Huntwell Privacy Notice

(A) This Privacy Notice

This Privacy Notice was last updated on October 23, 2025.

This Privacy Notice is issued by each of the Controller entities listed in Section (M) below (together, “Huntwell”, “we”, “us” and “our”) and is addressed to individuals outside our organization with whom we interact, including customers, visitors and users of our websites, or our products or services (collectively, the “Platform”), personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (collectively, “you”). Defined terms used in this Privacy Notice are explained in Section (N) below.

Individual employees of existing or prospective customers and partners who leverage Huntwell’s solutions and services, or use the Huntwell website, may be provided with further privacy notices which may be contained in a separate supplemental notice. These additional privacy notices shall supplement this Privacy Notice.

This Privacy Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Privacy Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Privacy Notice.

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

(B) 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 that data is provided to us (e.g., when 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).
Data we obtain in person: We obtain Personal Data during meetings, at trade shows, during visits 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).
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, 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) or our advertising on third party sites, 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, products, or services, including where that data is collected from different devices or sources.

(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.
Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
Correspondence: records and copies of your correspondence if you contact us.
Professional details: your CV; records of your expertise; professional history; practicing 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.
Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
Visitor logs: records of visits to our premises.
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; and consignee name, address, contact telephone number and email address.
Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data; and other technical communications information (some of which may constitute Personal Data); registration details; username; password; security login details; usage data; and aggregate statistical information.
Data relating to body cameras and in-car video: video, audio, geolocation, live streaming, technical communications information; security login details; usage data; and aggregate statistical information.
Employer details: where you interact with us in your capacity as an employee of a third party; and 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 including on third party sites, records of advertising and content displayed on pages, App screens, or third party sites, 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.
Cookie data: we collect information via cookies and similar technologies. Please see our Cookie Policy for more details.
Security information: your password(s); login attempt details; security settings; and other security-related information.
Views and opinions: responses to surveys, responses to testing, 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);
Performance of a Legal Duty or Obligation: We may Process your Sensitive Personal Data where the Processing is necessary for a government agency to perform its statutory duties or for a non-government entity to fulfill its legal obligations (e.g., where necessary for the establishment, exercise, or defense of legal claims), provided appropriate security safeguards are in place;
Necessity for Statistical or Academic Research: We may Process your Sensitive Personal Data may de-identify and disclose your special categories of personal data where such disclosure is necessary for statistical or academic research purposes by a government agency or academic research institution for reasons related to medical care, public health, or crime prevention ;
Lawful Public Disclosure: We may process your special categories of personal data if you have personally made them public or if they have been made public through other lawful means; or
Obtaining Written Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your written 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).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

(F) Automatic Data Collection Technologies

As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies to provide you advertising based upon your browsing activities and interests. These third-party cookies and other technologies are governed by each third-party’s specific privacy policy. We and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Users can control the use of cookies at the individual browser level. We use cookies for the following purposes:

Strictly Necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart, or make use of e-billing services.
Analytical or Performance cookies. These cookies allow us to recognize and count the number of visitors to the Platform and monitor usage at a collective level.
Functionality cookies. These are used to recognize individual users and tailor the Platform to their preferences. For example, these cookies might be used to greet you by name after you have logged into a secure area of the Platform or deliver content in your preferred language.
Targeting or Tracking cookies. These cookies record your usage of the Platform in order to make our content and advertising more relevant to your interests. We may also share this information with third parties for this purpose.

Once they have been placed, these cookies may remain on your browser until you remove them. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also place cookies on your browser using other websites you access, over which we have no control. These cookies are likely to record your browsing activity, which may include your usage of our Platform. You can clear or adjust settings related to cookies at any time using your web browser. To learn more about the cookies we use please review our Cookie Policy.

We treat information collected by automatic data collection technologies as Personal Data when it is associated with or stored in a way that can be reasonably associated with identifiable Personal Data we collect in other ways. While our Platform currently does not recognize Do Not Track signals from your browser, we do provide information below about how to manage your choices and preferences related to online tracking. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/. Please note that this is a third party website for which Huntwell is not responsible. Additionally, you may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, please note that some parts of the Platform may become inaccessible or not function as intended.

