Privacy Policy

Updated on Dec 1st, 2024

At Wigain, we are fully aware of how much the personal data is important to our customers and developers (hereinafter referred to as “user” or “users”), coworkers and partners. Wigain abides by applicable privacy laws and regulations to protect your personal data. This Privacy Policy describes what personal data we collect, how we acquire it, what purpose we collect and use it, who we share it with, how we transfer it, when and how we destroy it, and what measures we take to protect your personal data.

1. General rules and definitions

This Privacy Policy explains how Wigain collects, uses, discloses, processes and protects your personal data. In addition to viewing our newly released products and updates on our product, you can also register for an user account or pre-order the Wigain products on our product.

Please note that our product may include links to third parties, such as payment service providers, purchase service providers and community service provides. Clicking these links will take you out of the Wigain service area. Wigain is not responsible for the privacy protection practices of such third parties. We recommend that you exercise caution and read the Privacy Policy of each product you visit. This Privacy Policy applies to the Wigain product only.

Wigain is made up of different legal entities. When we mention “Wigain”, we are referring to the relevant company listed in Section 15 “Wigain Group Entities” of this Privacy Policy, as amended from time to time. For your visits to our product and related activities conducted via or interacted with our product, Wigain Inc is responsible for processing your personal data under this Privacy Policy (the “Controller” under the GDPR or any equivalent concept under applicable privacy laws). The Controller detail is set out in the appendix “Who controls your personal data”.

"Personal data" means any data that directly identifies an individual, such as a person’s name or profile photo, as well as any information which may not directly identify an individual but when combined with other information can be easily used to identify an individual, such as the serial number on a product pre-ordered on our product.

Some of the content described below may not comprise “personal data” but is included in this Privacy Policy to ensure better protection of your rights. Aggregated data is not considered personal data for the purposes of this Privacy Policy.

We may revise this Privacy Policy according to the changes of laws, regulations, and our services. Policy updates will be communicated to you via our product, applications, or email.

2. Personal data we may collect and method of collection

Wigain collects personal data within the minimum scope necessary to provide our services. We only collect personal data necessary for the provision of services via our product when you sign up for or use our services.

Website browsing

When you browse our website, we may collect the following information: log files and usage data, including IP address, NID, ENID, IDE, time and date of access, browsing history, and browsing and clicking behavior.

We may also use cookies and other technologies to collect analytics and usage information. For more information, please see 8. Cookies and other similar technologies below.

Website signing up and logging in

When you sign up for an user‘s account and log in to use our product, we may collect the following information: the user name, log-in password, and email address you provide when you create your user account.

Products pre-ordering

For customers, when you submit an order to pre-order our products via our product, we may collect the following information: the name, phone number, address, postal code, email address, and invoice information (if any) that you provide when submitting your order.

Post-sales and customer services

For customers, when you use our post-sales and customer services, we may collect the following information:

  • User information: Your name and contact information (such as phone number, address, postal code, email address, etc.).
  • Device information: Serial number (SN) of the product you purchased.
  • Other information: Order information (such as order number, etc.) and valid purchase certificate.

Developer community services

For developers, when you browse our developer community and submit questions or other information, we may collect the following information: the user ID, email address, avatar, device information, time zone, time and date of access, user posts and comments.

Wigain does not collect highly sensitive personal data, such as information that may reveal your ideology, belief, labor union or political party affiliation, political opinion, health, or sexual orientation.

Your options

You may opt out from providing certain types of information. This, however, may cause restrictions in using some of our services. When we request your information, we will try to help you accurately understand and make decisions on these restrictions. If you need further information, please feel free to contact us with Wigain@wigain.com.

Methods of collecting your personal data

When we collect personal data, we always inform you in advance and request your consent. We may collect personal data

  1. Via our product directly from you when you use our service, e.g., when you create a user account on our product;
  2. Via online and/or offline communications with you, e.g., through our product, email, facsimile, mail, phone calls, or in cases where you participate in Wigain events; or
  3. Via business exchanges with you or your employees.

3. Purpose of collecting and using personal data

Wigain process your personal data for specific purposes and process only the personal data relevant for achieving that purpose. Depending on our relationship with you and the products and services provided, we use collected personal data for following purposes:

  1. To help you better understand our products and services;
  2. To enable users sign up and log in, to enable customers complete the pre-order smoothly including placing the order, paying for the order, and receiving our products and after-sales services, and to enable developers browse, post and comment on developer community.
  3. To improve and optimize the service experience and product performance based on your usage of our service.
  4. To administer a customer survey of your opinions on our products and services after asking for your separate consent.
  5. To provide information on promotions and deals as a way of direct marketing communications.
  6. To perform advert campaign and relevant advertising effectiveness measurement.
  7. To prevent and take actions against behaviors that hinders normal services operation, such as theft of account information and illegal usage of user account.
  8. Abide by laws and regulations.
  9. To protect the rights, assets, or safety of Wigain, its subsidiaries, affiliates, employees, business partners, or customers.

