JW PEI Privacy Policy

Last Revised: 09/01/25

Overview

JW PEI respects your privacy. This JW PEI Privacy Policy (“Privacy Policy”) is designed to help you understand the types of personal information we at JW PEI Inc. (“JW PEI”, “us”, “we”, or “our”) collect, how we use it, how and when it may be shared, and the rights and choices you may have with respect to your personal information. It also explains how we communicate with you and how you can make requests or submit inquiries about your personal information.

By accessing, visiting, or using our Services (defined below), you acknowledge this Privacy Policy, and agree to our Terms and Conditions, Shipping, Return and Refund Policies (collectively, the “Terms”). If you are not comfortable with any part of this Privacy Policy or do not agree with the Terms, please immediately discontinue access and use of our Services.

We may provide additional "just-in-time" disclosures or additional information about our personal information collection, use and sharing practices. These notices may supplement this Privacy Policy, clarify our privacy practices in the circumstances described, or provide you with additional choices about how we process your personal information. Also, we may make changes to this Privacy Policy from time to time, and we will update the Last Revised date at the beginning of this Privacy Policy when we make changes. If we make changes to this Policy that we believe are materials, we will notify you of such material changes as required by applicable law.

If you have questions regarding this Privacy Policy, please contact our privacy department by emailing us at privacy@jwpei.com. Below is a Table of Contents which allows you to easily access any sections of the Privacy Policy of interest by clicking on the section title.  

1. Applicability and Scope

This Privacy Policy applies to all personal information that we collect during any written, electronic, and oral communications online or offline when you: interact with or purchases from our website located at https://www.jwpei.com/ , and any other websites, pages, features or content we own or operate (collectively, the “Site(s)”) that link to this Privacy Policy; attend or interact with us at one of our events; or interact with other products or services that direct you to this Privacy Policy (collectively, the “Service(s)”).  

2. Personal information We Collect 

We collect certain personal information about you and your use of our Services. Personal information is any information that relates to you, identifies you personally, or could be used to identify you. The definition of personal information (used interchangeably with “personal data”) depends on the applicable law based on your physical location. Only the definition that applies to your residency or physical location will apply to you under this Privacy Policy.

The personal information that we collect generally falls into three primary categories: (1) personal information you voluntarily provide to us; (2) personal information we collect from you automatically; and (3) personal information we collect from third parties. We may collect the following categories of personal information:

Information You Voluntarily Provide to Us. We, or service providers that assist us in providing, maintaining, and operating our Services, may collect the following types of personal information from you:

· Account Creation. We may collect information relating to the creation of an account when using our Services, such as your name and email address to create an account via Shop.

· Order Placement. We may collect your personal information when you place an order through our Services, including, for example, your first and last name, delivery address, postal code, email address, phone number, payment account or credit card information.

· Payment Information. When you place orders, we may collect your payment card information, shipping and billing addresses, and phone numbers.

· Newsletter Sign-ups. You may choose to provide us your contact details, such as your email address, if you wish to receive information about the products and services that we offer.

· Customer Service. When you engage with our support team, for example, emailing customer@jwpei.com or any other @jwpei.com email address, chatting with us on Sites, submitting a support request, we may collect records, copies of your correspondence (including email addresses), chat history, and any additional information you choose to share with us

Information We Automatically Collect. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. We may collect the following types of information automatically from you:

· Usage Data. When you browse our Sites, we automatically collect log data such as your web request, Internet Protocol (“IP”) address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access our servers, and other diagnostic data.

· Device Information. When you use your desktop or mobile devices to access our Services, we may be able to identify your device’s unique device identifier, MAC address, operating system, and your mobile device’s advertising ID.

· Location Information. When you use our Services, we may infer the generic physical location and geographic regions of your device from your device settings. For example, your IP address may indicate your general geographic region. You may choose not to share your location details with us by adjusting your mobile or desktop device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

Information We Collect from Third Parties. From time to time, we may obtain information about you from public or third-party sources as required or permitted by law. These sources may include:

· Affiliate Programs. When you opt to participate in our affiliate program operated by our third-party partner, we may receive your name, email address, company information, address and any other personal information you provide.

