# WPS Office Software Privacy Policy

###### Last Updated on March 4, 2022（Archived Versions）

1. Introduction

Your privacy is important to WPS Software Pte. Ltd. and its affiliates ("We" or "WPS" or "WPS Office"), and to protect your privacy we developed a Privacy Policy, which explains how we use any personal data (“information”) we collect about you. It describes:

- Introduction
- About us
- Revision to this Privacy Policy
- What information we collect about you
- How we use your information
- Collection and use of non-Personal data
- Who we share your information with
- Cross-border transfer of information
- Your rights in relation to our use of your information
- The security and storage of your information
- How long we retain your information
- Our policy towards children
- Links to other sites
- Additional privacy information for EEA/EU residents
- Additional privacy information for California residents
- Contact information

We provide this Privacy Policy to help you understand how we collect, use, disclose, transfer, and store your information that we access in order to provide our “Services”. When we say Services in this Privacy Policy, we mean our websites located at `http://www.wps.com`, `http://note.wps.com/` and other websites operated by us through which our Services are provided (“Sites”), our mobile device applications (“Apps”), and our software products available for use via the Apps or via installation on personal computers (collectively, the “Products”). This Privacy Policy applies to only those websites, products, services and applications included within the “Services” and does not apply to any third-party websites, products, services or applications, even if they are accessible through our Services.

2. About Us

WPS Office Software is a leading office productivity suite for PC and mobile devices, produced by WPS Office. WPS Office provides the above-mentioned Services to Individuals and Enterprises, accordingly, WPS Office is data controller with respect to Individuals’ personal information that we collect and process in connection with the Services; and WPS Office is data processor with respect to Enterprises’ personal information that we collect and process in connection with the Services.

3. Revision to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time in accordance with the law. If we make any material changes to this Privacy Policy, we will notify you of such changes by posting them on our websites or by sending you emails or other notifications, and we will update the Last Updated Date above to indicate when such changes became effective.

4. What Information We Collect about You

(1) Basic Subscription Information. If you create an account (“Account” or “WPS ID”) in connection with your use of any of the Services, either through our Sites or when you download and install our Apps and Products, we’ll collect certain information about you, such as your name, email address, postal address. If you create an Account using your login credentials from one of your accounts with third-party social networking services such as Google, Facebook, Microsoft, Dropbox or Twitter (each, an “SNS Account”), we’ll be able to access and collect your name and email address and other information that your privacy settings on the SNS Account permit us to access. If you create an Account, we may also collect other non-personal data information (e.g., virtual device identifier).

(2) Information Collected Using Cookies and Other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.

1. A. “Cookies” are small text files that are placed on your hard drive by a Web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and Web traffic routing on our Services, and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive on the basis of related arrangement. Please note that this Privacy Policy covers only our use of Cookies but not use of Cookies by such third parties.

2. B. “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on Web pages (or in an e-mail).

3. C. At the same time, our Services may include third-party tracking tools without limitation to individual cookies, APIs (application programming interface) and SDKs (software development kit) to collect and analyze technical data from you. WPS or aforementioned third-party services providers collect such data not to identify any specific individuality or personality of yours but to understand how you access and use the Services at general manner. Such data helps us provide the Services for you, learn how the Services are used, and make the Services more useful to you. The technical data collected by WPS and the aforementioned third-party services providers may include:

   - Your devices or software data, such as your Internet Protocol (“IP”) address, device identifier, region and language settings, Network provider, network settings and status, operating system, device storage, Android ID, Mobile advertising identifiers, such as iOS IDFAs and Android Advertising IDs (collectively, “Mobile IDs”), User Agent and HDID, browser or Apps that you have installed, mobile websites that you have interacted with, and how you interact with them, including whether and how you interact with ads (including time-stamp information);
   - Your operation data, such as the aggregate number of time, frequency and activity of your use of our Services, and when you use contact management functions or interact with other persons or institutions through our Services, we may collect data relating to your contacts and your relationship with such contacts, we may also collect Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether you clicked on it, and whether you visited the advertiser’s website or downloaded the advertiser’s app;
   - The metadata shared by you, such as shooting, uploaded sharing photos or videos, as well as exact date, time, place, and other data stored when using our Services.

