personal information in order to help you understand the type, reason to use and collection mode of specific personal information, which is collected by certain products, services or functions of Wagas.

2. Sometime when using certain wagas functions, we will collect some sensitive information upon the receipt of your express authorization, unless such collection is mandatory pursuant to applicable laws (Hereinafter referred to as “Laws”). If you refuse to provide such information, you may be blocked from these functions but generally this should not affect your access to the core functions of products and services offered by wagas.

3. wagas generally will not share or transfer your personal information to any third parties unless otherwise expressly stated in this Policy or required or permitted by the Laws. If sharing or transferring information is necessary, we will explain reasons and obtain your express consent, including through this Policy.

4. You may access, correct or delete your personal information, or withdraw previous consent, cancel your account, file complaints or reports or apply privacy setting to control your personal information.

Understanding this Policy is necessary to use the products and services of wagas. We recommend that you carefully read and understand the full content of this Policy so that you may make relevant choices as you deem appropriate. We have tried to use plain and concise languages and to mark clauses that could materially affect your rights and interests in bold, to bring them to your attention.

If you have any questions, complaints or comments related to this Policy, please contact [www.wagas.com.cn], our data protection specialist will respond to your needs in a timely manner. We are really glad to directly deal with your requests and fulfill your needs.

By clicking on the “I agree” button, you are acknowledging that you have carefully read, understand and agree with this Policy. If you do not agree with this Policy, please refrain from using our website and complete the registration of wagas website and products and services, including after having been informed of any change to these conditions, means that you have accepted and agreed with the Policy, and any revisions made. We undertake to comply with applicable laws data protection laws of the place in which you reside) to protect your personal privacy and data security. We also ensure that all of our staff will perform the above mentioned obligations. The purpose of collecting, storing, using and sharing your information is to offer you better services and improve the quality of our products. (e.g. to support the development of new products and function upgrades of existing products in order to provide you high-quality and suitable services). You are not required to provide us any personal information but if you voluntarily share your information listed in this Policy as we requested, you may enjoy better and more convenient services, faster responses and avoid any adverse consequences.

I. How we collect and use your personal information by wagas

(i) Information Type, Collection Mode and Purpose

1. Information provided during the registration procedure of your Wagas account. When you register wagas account, or use products and services of wagas through your account, we will collect and store your personal information, including your email address, username and password, nickname and portrait (possibly obtained througha third-party software), shipping address, billing address and telephone number, etc. By agreeing to this Policy and providing your information, you are warranting that the personal data you have provided is complete and accurate. You understand and agree that we can use such information to provide products and services to you, process orders and arrange shipment, and offer customer service and communicate with you directly, e.g. to send you emails of new product introductions, account verifications, order confirmations, important changes and updates of service functions, and notices regarding technology and safety, etc. You may refuse to receive such emails or notification by changing your email personal preference settings. Also, you have the right to object to data processing merely for the purposes of direct marketing (i.e. profiling to the extent that it is elated to such direct marketing), at any time and free of charge by contacting 【www.wagas.com.cn】

Moreover, we may collect other information of you for the purpose of providing services to you or improving service quality, e.g. to collect relevant information provided when our customer service team contact you, or your survey responses return to us, etc. If you refuse to provide such information, it may affect the quality of our services but you should still be able to use basic functions of services delivered by wagas.

Providing your personal data to wagas means that you:

i. declare that you are fully informed about this Policy and that you fully accept this Policy without any reservation; and

ii. give your free, specific, informed and unambiguous consent to wagas to process or have processed your personal data in accordance with this Policy and the Privacy Legislation applicable at each jurisdiction.

As a consequence, you expressly grant wagas permission to use your personal data to accomplish the purposes set out under the Policy.

This Policy is not necessarily applicable to services, activities or products of third parties to which you may be referred and on which a different privacy policy might apply.

Information collected by our registered robots. If you use our applications to register online and pair with robots, we will collect the information of your location and terminal devices (including the device ID, serial number or product code, or IP address, etc.). Under special circumstances such as where faults of robots are reported, we will collect the abstract layout of cleaned areas to help you tackle problems including to recovery from the reported technical failures or faults.

2. Information collected from our website and mobile application. To maintain the quality of our services and the safety of your information, when you visit the website or mobile application of wagas and use the services provided by wagas, we may record types and modes of services, the operation information during your services and any other log information in connection with your services including your IP address, system version, IMEI and MEID of your mobile device, and your location.

When using these general data and information, wagas does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisements, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, wagas analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process.

You understand and agree that we can provide your personal information to the competent regulatory agencies pursuant to the laws and regulations,the guidelines, the court orders or any other provisions of legal proceedings, or mandatory requirements imposed by administrative or judicial bodies (Hereinafter referred to as “Laws, etc.”) without your authorization or consent.