· Social Media. We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture) to deliver the content or as part of the operation of the third-party website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on our Services and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.

· Third Party Partners. Unless prohibited by applicable law, we may obtain your personal information from marketing partners, analytics providers, promotion providers, and other third-party partners to market to you, including to match custom audiences or create lookalike audiences on social media or other marketing platforms so that we can better understand which of our Services may be of interest to you, market our Services to you, and to provide us information necessary to improve our Services.

3. How We Use Your Personal information

JW PEI uses your personal information as described in this Privacy Policy for business and commercial purposes, or as disclosed to you prior to such processing taking place, such as to provide, improve, and optimize our products and services, to fulfill contracts, record-keeping, or regulatory obligations, or as required by a law enforcement agency, lawful order, or as required or permitted for other lawful purposes.  Below we describe why we collect your personal information:

(a) To Provide Our Services. We will use your personal information to provide the Services you request, including creating and managing your user accounts, processing and completing purchases, returns, and similar transactions.

(b) To Provide You with Service-Related Communications.  We will use your personal information to send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about Privacy Policy updates, security updates, tips or other relevant transaction-related information. Service-related communications are not promotional in nature. And you are not able to unsubscribe from such communications

(c) To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and satisfaction of the Services.

(d) To Personalize Your Experience. We may process your information to personalize your experience. By personalization, we enable you to more easily interact with our Services across platforms and devices.

(e) To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent and detect fraud and abusive use of our Service, monitor and verify your identity so that unauthorized users do not gain access to your information, enhance system security, and combat spam, malware, malicious activities or other security risks.

(f) To Provide Marketing Communication. Subject to applicable laws, we may collect your email address, phone number or other electronic addresses that you voluntarily provide to us when you subscribe to our marketing communications so that we may send you information on products, services and promotions.

(g) For Research and to Develop of Our Services. We may process your personal information to better understand the way you use and interact with our Services.

(h) To Comply with Our Legal and Regulatory Requirements.  We use personal information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.

(i) To Enforce Compliance with Our Terms, Agreements and Policies. When you access or use our Services, you are bound to our Terms. We may process your personal information to enforce our Terms or other legal rights, including those arising from any contracts entered into between you and us, including for billing and collection.

(j) To Facilitate Corporate Acquisitions, Mergers and Transactions. We may process your personal information as is necessary in the context of corporate acquisitions, mergers, sales, bankruptcy.

4. How We Disclose Your Personal information

We share your personal information as needed to fulfill the purposes described in this Privacy Policy and as permitted by applicable law. We may disclose your personal information as described below.

(a) With Our Service Providers. We may share your personal information with service providers acting on our behalf to help us operate our Services. Service providers provide us with support services, including. assisting us in e-commerce operations; managing a database of customer information; hosting the Sites; designing and/or operating the Sites’ features; tracking the Sites’ activities and analytics; enabling us to send you special offers or perform other administrative services; delivery and shipping; operating our customer support; allowing you to participate in live chat on the Site; payment processors; and fraud, abuse, and intrusion prevention services. These service providers may have access to or process your personal information only for the purpose of providing services to us.

(b) Within Our Corporate Organization. We may share your personal information within our organization, to provide you with the Services and take actions based on your request, such as our parent company, subsidiaries, and corporate affiliates, joint venturers, or other companies under common control with us.

(c) Business Partners, Sponsors, and Other Third Parties. Subject to applicable law, we may disclose your personal information to business partners, sponsors of promotions, and other third parties in order to provide you with services that may interest you, for permitted marketing purposes, or for co-sponsored events based on your voluntary participation. If we collect personal information from you in connection with a co-branded offer with one of our trusted partners, we’ll make it clear which party’s privacy policy applies. If you provide additional information to any of these third parties, such information provided to these third parties will be subject to each third party's privacy practices and policies.

(d) With Professional Advisors. We may disclose your personal information to our professional advisors—including lawyers, auditors, accountants, insurers, and similar consultants—when such disclosure is necessary for them to provide us with their professional services, to comply with our legal or financial obligations, or to protect or enforce our rights.