(3) Information Related to Use of the Services. Our servers automatically record certain data about how a person uses our Services (“Log Data”), including that of both Account holders and non-Account holders (either, a “User”). Log Data may include certain data such as a User’s IP address, browser type, operating system, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding and tailoring features and functionalities of our Services to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying data about where our Services are used. In addition, for the aforementioned purposes and providing better access to and experience of our Services for you, we may allow certain third parties to collect and use your information.

(4) Information Sent by Your Mobile Device. We may collect certain data sent by your mobile device when you use our Services, such as a device identifier, the number and type of your devices you use to connect to the Service, user settings, device storage, Android ID, Mobile advertising identifiers, such as iOS IDFAs and Android Advertising IDs (collectively, “Mobile IDs”), HDID and the operating system of your devices (e.g., iOS, Android etc.), as well as data relating to your use of our Services.

(5) Location Data. When you use our Services, our third-party services providers (such as Google Analytics, Firebase, Facebook Analytics, Flurry etc.) may collect and provide us with your location data by converting your IP address into a rough geo-location. We may use such location data to improve and personalize our Services for you.

(6) Information Received from Our Partners and Other Third Parties. We also may link your subscription information with the data information we receive from our partners or other third parties (such as Google Analytics, Firebase, Facebook Analytics, Flurry etc.) to help smoothly facilitate our Services for you, to better understand your needs and to provide you with better Services experience. Use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

(7) Contact Information for Technical Support. We also may record your email, telephone and dialogue contents when you contact us for service support by sending emails or calling, to help us keep contact with you for updates and support to resolve your queries for use of our Services.

5. How We Use Your Information

We process your information for specific purposes and process only the personal data relevant for achieving that purpose. Depending on our relationship with you and the Services that we are providing, we mainly use information for the following purposes:

(1) to provide the Services, which include troubleshooting, customizing, identifying, supporting.

(2) to improve and develop our Services.

(3) to protect the security and prevent criminal activity.

(4) to comply with our legal obligations

(5) to provide and improve the WPS Ad Services

(6) to communicate with you.

We may also use your information for other purposes. We use your information only when we have a valid legal basis.

6. Collection and Use of Non-Personal Data

“Non-Personal Data” is the data that cannot be used to identify you. We collect Non-Personal Data to understand how people use our Products and Services and to help us improve our Services to better satisfy customer needs. We may, at our own discretion, collect, use, process, transfer or disclose Non-Personal Data for other purposes as well.

We will keep your information and Non-Personal Data separate and use each independently. If we do combine Non-Personal Data with your information, the combined data will be treated as personal data. We will protect the privacy of your information through strong security and encryption and in accordance with this Privacy Policy.

7. Who We Share Your Information with

We will not share any information that we have collected from or about you except as described below and we will share only necessary information on the minimum basis:

(1) Information Shared with Our Services Providers. We may engage third-party services providers to work with us to administer and provide the Services. Such third-party services providers will have access to your information for the purpose of providing you with the basic Services. You will find a list of our service providers and the privacy policies of their services via the following URL: https://www.wps.com/service_provider_list

(2) Information Shared with Our Advertisement Providers. Generally, we share the Service Information with direct or 3rd party Advertisement Providers in order to provide the WPS Ad Services. You will find a list of our ad partners list and the privacy policies of their services via the following URL: https://www.wps.com/ad_partners

(3) Information shared with Software Development Kit (SDK) providers. We may share your information with SDK providers to realizing the corresponding purposes. You will find a list of providers and the privacy policies of their services via the following URL:https://www.wps.com/Third_Party_SDK

(4) Information Disclosed in Connection with Business Transactions. Information that we collect from our users is considered to be our business assets. Thus, if we are engaged with a third party in a transaction such as merger, acquisition or sales of assets or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your information, may be disclosed or transferred to a third party acquirer in connection with such transaction.

(5) Information Required by Law. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general as required or permitted by law; and (iii) to stop any activity that we consider illegal, unethical or legally actionable. However, we may push back when a legal request appears to be overly broad or does not follow the correct process.

(6) Other Data Shared with Third Parties. We may share aggregated data and non-personal data with third parties for industry research and analysis, demographic profiling and other similar purposes.