4. Sharing of personal data

In order to provide you with more convenient and prompt services, we may share your personal data with our partners or assign part of our businesses to other companies. We will not provide your personal data to a third party without prior consent from you except in cases where disclosure is permitted by law. We may share your personal data with the following categories of third parties:

  1. Our affiliates: as a global company, in order to maintain business operations and offer our services to you, we may need to share your personal data with Wigain affiliates listed in Section 15 “Wigain Group Entities” at the end of this Privacy Policy, as amended from time to time.
  2. Third-party service providers and business partners: to provide you with our services described in this Privacy Policy, we may, where necessary, share your personal information with our third-party service providers and business partners, including:
  • Google LLC: provides cloud storage and data analysis service, as well as advert campaign and measurement. For more information about Google LLC, you can visit: https://policies.google.cn/privacy?hl=en
  • Amazon Web Services Inc.: provides cloud storage. For more information about Amazon Web Services Inc., you can visit: https://aws.amazon.com/privacy/

Wigain may also share your personal data in the following cases:

  1. Where disclosure is required by court order, law enforcement authority, or administrative agency pursuant to lawful procedures in order to protect Wigain and/or your rights.
  2. Where a third party or Wigain is engaged in an acquisition or a merger. In this case, Wigain will inform the acquirer that your personal data is to be used only in accordance with this Privacy Policy.
  3. Wigain may also disclose your information in cases where it purchases or sells its business or assets. In this case, Wigain may disclose your personal data to the potential seller or purchaser. In cases where a third party acquires Wigain or substantial part of its assets, the personal data held by us may become a part of the assets transferred. The third company which acquires our assets may acquire a part or the whole of this business. They may not in the same line of business as ours. In addition, your personal data may be transferred to a successor which has an interest in cases of business restructuring, liquidation, or management.

5. Cross-border transfer of personal data

Generally, we will process your personal data in the country/region where we conduct business or provide products and services. However, we may transfer your personal data to other country/region that may have different laws for the protection of personal data. We will take all necessary measures to protect your personal data in accordance with this Privacy Policy and applicable law.

More information on international transfers we are required under applicable data protection laws can be found here.

6. Retention and destruction of personal data

In principle, Wigain destroys collected personal data without delay as soon as the purpose of the collection and usage of the personal data is achieved. Personal data stored in a procedure file format will be erased by a technical tool which prevents the recovery of the information. Personal data printed in a paper record, print media, or a document is destroyed into scrap or by incineration.

Where continued keeping of the personal data is required by law, personal data will be stored and managed separately from other personal data and not used for any purposes other than the purpose of fulfilling mandatory legal obligations.

7. Security of personal data

We will protect your personal data with appropriate security measures to prevent accidental disclosure or theft of your personal data such as hacking and prevent the personal data from being used, accessed, changed, or disclosed without your permission.

In addition, Wigain restricts the number of staff in charge of handling personal data to the minimum level and provides training so that our staff comply with the confidentiality obligations to safeguard your personal data.

8. Cookies and other similar technologies

Wigain and its service providers or other third parties may place cookies in your web browsers when you visit our product to provide you with convenience when using our product. You have the right to refuse this service.

A cookie is a small text file that a product stores in your computers. Cookies are widely used to operate the product or operate it in a more efficient manner and transmit information to the owner of the product. Cookies may be used to store items such as identifier and user preferences. product may install cookies in used browsers in cases where allowed by the browser’s preferences.

The following types of cookies may be used when you visit Wigain product:

Essential cookies

These cookies are necessary for the product to function and cannot be switched off without affecting the use of the site. These cookies are usually only set in response to specific actions you take on the site, such as filling in forms or setting your cookie preferences. We use these cookies as we believe it is in both our and your legitimate interests to enable the site to function properly. You can set your browser to block or alert you to these cookies, but some parts of the product will not work without them. We embed Wigain essential cookies to remember your language and theme preferences on your first visit to the product. We also embed AUTH0 cookies to authenticate customers to reach the product. These cookies secure the product against people who are interested in attacking information technology systems. For more information about AUTH0 cookies, please visit: https://auth0.com/docs/secure/data-privacy-and-compliance and https://www.okta.com/privacy-policy/.