(e) During Business Transaction or Other Asset Transfers.  We may disclose your personal information with another company that buys some, or all, of our assets in a merger, acquisition, sale, bankruptcy and that company may use and disclose personal information for purposes similar to what is described in this Privacy Policy. We may also disclose personal information with prospective purchasers to evaluate the proposed transaction.

(f) For Legal Compliance & Safety. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to (i) comply with law enforcement requests and legal processes, such as a court order or subpoena; (ii) comply with requests from auditors, examiners or other regulators; (iii) exercise, establish or defend our legal rights; or (iv) protect your, our, or others’ rights, property or safety. 

(g) With Your Consent. We may share your personal information with other companies if you give us permission or direct us to share your information.

5. Cookies and Similar Tracking Technologies

We and our service providers may automatically collect information from you when you use our Services using “cookies” and other tracking technologies to help us customize your experience and better manage content on our Services, including to: (a) analyze our web traffic using an analytics package; (b) identify whether you already visited any of our affiliated websites; (c) store information about your preferences (e.g., cookie consent); and (d) to recognize when you return to our Services.

Cookies are small amounts of data that are stored within your computer’s Internet browser and that are accessed and recorded by the websites that you visit so that they can recognize the same browser navigating online at a later time. Information that may be collected by cookies when you use the Sites may include, without limitation: the pages you visit within the Sites; the date and time of your visit to the Sites; the amount of time you spend using the Sites; the IP address used to connect your computer to the Internet; and/or your computer and connection information such as your browser type and version, operating system and platform.  

Below is a summary of the types of cookies we may use.

● Strictly Necessary Cookies: These are cookies without which you would not be able to use our Services. For example, essential cookies adjust the website data transmitted to match your internet connection, get you to the secure versions of the website, and help provide products or services you specifically request. If you set your browser to block these cookies, some parts of our website will not work. 

● Analytics/Performance Cookies: These cookies count visits and traffic sources to measure and improve the effectiveness of our Services. We may use persistent cookies, which will remain on your computer even after you close your browser, to understand general website usage and volume statistical information (which does not include personal information) and improve the content and offerings on our websites. We may also use persistent cookies to store user preferences.

● Functional Cookies: These cookies allow the website to remember choices you make and provide enhanced functionality and more personalized features. These technologies are used so that we can provide a continuous and more personalized experience for you (e.g., to recognize you by name when you return to a website). 

● Targeting Cookies. Targeting cookies may be set through our Sites and Services, by our advertising partners to deliver content, including ads, that are relevant to your interests across your devices, based on how you interact with our advertisements or content. They may be used by our advertising partners to build a profile of your interests and to show you relevant ads on other sites. If you do not allow these cookies, you will experience less targeted advertising.

Analytics. We may use third-party service providers to monitor and analyze the use of our online, web-based, and mobile-based Services, such as Google Analytics. Google Analytics is an analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. To opt out of Google Analytics or to prevent your data from being collected and used by Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout.

Managing Cookies via Browser Controls. You may set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Websites although your access to some functionality and areas may be restricted. If you want to understand your browser’s cookie default setting, or learn to modify your browser’s cookie settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers:

o Google Chrome

o Microsoft Edge

o Microsoft Internet Explorer

o Apple Safari

o Android Browser

Interest Based Advertising - Website Browser. Many third-party advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1. Residents of the European Union may opt-out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://www.youronlinechoices.eu/.

6. Retention of Your Personal information

We will retain your information for as long as we have ongoing business need to provide you services or for other purposes stated in this Privacy Policy. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us at privacy@jwpei.com. Please note that, we may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7. How We Protect Your Personal information

JW PEI utilizes industry-standard practices intended for safeguarding your personal information, both during transmission and once it is received. Our website is updated on a regular basis for security holes and known vulnerabilities in order to make your visit to our website safely. We utilize physical, technical, and administrative procedures to protect against the loss, unauthorized access, destruction, misuse, modification and improper disclosure of your personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the internet. If you feel that the security of any account you might have with us has been compromised, you should contact us immediately at privacy@jwpei.com..