8. Cross-border Transfer of Information

Since we are a global company, it may be necessary for us to transfer your information to any third party affiliated to us or with whom we have a cooperative relationship, and such information may be maintained on computers and/or other servers located outside of your state, province, country or other governmental jurisdiction in whole or in part. (“Cross-border transfer of information”).

Please note that where necessary to deliver the services, we will transfer personal information to countries/territories outside your countries/territories and they may not provide an adequate level of protection to your personal information, however, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.

If you want to know more about such Cross-border Transmissions of Information, please send your e-mail to privacy@wps.com. We will duly handle your response but please note that our Services may not be available to you if you refuse cross-border transfer of information.

9. Your Rights in relation to Our Use of Your Information

We provide the following rights to protect your information for our global customer:

(1) Right of Access. You have the right to receive information about your personal data processed by us upon request.

(2) Right to Rectification. You have the right to correct or amend your information if it is incorrect, inaccurate or incomplete.

(3) Right to Withdraw Your Consent You have the right to withdraw consent given to us at any time. As a result, we are no longer allowed to continue the processing based on this consent in the future. This does not affect the legality of the processing carried out on the basis of the consent up to the point of withdrawal.

(4) Right to Erasure. You have the right to obtain from us, under the following conditions, the deletion of your information:

1. A. the respective processing purpose has been achieved;

2. B. we have unlawfully processed your information;

3. C. you have withdrawn your consent without another legal basis applying to the data processing;

4. D. you have successfully objected to the data processing;

5. E. in cases where there is an obligation to delete information on the basis of EU law or the law of an EU member state to which we are subject.

(5) Complaints. In addition, you have the right to file a complaint with a data protection authority on our collecting and processing of your information. Please see this directory for more details with regard to the local data protection authorities. (`https://edpb.europa.eu/about-edpb/board/members_en`)

You can exercise your right to access, update and delete your information:

- in the settings of your Apps, or
- in the settings of your Products, or
- you could contact us at privacy@wps.com and we will assist you to exercise your right.

We may provide other rights for residents of some countries/territories subject to the locally applicable data protection law. We respect and constantly take multiple practices to protect your information no matter where you live.

If you have any questions about these rights or you would like exercise any of them, please contact us by sending an email to privacy@wps.com. Additional details of how to get in touch are set out below.

10. The Security and Storage of Your Information

We take all reasonable administrative, physical and electronic measures to protect the information that we collect from or about you from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. We work hard to protect you and WPS from unauthorized access, alteration, disclosure, or destruction of information we hold, including: (i) we use encryption to keep your data private while in transit; (ii) we offer security features, like 2 Step Verification to help you protect your account; (iii) we restrict access to personal information to WPS employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. However, please note that no transmission over the Internet is completely secure or error-free, and that the information security policies, rules and technical measures utilized and maintained by us may be subject to compromise.

When you use our Services on your computing and mobile devices (“Devices”), such as by using one of our downloadable applications, some of your data will be stored locally on such Devices.

When you sync your Devices with our Service, such data will be replicated on servers maintained in the United States, Singapore, India, Paris,Japan or Russia. This means that if you store your information in or submit data to our Sites, Apps or Products, your information will be transmitted, hosted, and accessed in any of these countries and/or districts based on your location.

Data privacy laws or regulations in your home country may differ from those in the places where you are located. We will collect, store, and use your information in accordance with this Privacy Policy and applicable laws, wherever it is processed.

11. How Long We Retain Your Information

We will retain your information for the period strictly necessary for fulfilling the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. For example, we retain your account information for as long as your account is active or as needed to provide you with Products or Services you have requested or authorized, including maintaining and improving the performance of the Products or Services and protecting system security. We also retain personal data as needed to maintain appropriate business and financial records, protect our legal interests, resolve disputes, or comply with legal or regulatory requirements.