(G) Purposes of Processing and Use and legal bases for Processing

The purposes for which we Process the categories of Personal Data identified in Section (D) above, subject to applicable law, and the legal bases on which we perform such Processing and Use, are as follows:

Purpose of Processing and Use	Categories of Personal Data	Legal basis for Processing and Use
Provision of Sites, products, and services: providing our Sites, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, products, or services.	Personal details Contact details Correspondence Demographic information Consent records Purchase details Payment details Data relating to our Sites Data relating to body cameras and in-car video Employer details Content and advertising data Cookie data Security information Views and opinions	The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, products, or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (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).
Compliance checks: fulfilling our regulatory compliance obligations; ‘Know Your Client’ checks; and confirming and verifying your identity; use of credit reference agencies; and screening against government and/or law enforcement agency sanctions lists and other legal restrictions.	Personal details Contact details Correspondence Professional details Consent records Payment details Employer details Security information	The Processing is necessary for compliance with a legal obligation; or The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of fulfilling our regulatory and compliance obligations (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (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).
Operating our business: operating and managing our Sites,our products, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our products, or our services; and notifying you of changes to any of our Sites, our products, or our services.	Personal details Contact details Correspondence Consent records Payment details Data relating to our Sites Data relating to body cameras and in-car video Content and advertising data Cookie data Security information Views and opinions	The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of operating our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (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).
Planning: organisational planning; succession planning; making changes to the nature and scope of our operations or our business; mergers, acquisitions, dissolutions demergers, liquidations, asset sales, divestitures, reorganizations and similar corporate structuring arrangements.	Personal details Contact details Professional details Demographic information Data relating to our Sites Employer details Content and advertising data Views and opinions	We have a legitimate interest in carrying out the Processing for the purpose of planning the future operation of our operations or our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalizing our Sites, products and services for you; maintaining and updating your contact information where appropriate; displaying advertising to you on third party sites; processing personal data for the purposes of analytics, conversion tracking, and developing more tailored advertising campaigns; obtaining your prior, opt-in consent where required; and enabling and recording your choice to opt-out or unsubscribe, where applicable.	Personal details Contact details Correspondence Demographic information Consent records Data relating to our Sites Content and advertising data Cookie data Views and opinions	The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (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).
Product safety communications: communications in relation to product safety, including product recalls and product safety advisory notices.	Personal details Contact details Payment details	The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of ensuring the safety, and proper use, of our products (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.	Personal details Contact details Professional details Demographic information Consent records Payment details Data relating to our Sites Employer details Content and advertising data Cookie data Security information Views and opinions	The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.	Personal details Contact details Correspondence Visitor logs	The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or The Processing is necessary to protect the vital interests of any individual.
Financial management: sales; finance; corporate audit; and vendor management.	Personal details Contact details Payment details	We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (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).
Surveys: engaging with you for the purposes of obtaining your views on our Sites, our products, or our services.	Personal details Contact details Correspondence Consent records Views and opinions	We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (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).
Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).	Personal details Contact details Visitor logs	The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.	Each category of Personal Data identified in Section (D) above, to the extent necessary in the context of the relevant legal obligation or regulatory requirements or guidance.	The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Legal compliance: compliance with our legal and regulatory obligations under applicable law.	Each category of Personal Data identified in Section (D) above, to the extent necessary in the context of the relevant legal obligation or regulatory requirements or guidance.	The Processing is necessary for compliance with a legal obligation, where applicable; or We have a legitimate interest in carrying out the Processing for the purpose of compliance with regulatory requirements or guidance (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Improving our Sites, products, and services: identifying issues with our Sites, our products, or our services; planning improvements to our Sites, our products, or our services; and creating new Sites, products, or services.	Personal details Contact details Correspondence Demographic information Consent records Data relating to our Sites Data relating to body cameras and in-car video Content and advertising data Views and opinions	We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our products, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (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).
Fraud prevention: Detecting, preventing and investigating fraud.	Each category of Personal Data identified in Section (D) above, to the extent necessary in the context of the relevant fraud detection, prevention or investigation activities.	The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Establishment, exercise and defense of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defense of legal rights and claims, including formal legal proceedings.	Each category of Personal Data identified in Section (D) above, to the extent necessary in the context of the relevant legal obligation or regulatory requirements or guidance.	The Processing is necessary for compliance with a legal obligation; We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or The Processing is necessary for the establishment, exercise or defense of legal claims.
Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.	Personal details Contact details Correspondence Professional details Demographic information Visitor logs Consent records Data relating to our Sites Employer details Content and advertising data Views and opinions	The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (e.g., where this is necessary for the purposes of criminal records checks, in accordace with applicable law).