8. Your Choices 

We offer you certain choices about how we communicate with you and what information we collect from you.

A. Correct, Update or Delete Your Personal information

As a registered user with our services, you can access, modify, or delete certain profile information at any time by logging into your JW PEI account.

B. Communication Preference

We offer you certain choices about how we communicate with you and what information we collect from you. When you no longer wish to receive these marketing emails or text messages from us, you can unsubscribe at any time by unsubscribing or following the instructions contained within such messages, or emailing us at privacy@jwpei.com.. Please note that we may still send you certain communications relating to your account or use of our services (such as administrative and service announcements), and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.

9. Privacy Rights

For individuals in the United States, depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information.

If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please refer to the “What Rights Apply” section to determine the rights you have in the jurisdiction you reside. Your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (i) when denial of the request is required or authorized by law; (ii) when granting the request would have a negative impact on another’s privacy; (iii) to protect our rights and properties; (iv) where the request is frivolous or vexatious, or for other reasons.

a) Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information.

b) Right to Correct. You may have the right to rectify, correct or update any of your personal information held by us that is inaccurate.

c) Right to Delete. Under certain circumstances, you may have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse your right to delete if it is reasonably necessary for us to provide a service requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your personal information; to exercise a right provided by law; to comply with a legal obligation, or if there are compelling legitimate grounds for keeping your personal information.

d) Right to Portability. Under certain circumstances, you may have the right to receive personal information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another entity.

e) Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.

f) Right to Object to Automated Decision-Making. You may have the right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you, using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.

g) Right to Opt-Out of Sale. You may have the right to opt-out of the sale of your personal information. Like many businesses, we use cookies, pixels, and similar technology on our Websites and Apps, and we share certain personal information, such as your email address, phone number, IP address or device identifiers, to third-party advertisers to improve your user experience and to optimize our marketing activities. Under the broad definition of “sell” contained in some jurisdictions’ privacy laws, this could be considered a sale.

h) Right to Opt-Out of Sharing for Targeted Advertising. You may have the right to opt-out of the sharing of your personal information to third parties for behavioral or cross-contextual advertising purposes. Like many websites, we use cookies, pixels, and similar technology, and we share certain information, such as your email address, phone number, IP address or device identifiers, to certain third-party advertisers to improve your user experience and to optimize our marketing activities. You have the right to direct us not to share your personal information for targeted advertising purposes.

What Rights Apply

To determine which of the rights listed above that the law in your state offers, please refer to the table below. States not listed either do not have a law providing such rights or it does not apply to our operations.  

State of Residence	Applicable Rights
California	(a) - (h)

Submitting a Request to Exercise Your Privacy Rights

To assert your privacy rights noted above, please email us at privacy@jwpei.com, or use the webform（https://www.jwpei.com/pages/jw-pei-privacy-webform） at PLEASE SPECIFY, and indicate which rights you would like to exercise. 

Request Cadence: Please note that depending on your state of residence, applicable law may limit how many times per year you may submit a Right to Know/Access. We may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.

Identity Verification: To protect your privacy, we must be able to verify your identity to confirm that the request came from you before we can process your request to exercise certain privacy rights that you may be entitled to under the applicable law. We may contact you by phone or e-mail to verify your identity. Depending on your request, we will ask for information such as your name, address, an e-mail address or a phone number you have used with us. For certain requests, we may also ask you to provide details about your most recent purchases.

Authorized Agents: In certain states you may designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

Opt-Out of Cookie-Based Sales, Sharing and Targeted Advertising. You can exercise your right to opt-out of sales and targeted advertising by [clicking the "Your Privacy Choices" link in the website footer and following the directions in the Your Privacy Choices pop-up screen regarding how to opt-out of sales, sharing and targeted advertising.] If you previously opted-out and wish to opt-in, you can use the options identified above to change your preferences

If you are a resident of California, you may also opt-out of sharing and sales via cookies by using an opt-out preference signal. The Global Privacy Control (GPC) signal is currently the only opt-out preference signal we recognize. You can visit the GPC official site at https://globalprivacycontrol.org/#about to learn how to configure your device to send such signals. We will honor and process the opt-out preference signal in a frictionless manner. Your opt-out choice will only apply to your use of our Websites through the current browser or device you are using and only so long as that browser’s cookies are not erased. You will need to submit a separate opt-out of sharing request on each device and browser you use to visit our Websites to completely opt-out using this method.  Please note that after opting out of targeted advertising, you may still receive generalized ads.