II. How we apply Cookie technology or Beacon technology by wagas

1. How we apply Cookie technology to automatically collect information. To facilitate your browse activity, when you access to the website or services of wagas, we may identify you through small data files, which may assist you in skipping the repeat input of your information or help determine the safety of your account. This data may include Cookies, Flash Cookies, or other local stored data provided by your web browser or related applications (Collectively referred as “Cookie”). Our system may automatically collect the following information from you through Cookie:

 Information of your device or software, e.g. configuration information of your mobile device, web browser and any other applications connected to our services, your IP address, system version and IMEI of your mobile device;

 Information searched or browsed in the course of our services, e.g. search words on the webpage, URL addresses entered and any other information or details browsed or provided when using our services.

2. How we apply Beacon technology to automatically collect information. To further understand your preferences on our products and services, and improve our services, our website may also insert some digital images (namely “single-pixel GIF file” or “Web Beacon”), in order to collect information related to your web search activities, including webpage addresses you access to and cited webpage you previous visited, your browsing environments and display settings.

3. Our products and services may contain third parties’ Cookies or Beacon. Our products and services may have imported Cookies and Beacon placed by advertisers or other partners. These Cookies and Beacons may collect non-personal information from you to analyze your usage of services, send advertisements you may be interested in or assess the effects of advertisements. Cookies and Beacons applied by third parties for collecting and using such information are not bound by this Policy but only subject to their own privacy policies. Therefore, we shall not be liable for Cookies or Beacons used by third parties.

4. How to refuse to apply Cookie technology or Beacon technology. You can refuse to or manage Cookies or Beacon through your web browser settings. However, please note that if you disable Cookies or Beacons, you may not enjoy the best service and certain services may also be unavailable to you.

III. How we store and protect your personal information by wagas

1. Location for storing your information. The headquarter of wagas is based in People's Republic of China. Personal information collected and generated in the jurisdiction in which you reside in the course of providing products and services to you will be stored in servers of wagas located in European Union. Further, we will only store your personal information during the period required for the purpose of this Policy or required or permitted by the applicable Laws, etc.

2. Management and policies concerning data security. We undertake to maintain information safety to the level as specified by the Law, etc. In order to keep your information safe, we commit to apply various safety technologies and associated management systems to protect your information from being disclosed, destroyed or lost. We have a personal information protection department. We have also developed a relevant internal control policy, where we seek to only give employees who may access to your information, the least authority and limited information access, sufficient for fulfilling their duties. We have further established access procedures and approval mechanisms to strictly control data.

3. Reporting mechanism for personal information safety accidents. Please understand that due to the limitation of technologies or potential malicious attacks, personal information safety accidents may unfortunately occur due to factors beyond our control. If a safety accident occurs, if required according to the Laws, etc., we will immediately notify you of: general facts and potential influences of the safety accident, measures we have adopted or will adopt, advice for you to protect your information and reduce risks as well as remedial measures, etc. We will inform you of the relevant facts of the accident by email, letter and telephone or by push notifications. If we cannot contact you individually, we will publish notifications in a reasonable and effective manner. We will also report the result of personal information safety accident to regulatory departments if required.

4. Delete your information. If we stop the provision of services or business operation, or your personal information become unnecessary to achieve the above purpose, we will promptly cease to continuously collect your personal information and may give notice to you individually or by publishing notifications. We will also delete or de-identify your personal information possessed by us without delay.

IV. How we entrust, share, transfer and disclose your personal information

(i) Delegation of data processing

If it is necessary for providing you better or satisfactory products or services, we may engage third-party service providers located your jurisdiction to analyze or process your personal information. Unless otherwise expressly stated in this Policy, we shall not engage third-party service providers located outside your jurisdiction without your prior express authorization or consent. The above third-party service providers will analyze or process your information on behalf of wagas.

Our third-party service providers such as Google Analytics, Umeng, Zendesk, etc. may collect your IP address, visited web pages, app’s statistical data, customer consultation or feedback records, and other related information for purpose of fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, pushing personalized advertising, and conducting customer research or satisfaction surveys, etc.

wagas also ensures that we will comply with the following requirements when delegating such third parties to process your personal information:

1. wagas will not analyze or process information beyond the scope authorized by you;

2. wagas will make prior assessment on whether third-party service providers are qualified to maintain data security, in order to make sure they are eligible according to the Laws, etc.

3. wagas will require the third-party service providers to comply with the applicable obligations by contract scheme, to follow all of the applicable Laws, regulations, industry rules and standards, business norms and practices of the jurisdiction in which you reside, and to be subject to obligations hereunder with the same or comparable standard adopted by wagas to protect your information.