12. Our Policy Towards Children

To protect children’s privacy and safety, we provide specific protection with regard to children’s personal data. Our Services are not directed to children under the age of 16 years （or otherwise provided by the related jurisdiction） and we do not knowingly collect, store, share or use personal data from children. If you are a child under 16（or otherwise provided by the related jurisdiction）, you are not permitted to use and install our products or create your own WPS IDs, unless your parent provides verifiable consent. If we learn that we have collected personal data of a child under 16, unless we have first obtained verifiable, explicit parental permission for collecting personal data of such child, we will take steps to delete the information as soon as we can.

Once a child downloads, installs or uses any of our Services, in whole or part, such action shall be deemed representing that his/her parents agree with our policies, terms and conditions including but not limited to this Privacy Policy.

13. Links to Other Sites

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

WPS's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

14. Additional Privacy Information for EEA Residents

In this section, we provide additional information to European Economic Area (EEA) residents, as required under EU privacy laws, including the General Data Protection Regulation (“GDPR”).

(1) Legal Basis of Processing Information

We process information if one of the following applies:

1. A. Necessary for entry into, or performance of, any contract(s) with you (Art 6(1)(b) of the GDPR). This applies to section 5(1) to provide the Services, which include troubleshooting, customizing, identifying, supporting.

2. B. Necessary for the legitimate interests of us, where these are not overridden by your interests or fundamental rights and freedoms (Art 6(1)(f) of the GDPR). This applies to section 5(2) to improve and develop our Services, 5(3) to protect the security and prevent criminal activity.

3. C. Necessary for compliance with a legal obligation to which we are subject (Art 6(1)(c) of the GDPR). This applies to section 5(4) to comply with our legal obligations.

4. D. In limited circumstances and to the extent the legal bases for processing set out above do not apply, processed with your consent (Art 6(1)(a) of the GDPR). This applies to section 5(5) to provide and improve the WPS Ad Services, 5(6) to communicate with you.

(2) Cross-border Transfer of Information

If you are based within EEA, please note that where necessary to deliver the services, we will transfer personal information to countries/territories outside the EEA (e.g., USA). Countries/territories outside the EEA may not provide an adequate level of protection to your personal information; however, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. The safeguard we primarily rely upon is the European Commission-approved standard contractual data protection clauses.

(3) GDPR Rights

In general, EEA residents have the following rights with respect to their personal information:

1. A. Right to Object. You have the right to object to the processing of your information. If you object, we will no longer process your information unless we can prove compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims on our part.

2. B. Right to Restriction of Processing. You have the right to request us to process your information only to a restricted extent under the following conditions:

- the accuracy of your information is contested;
- you request limited processing instead of deletion under the conditions of a justified right of erasure;
- the data is no longer required for the purposes pursued by us, but you need the information to assert, exercise or defend legal claims; or
- the success of an objection is still disputed.

1. 4. C. Right to Data Portability. You have the right to receive from us information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, as well as the right to request us to forward this information to another controller under the following conditions:

- the processing is based on consent or the contract, or
- the processing is carried out by automated means.

15. Additional Privacy Information for California Residents

In this section, we provide additional information to California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not apply to publicly available information lawfully made available by state or federal government records, deidentified information, aggregate consumer information, or other personal information that is exempt under the CCPA (such as information covered by the Health Insurance Portability and Accountability Act).

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about California residents in the prior 12 months (from the Last Updated date above), and the rights California residents have under the CCPA regarding this personal information.

CCPA Rights

In general, California residents have the following rights with respect to their personal information:

Do-not-sell (opt-out): to opt-out of our sale of their personal information, including those we have actual knowledge are younger than 16.

Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.

Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):

1. A. categories of personal information collected

2. B. categories of sources of personal information

3. C. categories of personal information about them we have disclosed for a business purpose or sold

4. D. categories of third parties to whom we have sold or disclosed for a business purpose their personal information

5. E. the business or commercial purposes for collecting or selling their personal information

6. F. a copy of the specific pieces of personal information we have collected about them

Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests

California residents may submit CCPA requests to exercise their “Right to know (access)” and “Right of deletion” to privacy@wps.com.

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide your name and contact information to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us by email; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

16. Contact Information

Please contact us at your convenience if you have any questions about our Privacy Policy through the following ways:

E-mail contact: privacy@wps.com

Address: WPS SOFTWARE PTE. LTD., 6 RAFFLES QUAY #14-06 SINGAPORE(048580)