10. Children’s Information

Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 13. If we become aware that a child under 13 has provided us with personal information, we will terminate the user’s access to our Service and take steps to delete such information from our file systems, unless we have a legal obligation to keep it.

11. Notice to Individuals in the European Economic Area, the United Kingdom, Switzerland

This section only applies to individuals using or accessing our Service while located in the European Economic Area, the United Kingdom, and, Switzerland (collectively, the “European Countries”) at the time of data collection. Pursuant to the European Union’s General Data Protection Regulation, the UK General Data Protection Regulation, the Switzerland's revised Federal Act on Data Protection (collectively, the “GDPR”). For the sake of clarity, references to personal information in this Privacy Policy concerns personal data in the sense of the GDPR.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in European Countries. If any terms in this section conflict with other terms contained in this Privacy Policy, the terms in this section shall apply to individuals in a European Country.

Our Relationship to You. Your personal data is collected and processed by JW PEI, Inc. in the United States, which is operating the Site and the Services, and is the Controller of the personal data.

Legal Bases for Processing Your Personal Data

We generally process your personal data when we need to fulfill a contractual obligation (such as fulfilling your orders), where we need to comply with our own legal obligations, where we have your explicit consent to do so, or to use your personal data for a reason related to our business (the GDPR refers to these reasons as “legitimate interest”). Below is a chart detailing the legal basis for processing your personal data in relation to the purposes identified in Section 3 and 4 of this Privacy Policy.

Section & Purpose of Processing	Legal Bases for Processing
Section 3(h) To Comply with Our Legal and Regulatory Requirements Section 3(e) To Detect and Prevent Fraud and Security Risks Section 4(d) With Professional Advisors Section 4(f) For Legal Compliance & Safety Section 4(g) With Public Registries and Data Escrow Providers via Registration Data	Based on our legal obligations. Article 6(1) lit.(c) GDPR.
Section 3(a) To Provide Our Services Section 3(b) To Provide You with Service-Related Communications Section 3(c) To Provide Customer Support or Respond to You Section 3(i) To Enforce Compliance with Our Terms, Agreements and Policies Section 4(a) With Our Service Providers Section 4(b) Within Our Corporate Organization Section 4(c) With Business Partners, Sponsors, and Other Third Parties	Based on our contract with you or to take steps at your request prior to entering a contract. Article 6(1) lit.(b) GDPR.
Section 3(g) For Research and Develop Our Services Section 3(d) To Personalize Your Experience Section 3(j) To Facilitate Corporate Acquisitions, Mergers and Transactions Section 4(e) During Business Transaction or Other Asset Transfers	Based on our legitimate interest to operate our business and not overridden by your data protection interests or fundamental rights and freedom. Article 6(1) lit.(f) GDPR.
Section 3(f) To Provide Marketing Communication Section 4(g) With Your Consent	Based on your consent. Article 6(1) lit.(a) GDPR.

Individual Rights. We provide you with the rights described below when we process your personal data. We may limit your individual rights: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on another data subject’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic.

· Right to access. You may have the right to obtain a copy of your personal data that we hold about you, as well as other supplementary information, such as the purposes of processing, the categories of personal data that we process, the entities to whom we disclose your personal data, etc.

· Right to rectification. You may have the right to request us correct any of your personal data in our files.

· Right to erasure. Under certain circumstances, you may have the right to request erasure of your personal data that we hold about you. This right is not absolute, and we may refuse your erasure request if there are compelling legitimate grounds for keeping your data.