(H) Disclosure of Personal Data to third parties

We disclose Personal Data to our affiliates, service providers, business partners, and other third parties for legitimate business purposes and the operation of our Sites, products, or services to you, in accordance with applicable law. We do not sell Personal Data to third parties for their own use. In addition, we disclose Personal Data to:

you and, where appropriate, your appointed representatives;
others with your consent or at your request;
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 Huntwell, subject to binding contractual obligations of confidentiality;
resellers, distributors and third party business partners of Huntwell for the purposes to take steps at the request of you prior to entering into a contract, or to perform a contract upon your request;
third party Processors, including payment services providers; shipping companies; telemarketing companies; data supply service providers; data cleansing service providers; customer contact management; cloud and data storage services; website data analysis; advertising delivery services; and marketing, located anywhere in the world, subject to the requirements noted below in this Section (H);
any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal claims or compliance with applicable law;
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 including safeguarding against, and prevention of, threats to public security;
binding contractual obligations of confidentiality;
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 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 (e.g., LinkedIn, YouTube and Facebook). 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.

(I) Your privacy 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, 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; However, the Company may refuse such a request in the following circumstances:
- The request involves an impediment to national security, foreign affairs, or military secrets;
- The request involves an impediment to the overall economic interests or other major national interests;
- The request impedes a government agency's performance of its statutory duties; or
- The request impedes the major interests of the Company or a third party.
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 collect, process and use 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 to Huntwell, please contact dpm.LAC@huntwell.com.tw.

Please note that if you submit a request to exercise any of the above rights (a “Privacy Rights Request”), we may request additional information to enable us to process your Privacy Rights Request. We will use the information you provide to verify your identity, locate your personal information that we may hold about you, and to fulfill your Privacy Rights Request.

Please keep in mind that, in accordance with applicable law, we may not be able to honor all Privacy Rights Requests (e.g., if the information is required to process your payments or returns, to fulfill your order, or to comply with tax, audit, or other regulatory requirements).

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (M) below. Please note that:

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.

(J) Direct marketing choices

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, products, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, products, or services. If we provide Sites, products, or services to you, we may send or display information to you regarding our Sites, products, or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, products, or services you have requested.

(K) Data security

We have implemented appropriate technical and organizational security measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. We do this by:

Using encryption when collecting or transferring sensitive information, such as credit card details.
Designing our data security safeguards to ensure the ongoing security, integrity, availability and resilience of processing systems and services.
Limiting physical access to our premises.
Limiting access to the information we collect about you.
Ensuring that our Business Partners have appropriate safeguards in place to help protect your personal information.
As required by law, destroying or de-identifying personal information.

Any Personal Data sent to us, either in writing or email, may be insecure in transit and we cannot guarantee its delivery. Passwords must be kept confidential and not disclosed to a third party. Huntwell does not ask you for your password.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

(L) Data retention

We take every reasonable step to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this Privacy Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

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

(a) 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

(b) your Personal Data is necessary in connection with the lawful purposes set out in this Privacy Notice, for which we have a valid legal basis (e.g., where your Personal Data is 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:

(a) 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 is relevant); and

(b) 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.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

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

(M) Details of Controllers

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

Controller entity	Contact details
Huntwell Technology Corporation	No. 2, Dazhi Rd., Taoyuan Dist., Taoyuan City 330417, Taiwan (R.O.C.) Attn: Data Protection Manager Tel: 03-3755288 Email: dpm.LAC@huntwell.com.tw

(N) Definitions

"Cookie" means a small file that is placed on your device when you visit a website (including our Sites). In this Privacy 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 is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
"Personal Data" means information relating to a natural person that can directly or indirectly identify the natural person, including but not limited to: name, date of birth, national identification card number, passport number, physical characteristics, fingerprints, marriage status, family background, education, occupation, medical records, medical treatment, genetic information, sexual life, health examination results, criminal record, contact information, financial status, and social activities.
"Process", "Processing" or "Processed" means anything that is done with any Personal Data, such as recording, input, storage, editing, correction, duplication, retrieval, deletion, output, linking, or internal transmission of such data.
"Use" means the application of collected personal data for purposes other than processing.
"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.
“Sensitive Personal Data” means Personal data involving medical records, medical treatment, genetic information, sexual life, health examination results, and criminal record. The detailed classification of this data shall follow the provisions of Article 4 of the Enforcement Rules of the Personal Data Protection Act.
"Site" means any website operated, or maintained, by us or on our behalf.