4. wagas will accurately record and regularly audit the activities of the delegated third parties to process personal information in order to protect information safety and ensure your effective access to and control over your information.

5. wagas shall ask third-party service providers to delete your personal information and destroy all data copies upon the termination of the principal-agent relationship.

6. If wagas engages the third-party service providers located outside your jurisdiction, we will accurately keep the records of providing of your personal information, including but not limited to the date, scale, type, item identifying the individual, purpose of providing your information, and basic information of the third-party service providers, in order to help you to learn the storage and usage of your information by the third-party service providers.

(ii) Data sharing and transferring

In principle, we will not share or transfer your personal information to any third party companies, organizations and individuals. In the following exceptional circumstances, we will share your personal information for legal, reasonable and necessary purposes. Third parties receiving such data have no right to share and transfer personal information for any other usage that you are not advised of by this Policy.

1. Sharing information is necessary for providing products and services to you and upon your prior express authorization or consent

You understand and agree that if it is necessary to provide you better or satisfactory services, wagas may share your personal information with its affiliates or any other third-party service providers upon your prior express authorization or consent. These affiliates or third-party service providers may be located outside your jurisdiction. As for the cross-border transfer of your personal information, please refer to Chapter VIII of this Policy. For instance, when you purchase products through the website of wagas, we may share the information of your transactions with banks or the counterparty of your transactions to prove the authenticity of the transactions and protect your lawful rights and interests. Meanwhile, we must share the information of your address with shipping service providers for arranging the delivery of our products.

wagas ensures that we will comply with the following requirements when sharing your personal information with the above third parties:

1) wagas will conduct prior assessment of impacts on personal information safety and adopt effective measures to protect your personal information based on the result of the assessment.

2) wagas will accurately keep the records of sharing or transferring your personal information, including but not limited to the date, scale, purpose of sharing and transferring your information, and basic information of data receiving parties, in order to help you to learn about storage and usage of your information by the receiving parties.

3) wagas will exert commercially reasonable efforts to cause third parties to follow all applicable laws and regulations as well as agreed confidentiality and safety measures when processing your personal information.

4) wagas will keep your information safe, and ensure effective access to and control over the information, e.g. access to, correct, delete and cancel the account, etc.

2. Transfer information when wagas has undergone acquisition, merger or reorganization

With the continuous development of our business, wagas may engage in transactions including mergers, acquisitions and assets transfers. We will notify you of relevant facts and continuously protect or cause data receiving parties to continuously protect your personal information pursuant to the Laws, etc. or, in each as ask required by laws and regulations and with no less than the standard under this Policy.

3. Share your personal information pursuant to the Laws, etc. and mandatory requirements imposed by regulatory agencies

We may provide your personal information to the competent regulatory agencies pursuant to the Laws, etc. the court orders or any other provisions of legal proceedings, or mandatory requirements imposed by administrative or judicial bodies. Information sharing under this circumstance may not require your prior authorization or consent.

Third parties to whom wagas may, or is obliged to, transfer personal data on the basis of the above, can be located in another country. wagas cannot be held responsible regarding the transfer of personal data and cannot be liable for the further processing of the personal data by third parties except to the extent required by applicable laws and regulations.

(Iii) Disclose

We will not disclose your personal information to the public. If disclosure is needed, we will notify you of the purpose of such disclosure, the type of information disclosed and the scope of any sensitive information involved. We will disclose information with your prior explicit consent (including through this Policy).

V. How to access to and control your personal information

1. How to access to or correct your personal information. You may log in your wagas account through the official website of wagas, click on “Account Management”, or sign in your account of the mobile application and click on “My Personal Information Management” to view or change your personal profile or make relevant privacy or safety settings.

2. How to refuse to receive promotion notifications. You may click on “unsubscribe” button in any emails sent by us to refuse to receive promotion notifications. Please note that you may not unsubscribe or refuse to receive any messages related to your account, e.g. account verifications, order confirmations, changes or updates of service functions, or notices regarding technology and safety, etc.

3. How to delete your personal information. If you find our collection and usage of your personal information are in violation of the Laws, etc,. or our mutual agreements, you may contact us at [www.wagas.com.cn] or talk to our online customer service staff, and ask them to delete your personal information collected through such acts.

4. How to correct your personal information. If you find the personal information we collected and stored has any errors, you may contact us at [www.wagas.com] or talk to our online customer service staff, and ask them to correct your information.

5. To ensure data security, we will need to verify your ID, evidence and materials before responding to your requests under the above Paragraph 3 or 4. We will complete the deletion or correction within five (5) business days after the verification; in special circumstances, we will respond to you within not more than thirty (30) days or any period specified by the Laws, etc., with reasonable explanations for the failure of prompt response. Furthermore, we will also notify third parties, who receive your information according to Chapter IV, to respond to your requests under Paragraph 3 or 4.