· Right to restriction. In certain circumstances, you have the right to request that we restrict our processing of your personal data. For instance, this right is available if you contest the accuracy of the personal data, or you objected to our processing.

· Right to object to processing. If we process your personal data on the legal bases of consent, or legitimate interests, you have the right to object to our processing of your personal data. We may, however, continue to process your personal data if it is permissible pursuant to any exception under applicable law.

· Right to portability. Under certain circumstances, you may have the right to receive personal data we hold about you in a structured, commonly used, and machine-readable format.

· Automated Decision-Making. We do not make any decisions based on algorithms or other automated processing that significantly affect you.

· Right to lodge a complaint. If you reside in the European Countries, you may have the right to lodge a complaint with your national data protection authority or equivalent regulatory body. You can find details of EEA Supervisory Authorities here: https://edpb.europa.eu/about-edpb/board/members_en.  The Supervisory Authority in the UK is the Information Commissioner’s Office (ICO), available here. The Supervisory Authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC), available here.

To assert your privacy rights, please email privacy@jwpei.com and indicate which rights you would like to exercise. To protect your privacy, we must be able to verify your identity to confirm that the request came from you before we can process your request to exercise any of the rights that you may be entitled. We may contact you to verify your request. Depending on your request, we will ask for information such as your username, an e-mail address, or a phone number you have used with us.

International Transfer of Your Personal Data. We may, subject to applicable law, transfer your personal data, to service providers, vendors, registries, or partners outside the country where you are located and where information protection standards may differ (e.g., your information may be stored on servers located in other jurisdictions). We will utilize appropriate safeguards governing the transfer and usage of your personal data, for example, Standard Contractual Clauses. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.

12.   California Notice at Collection

If you are a California resident, then this Notice at Collection also applies to you in accordance with requirements under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively “CCPA”).

Categories of Personal Information Collected, Disclosed and Categories of Recipients

Depending how you interact with our Services, the chart below describes the categories of personal information (as the CCPA defines that term), collected the sources and purpose of such collection, and the parties to whom the information was disclosed for business purpose for the preceding 12 months.

Personal Information Collected	Purpose of Information Collection (see Section 3, above, for more information)	Disclosure of Personal Information (see Section 4, above, for more information)
Identifiers, such as a name, address, email, phone number, your device’s IP address, identification numbers associated with your devices, account number, account login, or similar identifiers.   AND   Personal information under California Civil Code section 1798.80, including name, address, email, phone number, account number, account login, and credit/debit card number.	-To Provide Our Services. -To Provide You with Service-Related Communications. -To Maintain Legal and Regulatory Compliance. -To Enforce Compliance with Our Terms, Agreements and Policies. -To Detect and Prevent Fraud and Security Risks -To Provide Customer Support or Respond to You. -To Provide Marketing Communications. -To Research and Develop Our Services. -To Personalize Your Experience. -To Facilitate Corporate Acquisitions, Mergers and Transactions.	-Within Our Corporate Organization. -With Our Vendors and Service Providers. -With Business Partners, Sponsors, and Other Third Parties. -With Professional Advisors. -During Business Transaction or Other Asset Transfers. -For Legal Compliance & Safety. -With Your Consent.
Commercial information, such as records of products or services purchased, obtained, or considered by you, transaction records, payment card information and billing address.	-To Provide Our Services. -To Provide You with Service-Related Communications. -To Comply with Our Legal and Regulatory Requirements. -To Enforce Compliance with Our Terms, Agreements and Policies. -To Detect and Prevent Fraud and Security Risks -To Provide Customer Support or Respond to You. -To Provide Marketing Communications. -To Research and Develop Our Services. -To Facilitate Corporate Acquisitions, Mergers and Transactions.	-Within Our Corporate Organization. -With Our Vendors and Service Providers. -With Business Partners, Sponsors, and Other Third Parties. -With Professional Advisors. -During Business Transaction or Other Asset Transfers. -For Legal Compliance & Safety. -With Your Consent.
Internet activity information, such as browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information.	-To Provide Our Services. -To Provide You with Service-Related Communications. -To Maintain Legal and Regulatory Compliance. -To Enforce Compliance with Our Terms, Agreements and Policies. -To Detect and Prevent Fraud and Security Risks -To Provide Customer Support or Respond to You. -To Provide Marketing Communications. -To Research and Develop Our Services. -To Personalize Your Experience. -To Facilitate Corporate Acquisitions, Mergers and Transactions.	-Within Our Corporate Organization. -With Our Vendors and Service Providers. -With Business Partners, Sponsors, and Other Third Parties. -With Professional Advisors. -During Business Transaction or Other Asset Transfers. -For Legal Compliance & Safety.
Geolocation data, to the extent you have configured your device to permit us to collect such information.	-To Provide Our Services. -To Provide You with Service-Related Communications. -To Provide Marketing Communications. -To Personalize Your Experience.	-Within Our Corporate Organization. -With Our Vendors and Service Providers. -With Business Partners, Sponsors, and Other Third Parties. -With Professional Advisors. -During Business Transaction or Other Asset Transfers. -For Legal Compliance & Safety. -With Your Consent.
Inferences drawn from any of the information listed above, such as your purchase preferences, characteristics, and behavior.	-To Provide Marketing Communications. -To Research and Develop Our Services. -To Personalize Your Experience.	-Within Our Corporate Organization. -With Our Vendors and Service Providers. -With Business Partners, Sponsors, and Other Third Parties. -With Professional Advisors. -During Business Transaction or Other Asset Transfers. -For Legal Compliance & Safety.