Analytics cookies

We embed Wigain analytics cookies to save the user’s search history in order to provide a better service experience and count the online activity of customers in order to improve the quality of the product services. We also embed Google Analytics cookies to monitor how users reach the product, and how you interact and move around once on the product. These cookies let us know what features on the product are working the best and what can be improved. For more information about Google Analytics cookies, please visit: https://policies.google.com/technologies/types.

Advertising cookies

We embed Google advertising cookies to collect information about your online activities and interests and provide you with advertisements that correlate most highly to your profile and interests. They are used to build a profile of your interests and show relevant ads on other product. You can opt-out of having your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on. For more information about Google advertising cookies, please visit: https://policies.google.com/technologies/types.

Most devices and browsers also provide a way to set your cookie preferences. These settings are usually found in the "options", "preferences" or "settings" menu of your browser. You can also find information on how to disable or manage your browser's cookies by consulting the cookie policies of the following browsers:

  • Google Chrome
  • Microsoft Edge
  • Microsoft Internet Explorer
  • Opera
  • Apple Safari
  • Firefox

9. Connection to a third-party product and services

Third-party content may be part of, or accessible through Wigain, which may include without limitation links to third-party products and services. We are not responsible for the practices employed by third-party products linked to or from the services, nor the information or content contained therein. Your browsing and interaction on any other product or service is subject to that third party’s own rules and policies. Please make sure to read over those rules and policies before proceeding.

10. Your rights

You have rights to protect your personal data. If you would like to exercise any of the following rights, please contact us with wigain2021@gamil.com.

  1. You have the right to refuse to receive marketing messages from us. You can exercise this right by clicking the “cancel subscription” or “opt out” link in the marketing emails from us. To opt out from other marketing types of communications (such as mails, direct marketing, etc.), please contact our customer service to connect with our staff in charge of personal data protection.
  2. You also have the following rights (these rights are subject to several conditions and exceptions):
  • Request for access, correction, and deletion of your personal data;
  • Objection to the handling of your personal data, request to prevent such handling, and/or request of transparent treatment of your personal data;
  • Erasing your personal data.
  1. In a case where Wigain collected and handled your personal data by acquiring your consent, you can withdraw the consent at any time. Withdrawal of the consent does not affect the legality of the handling performed prior to the withdrawal and the handling of personal data on a legal basis other than the consent as well.
  2. You have the right to file a complaint with the data protection authority on our collecting and handling of your personal data. For further details, please contact your regional data protection authority.

You and your legal representatives can request perusal, correction, deletion, suspension of handling, and withdrawal of consent for the personal data of you or those of minors, whenever you want to. In a case where you request the correction of wrong personal data, Wigain does not provide the information to a third party or use the personal data concerned until the completion of the correction. Furthermore, in a case where the wrong personal data has been provided to a third party, we will transmit the corrected information to the third party.

You are asked to fill in correct and true personal data. You are liable for the accidents due to wrong information filled in by yourself. In cases where you use other persons’ information illegally, you may lose membership.

You have the obligation to protect your own personal data from leakage and not to infringe on other person’s information as well as every right to protect your personal data.

11. Protection of minors

We consider it the responsibility of the parent or guardian to supervise the child's use of our services. However, we do not offer services directly to a child or use the personal data of children for the purposes of marketing.

If you are a parent or guardian and you believe that the minor has provided Wigain with personal information, please contact us to ensure that the personal information is removed immediately.

12. Updates on this Privacy Policy

Wigain may revise this Privacy Policy to reflect related laws or changes in services. In cases where there are additions, deletions, and/or revisions of this Privacy Policy, we will publish the effective time and the updates on our product or via email communication.

13. Language

For your convenience, this Privacy Policy is written in English and your native language. We will do our best to keep the content of the two versions of Privacy Policy consistent. In case of discrepancies between the English text version and any courtesy translation, the English version shall prevail.

14. Contact us

As per queries, complaints, feedbacks or other matters on personal data protection which arise from the use of our product, please contact us with wigain2021@gmail.com. Wigain will listen to your opinions and do its best to respond to the queries without delay.

15. Wigain Group Entities

  1. Hangzhou Wigain Plan Technology Co., Ltd, which has its registered office at 5th Floor, Building 4, Alibaba Park, 699 Wangshang Road, Binjiang District, Hangzhou City, Zhejiang Province, China.
  2. Hong Kong Wigain Technology Co., Ltd, which has its registered office at Room 5003, 5th Floor, Beneficial Centre, 45 Yuen Road, Kwun Tong, Hong Kong.

16. Additional information for Certain Jurisdictions

We provide additional information about the Controller(s) of your personal data and the contact details of the Representative and Data Protection Officer where applicable, legal bases, safeguards we rely on for transferring your personal data outside the Country/Region of Origin, and your legal rights for certain jurisdictions.

