Privacy Statement

This Privacy Statement explains how Creative Wave IT Solutions LLC , will be refer Wi5global here onwards ("Wi5global," "we," "us," or "our") collects, uses, and discloses your information. The Privacy Statement applies to all Wi5global products and services, except those products and services that have a separate privacy statement.

 Where applicable, you consent to the use of your information as described in this Privacy Statement each time you use our products or services, so we urge you to read this document in full and Contact Us if you have any questions.

Collection And Use Of Personal Information

Personal information is information that can be used to directly or indirectly identify you. Personal information also includes information that is linked to information that can be used to directly or indirectly identify you. Personal information does not include information that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you. To the extent we process de-identified information, we will maintain and use the information in de-identified form.

Here is a description of the types of personal information we may collect and how we may process it:

Collection And Use Of Personal Information

Depending on the products and services you use, we may collect and have collected, including within the preceding 12 months, different kinds of personal information from or about you:

• Personal identifiers, including name, username, email address, phone number, and mailing or shipping address.
• Commercial information, including the products or services purchased or considered by customers, information about your Western Digital account and authentication information; billing address, shipping address, and contact details.
• Financial information, including certain limited credit or debit card information.
• Personal characteristics, such as demographic data, including your location, age, gender, income level, employment, or level of education.
• General location information. Where available, our services may use GPS, the location inferred from your IP address, and other technologies to determine the approximate, location of the computers, phones, or other devices on which you install or access our products or services.
• Internet or other electronic network activity information, including browsing history, search history, and information regarding your interaction with our products and services, such as the type of device you use, your device configuration, your device's unique identifier, the IP address of your device, your operating system, the type of Internet browser that you use, usage information, diagnostic information, browsing information, session summary information, CPU and other usage statistics, API calls, service crash information, network status, storage utilization, search terms, and file attributes (including attributes for photos, videos, music, and documents).
• Professional or employment-related information, such as position, role, occupation, previous work experience or current or former employer.
• Inferences drawn from personal information, such as information about your interests or purchase preferences.
• Sensitive Personal Information, specifically credit or debit card information that is used by our payment processor to help fulfill a transaction you have requested.

In addition to the above categories of personal information, you may choose to provide us with additional personal information, such as when you create an account, fill in a form, provide us a photograph, or submit an application for employment.

How We Collect Personal Information

• Information you provide: We may collect the personal information you provide when you use our products and services, create an account, contact us, participate in a survey, participate in community discussions or chat rooms, apply for employment, sign-up to receive our marketing communications, interact with us at in-person events, or otherwise interact with us.
• Information about payments: If you make a purchase, we may collect personal information in connection with the purchase.
• Information about use of our products and services: When you use our products and services, including our websites and web, mobile, and desktop applications, or view our emails or advertisements, we may collect information from or about the computers, phones, or other devices on which you install or access our products or services. We may gather some of this information automatically. Please read our Cookie Statement for more information on how we use web tracking technologies and the choices you have.
• Information from third parties: We collect information from third parties, including business partners, marketing agencies, and service providers. This may include your contact information from marketing partners when we engage in joint marketing or co-branding activities, your IP address or location information from service providers to offer certain products and services relevant to your location, and data from your social networks to authenticate your product use with us, or that you grant permission to our products or services to access.
• Information from public sources: We may collect information from government sources and records and other publicly available information.

How We Use Your Personal Information

We may use personal information for the purposes described in this Privacy Statement. Generally speaking, we use personal information to provide, improve, develop, and personalize your experience with our products and services, to communicate with you, to offer you targeted advertisements and services, and to protect us and our users. We may do so with your consent, for compliance with a legal obligation, for the performance of a contract with you, or for our legitimate interests, to the extent permitted by applicable laws. Creative Wave IT Solutions LLC collects, processes, and determines how to process your personal information as data controller for the following purposes:

• Providing, improving, developing, and personalizing your experience with our products and services: We may use personal information to help us provide, improve, develop, and personalize your experience with our products and services. This includes using personal information for purposes such as data analysis, research, and audits. We may perform such processing based on your consent or our legitimate interest in offering you products and services and for business continuity. If you enter a sweepstakes, contest, or other promotion, we may use the personal information you provide to administer those programs. Some of these activities have additional rules, which may contain further information about how we use personal information, so we encourage you to read those rules carefully before participating.
• Communicating with you: We may use personal information to respond to your inquiries and communicate with you about important notices, including notices related to your account, products, services, transactions, or changes to our policies and terms. Such processing is undertaken because it is necessary for the performance of a contract with you or is based on our legitimate interest in interacting with you to provide you with our products and services. We may also use personal information to communicate with you about your employment requests. Our privacy notices to applicants and employees provide additional information concerning the personal information we collect and how we use personal information in connection with your employment requests. Subject to your prior express consent, we may use personal information to send you marketing communications in relation to Western Digital's own products and services, and we may share your personal information with third-party partners who may send you marketing communications in relation to their products and services. If you no longer wish to receive email communications for marketing purposes, please Contact Us to opt-out. We may use your information to process and respond to your requests when you contact us.
• Offering and measuring targeted advertisements and services: We may use personal information to provide you with personalized advertisements, including on third-party websites and applications, and to determine the effectiveness of our promotional campaigns. Please read our Cookie Statement for more information on how we use web tracking technologies for personalized advertisements and the choices you have. We may also use audience matching to reach people (or people similar to people) who used our products and services or are identified in one or more of our databases. This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own products and services, and the ad partner matching common factors between our data and their data.
• Promoting safety and security: We may use personal information to help verify accounts and user activity, as well as to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies. Such processing is undertaken because it is necessary for the performance of a contract with you or is based on our legitimate interest in helping to ensure the safety of our products and services.
• Payment processing: Our payment processor may use your personal information, including commercial, and financial information, specifically for processing payments and transaction fees related to a product or service you have requested.

For any of the uses of your data described above that require your prior express consent under applicable law, note that you may withdraw your consent by contacting us via our webform.

As a global company, Wi5global has a number of corporate affiliates in different jurisdictions. Each of these affiliates collects, processes, and determines how to process your personal information as a data controller to help provide you with the products and services you request.

Cookies And Similar Technologies

We use and have used within the preceding 12 months cookies and similar technologies to provide, protect, and improve our products and services, such as by personalizing content, understanding user behavior, and providing a safer experience. We also use these technologies to provide you with personalized advertisements, including on third-party websites and applications, and to determine the effectiveness of our promotional campaigns.

Please read our Cookie Statement to learn more about how we use cookies and web tracking technologies and the choices you have.

Disclosure Of Personal Information

We make certain personal information available to the strategic partners and other recipients described below for the purposes described in this Privacy Statement.

Service Providers and Other Companies

We may share personal information with service providers and other companies that provide services on our behalf, such as website hosting; email services; marketing; advertising; sponsoring of sweepstakes, contests, and other promotions; auditing; payment processing; fulfilling customer orders; data analytics; providing customer support; conducting customer research and satisfaction surveys; cloud storage services; and other services that assist in providing or selling our products and services. We also may share your personal information with advertisers, data analytics providers, and social media networks, which assist us with making product recommendations, marketing messaging, and sending you relevant content. These companies are obligated to protect your information and may be located wherever we operate.

Corporate Affiliates and Corporate Business Transactions

We may share personal information with all Western Digital Corporation-affiliated companies. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal information to the relevant third party.

Legal Compliance and Security

It may be necessary—by law or as a result of legal process, litigation, or requests from public or governmental authorities within or outside your country of residence—for us to disclose personal information. We may also disclose personal information if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose personal information if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.

Your Rights (Including Your California Privacy Rights)

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date. Depending on where you live, you may have the rights described below.

• Right to know the personal information that we collect, including the sources from which the personal information is collected, our purpose(s) for collection, and the categories of recipients with whom we have shared your personal information, including any sharing with third parties for their own marketing purposes
• Right to access, in a structured and standard format, the personal information that we process about you
• Right to delete your personal information
• Right to opt-out of the sale or share of your personal information to third parties
• Right to opt-out of targeted advertising, including the sharing of your personal information to third parties for cross-context behavioral advertising
• Right to opt-out of certain automated decision making
• Right to correct or rectify any inaccurate information concerning you

Exercising Your Rights

You may fill out our webform to exercise your applicable rights. We will respond to your request in the timeframe required by applicable law (and in general within 30 days).

As required by law, and to protect the privacy and security of your personal information, we may request information from you to enable us to confirm your identity and right to access such information, as well as to search for and provide you with the personal information we maintain. There are instances where applicable laws or regulatory requirements allow or require us to deny a request.

If you are a resident of California or another state or jurisdiction that provides this right, to opt-out of the sale or the sharing of your personal information by us to third parties for the uses of your data described above, including cross-context behavioral advertising:

• submit a request through the Do Not Sell or Share My Personal Information form available here, specifying you wish to opt-out of sales (such as sharing your information with our partners for audience matching purposes via means other than cookies or web tracking technologies referenced in (2) below); and
• click Cookie Preferences in the footer below and toggle the options to "No" for both "Performance and Functionality" and "Advertising" Cookie options, and click "Submit Preferences". This will deactivate performance, functionality, and advertising cookies and web tracking technologies on our site, including those used for audience matching purposes and personalized advertisements. Deactivating these cookies and web tracking technologies may only apply to the specific browser from which you click the link, and your preferences may reset if you change your settings.