California Privacy Rights

California residents have the right to access, to correct, to delete, to portability, to opt-out of the sale or sharing of your personal information, to object to automated decision making (upon effective date of relevant CCPA regulations), and the right not to be discriminated against for exercising any of the rights described in this section.

At JW PEI, no decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.

If you are a California resident, to the extent your sensitive personal information (as that term is defined under the CCPA) is used to infer characteristic about you, you have the right to direct us to stop such processing of your sensitive personal information for such purposes. However, we do not process any of your sensitive personal information to infer characteristic about you.

We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age.

For more information about your rights and how to exercise them, see Section 9, Privacy Rights, above.

Retention of Personal Information

We will retain your personal information for the time period required or permitted by law or for the time reasonably necessary to achieve the purposes described in this Privacy Policy or any other notice provided at the time of collection.

Shine the Light

You may request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, contact us as provided in the “Contact Us” section below.

Do Not Track Signals

We do not currently respond to browser Do Not Track signals that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. However, we do provide consumers with the ability to manage their cookie choices as described in the “Cookie and Similar Tracking Technologies” section above.

13.  Third-Party Links

JW PEI’s Sites or communications may provide links to other websites or services that are not owned or controlled by us, including links to affiliate program sites, and social media platforms. Links to other websites do not constitute or imply an endorsement of recommendation by use of the linked website and/or content. This Privacy Policy only applies to information collected by our Sites and Services.  We are not responsible for the privacy or security practices of other websites or social media platforms or the information they may collect. You should refer to such third parties’ privacy policies on their website to determine their privacy practices.

14.  Contact Us

If you have any questions or comments about this Privacy Policy, you may contact us by email at privacy@jwpei.com.

For general questions or comments regarding this Privacy Policy, you may contact us via email at: privacy@jwpei.com.

For U.S. Users：

If you are a U.S. resident—including if you are a California resident seeking to exercise rights under the California Consumer Privacy Act (CCPA, as amended by the California Privacy Rights Act (CPRA)), or a resident of another U.S. state with applicable privacy laws—you may direct privacy-related inquiries to the email address listed above.

For EU/EEA/UK Users：

If you are a resident of the European Union, European Economic Area, and/or the United Kingdom, and you believe we process your Personal Information within the scope of the General Data Protection Regulation (“GDPR”) (applicable in the EU/EEA) or the Data Protection Act 2018 (as amended) (applicable in the UK), you may direct questions or complaints related to such processing to our GDPR Data Protection Representative.

Please note: Our GDPR Data Protection Representative is currently in the process of being finalized. The relevant contact details will be promptly updated in this Privacy Policy once confirmed.