16.1 U.S.

1. Your legal rights

Residents of Particular States.

Residents of certain states, including California, Connecticut, Colorado, Utah, and Virginia have certain rights in relation to their personal information pursuant to applicable state consumer privacy laws.

Information we collect

The information we have collected about California and other state residents in the last 12 months is described in personal data we collect and method of collection section above. That information corresponds with the following categories of personal information:

CATEGORY EXAMPLE COLLECTED

A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES

B. Personal information categories listed in the California Customer Records statute (e.g., Cal. Civ. Code § 1798.80(e)) and similar statutes from other states. A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories. NO

C. Protected classification characteristics under state or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO

D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES

F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a product, application, or advertisement. YES

G. Geolocation data. Physical location or movements. NO

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO

I. Professional or employment-related information. Current or past job history or performance evaluations. NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO

K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

In the last 12 months, we have collected personal information from the sources described in personal data we collect and method of collection section above.

Use of personal information

In the last 12 months, we have used your personal information for the business and commercial purposes described in personal data we collect and method of collection and sharing of personal data sections above.

Sharing of personal information


The business and commercial purposes that we have shared your personal information in the last 12 months are described above in Sharing of personal data. More specific information on that sharing is as follows:

1) Sharing your personal information for business purposes. We have shared the following categories of personal information with our affiliated companies, service providers and public or government (including enforcement) authorities for our business purposes:

• Category A: Identifiers.

• Category D: Commercial information.

• Category F: Internet or other similar network activity.

• Category K: Inferences drawn from other personal information.

As described above, examples of business purposes include performing transactions, registering accounts, managing our relationship with you, and monitoring for security threats and fraud.


2) Sharing your personal information for commercial or other purposes: We have shared the following categories of your personal information with co-sponsors, business partners and other third parties in a manner that is likely to be considered to be a “sale” under the California or other state privacy laws:

• Category A: Identifiers.

• Category D: Commercial information.

• Category F: Internet or other similar network activity.

• Category K: Inferences drawn from other personal information.


Your right to know. You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we verify your request, we will disclose to you:

1.The categories of personal information we collected about you.

2.The categories of sources for the personal information we collected about you.

3.Our business or commercial purpose for collecting or selling that personal information.

4.The categories of third parties with whom we share that personal information.

5.If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.


Your right to obtain a copy of your personal information.

You have a right to obtain a copy of the specific pieces of personal information we collected about you (also called a data portability request). Once we verify your request, we will provide you a copy of your personal information that is responsive to your request.


Your right to delete your personal information.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.


Your right to opt-out of sale of your information or sharing for cross-context behavioral advertising or targeted advertising.

We will only disclose your personal Information to third parties as described in this section or otherwise with your prior consent. To provide convenient and prompt services, Wigain may disclose your Personal Information to third parties for a business purpose to provide you with the Services and to facilitate our operations. To control which of your Personal Information Wigain discloses to third parties, please submit your request to us with wigain2021@gmail.com.


How to exercise your US state privacy rights

To exercise your right to know, right to obtain a copy, or right to delete your personal information as described above, please submit your request to us with wigain2021@gmail.com.


How we verify requests and respond to requests

Before fulfilling your request, we take steps to verify you are who you say you are or that you have authority to act upon someone else’s behalf. Therefore, upon receipt of your request, we will request additional information that we need to verify you and, if you are submitting a request on behalf of someone else, to verify that you are permitted to act on that person’s behalf.

When we contact you to request verification information, please respond and provide the information that we have requested. Depending on the nature of the request you make, we may require you to verify your identity to either a reasonable degree of certainty or high degree of certainty. This may mean that we need to match two or three pieces of information that we hold about you with information that you provide to us. In some cases, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request or that you are authorized to make the request on behalf of someone else.

In addition to providing the information we need to verify you or your authority, you must provide us with enough information so that we can understand, evaluate, and respond to your request. We cannot respond to your request or provide you with personal information if we cannot confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request and to locate relevant information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and to understand, evaluate, and respond to your request.

We cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by US state privacy laws (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.


1.Who may submit requests?

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make request on behalf of your minor child. You may designate an authorized agent to make a request on your behalf by following the processes required by your particular state.

2.How often you can submit requests?

You may make a privacy rights request twice within a 12-month period.

3.Response timing and format

We make every attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your personal information, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity easily.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

4.Non-discrimination

We will not discriminate against you for exercising any of your US state privacy rights. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.

5.Right to appeal

You have the right to appeal any decision regarding your privacy rights. To exercise your right to appeal, please submit your request to us with Wigain2021@gmail.com.

6.Other California privacy rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits customers of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to wigain2021@gmail.com.