 

Authorized Agent: You may authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission signed by you to make a request on your behalf, and your authorized agent additionally is able to verify their identity with us. If you are a resident of California, and would like to designate an agent for purposes of making a request, your agent must register as such with the California Secretary of State and submit a copy of this registration along with your verified consumer request. Please have your authorized agent follow the instructions above to make a request, and additionally mail your written declaration authorizing the agent to act on your behalf, certified by a notary public, to: Legal Department, 5601 Great Oaks Parkway, San Jose, California 95119 USA. If your authorized agent has power of attorney, it may not be necessary to perform these steps.

You may also contact us via phone at 888-914-9661 (PIN: 228663) to exercise your applicable rights, and you may lodge a complaint with the competent data protection authority regarding the processing of your personal information. You also may object to, or restrict, the further processing of your personal information, and appeal any decisions involving the exercise of your applicable rights. We will not discriminate against you for the exercise of your applicable rights. If you request to delete your data, this would remove your ability to access any Wi5global accounts. We have no obligation to retain your information, and we may delete any or all of your information without liability. We may retain, however, information related to you if we believe it may be necessary to prevent fraud or future abuse, if required by law, or for legitimate purposes, where applicable, such as analysis of non personal information, account recovery, maintaining the functionality or security of our systems, auditing our records, or enforcing our rights and obligations under our agreements.

Third-Party Websites And Services

Our products and services, including our websites and digital media properties, may contain links to or the ability for you to access third-party websites, products, and services. We are not responsible for the privacy practices employed by those third parties, nor are we responsible for the information or content their products and services contain. This Privacy Statement applies solely to information collected by us. We encourage you to read the privacy policies of any third parties before proceeding to use their websites, products, or services.

Information Security, Integrity, And Retention

It is important that you take precautions to protect against unauthorized access to your Wi5global products, account credentials, and computers or other devices. If you feel that the security of your account or personal information has been compromised, please immediately Contact Us. Please be aware that, despite our efforts to maintain reasonable and appropriate physical, electronic, and procedural security measures, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law.

We will store your personal information in accordance with applicable data protection law, retain such information in accordance with our data retention policy for as long as it is necessary to fulfill the purposes outlined in this Privacy Statement, and delete such information in accordance with our deletion policy unless a longer retention period is required or permitted by law, Sensitive Information shall be used for the specific transaction in which it was intended and only retained by us for the period of time needed to complete the transaction or as otherwise permitted by the user.

Children

We do not knowingly collect, use, or disclose information from children under the age of 16. If we learn that we have collected the personal information of a child under the age of 16—or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States or 14 in the People's Republic of China (which, for the purposes of this Privacy Statement, excludes the Hong Kong SAR, Macao SAR and the Taiwan region)—we will take steps to delete the information as soon as possible. Please immediately Contact Us if you become aware that a child under the age of 16 has provided us with personal information.

If you are a California resident under the age of 18, and you are a registered user of our products or services, California law permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please Contact Us with specific information about where the content or information is posted and attesting that you posted it. We will then make reasonable, good faith efforts to remove the post from prospective public view, or anonymize it so you cannot be individually identified, to the extent required by applicable law. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Information Transfers, Storage, And Processing Globally

When we share your personal information with our partners, Wi5global-affiliated companies, and service providers, your personal information may be transferred to and/or made accessible from countries out of the European Economic Area or the People's Republic of China. In such circumstances, we will enter into model contractual clauses as adopted by the European Commission or the Cyberspace Administration of China, as applicable, or rely on alternative legal bases, and implement mandatory measures to act in accordance with applicable laws (for example, creating a process to disclose additional required information to you when transferring your personal information out of the People's Republic of China). For some of our services, your personal information may be transferred to and/or stored and processed on servers located in the United States, or in other locations outside of the country where you reside for the purpose of providing the services to you.

Changes To This Privacy Statement

We may periodically change this Privacy Statement to keep pace with new technologies, industry practices, and regulatory requirements, among other reasons. We expect most such changes to be minor. Any non-material changes will take effect immediately upon posting of an updated Privacy Statement, and we will indicate the Last Modified date at the top of this document. There may, however, be cases where changes to this Privacy Statement may be more significant. In such cases, we will provide you with a prominent notice of such changes on our website or will directly send you a notification.

Your continued use of our products and services after the effective date of the Privacy Statement means that you accept the revised Privacy Statement. If you do not agree to the revised Privacy Statement, please refrain from using our products and services and Contact Us to close any account you may have created.

Contact Us

If you have any questions regarding this Privacy Statement or its implementation, you may email our Data Protection Officer (DPO) at admin@wi5global.com. You may also reach us via our webform or write to us at a location nearest you via mail addressed to: ATTN: Legal Department - Privacy Statement Question.

For customers in the European Union, we have registered our DPO with the Irish Data Protection Commission. If you have any questions or concerns about our privacy practices, we encourage you to contact our DPO at the email address above.