6. How to cancel your wagas account.

You may contact us at [www.wagas.com.cn] and apply for cancellation of your wagas account. Please note that we will delete or de-identify your personal information after the cancellation of your account.

7. Notwithstanding the foregoing, under the following circumstances, we may not respond to your request pursuant to laws and regulations:

1) Directly related to national security or national defence;

2) Directly related to public safety, public health or vital public interests;

3) Directly related to criminal investigation, prosecution, trial and execution;

4) We have sufficient evidence to prove that you conduct acts in bad faith or abuse your rights;

5) Responding your request will cause severe damages to your lawful rights and interests or those of any other individuals or organizations; or

6) Involving trade secrets.

VI. Statement of liabilities to third parties

Please note that third-party website operators you visit, third-party service access to through us and third parties receiving your personal information from wagas may have separate privacy policies. We encourage you to read and learn about their privacy policies published on their official websites. Please note that we are not directly involved in the abovementioned third parties’ data collection and use, therefore are not liable for this. The third parties’ data collection is bound by their own private policies. However, we will use commercially reasonable efforts to have these third parties adopt data protection measures on your personal information. However, we may not guarantee that they will 100% follow our requirements. You can opt out these third parties’ services, following the corresponding parts in their private policies if you wish them not to further collect or use your personal information.

VII. Security.

wagas commits to take (or have) all reasonable measures (taken) to its best ability to safeguard the protection of the personal data through technical safety measures and an appropriate safety policy for its employees. The personal data are stored with wagas, or, if applicable, with the processor of the personal data, on servers located in the United States. You acknowledge and accept that the transfer and storage of personal data is never without risk and consequently, the damage that you may suffer from the unlawful use of your personal data by third parties can never be collected from wagas.

VIII. Liability

wagas can solely be held accountable for damages which directly result from the processing of your personal data due to a fault or negligence of wagas. In any event, you agree that wagas cannot be held liable: (i) in circumstances of force majeure and/or (ii) for any indirect or consequential damage and/or (iii) for damages that result from errors, faults or negligence by you or third parties.

IX. Special provision on right to privacy of minors

We expect parents or guardians may instruct minors to use our services. If you are under 18 years old or you are a minor pursuant to the laws and regulations of the place in which you reside, we recommend you to ask your parents or guardians to read this Policy and use our services or provide your information to us with the prior consent from your parents or guardians. If your guardians do not allow you to use our services or provide your information to us according to this Policy, please stop using our services immediately and give a notice on time so that we can react accordingly. wagas will keep personal information of minors confidential and safe in accordance with the relevant laws and regulations of the state.

X. Cross-border transfer of personal information

In principle, the personal data as collected and produced during our provision of relevant products and services is stored in our servers located in European Union. Since we provide products or services based on our resources and servers worldwide, that being said, you understand and agree, your personal data might be transmitted to a jurisdiction or accessed from such jurisdiction outside of the country/region.

Such jurisdiction might have different data protection law. Under such circumstance, we will ensure that your personal data will be protected enough as that in the country/region where your products or services are located. For instance, we will ask you for your consent of cross-border transmission of personal information, and employ relevant security measures before transmitting data across border.

XI. Scope of and amendment to this Policy

This Policy applies to all customers and users of wagas products and services.

We may amend this Policy from time to time. If the clauses of this Policy are changed, we will show the amended privacy policy to you in the form of pushing notifications when you log in the account or update your products or services. Please note that we will collect, use and store your personal information pursuant to the updated privacy policy only after you click on the “Agree” button.

You may read this Policy at the bottom of the homepage in our official website. You may also find this Policy in the mobile application of wagas and read it under “Me - Setting - Privacy”. We encourage you check our privacy policy whenever you access to our services.

XII. Severability

If any provision in this privacy policy is deemed to be unlawful or unenforceable, that provision shall be amended by wagas and yourself insofar as necessary in order to make it lawful or enforceable, while retaining the meaning of wagas and yourself with respect to that provision as much as possible.

Whenever possible, the provisions of this Policy shall be interpreted in such a manner as to be valid and enforceable under the applicable law. However, if one or more provisions of this Policy are found to be invalid, illegal or unenforceable, in whole or in part, the remainder of that provision and of this Policy shall remain in full force and effect as if such invalid, illegal or unenforceable provision had never been contained herein.

XIII. Definitions of keywords in this Policy

“Affiliates of wagas” in this Policy refer to any companies, legal organizations and their lawful successors that are or will be controlled by one party, or one party is under the control of, or under the common control with Wagas Group related to the data collection, storation, processing.

“Data subject” is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

How to Contact Us

If you have any questions regarding our Privacy Policy, please contact us at:

member@wagas.com.cn

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