This Privacy Statement describes how The Webster Inc. and its affiliates (“Webster”) may collect information from or about you when you visit this website (www.webster.net.cn) and other Webster websites that display or link to this Privacy Statement.

Webster values your privacy, and is providing this Privacy Statement to explain what information we collect and how that information may be used by Webster when you interact with Webster online.

In some countries, your use of Webster’s website could be considered consent by you to Webster’s use of this information. If you do not want us to collect or use your information as set out in this Privacy Statement, please do not use our websites or provide us with your information.

Please take a few minutes to review this Privacy Statement. If you have any questions about this Privacy Statement, please contact us.

This Privacy Statement includes the following:
Who Is Collecting Your Information
What Information We Collect
Additional Information for EU-based Users
Additional Information for California Residents
How Webster May Use and Share Your Information
Location of Information
Use of Special Features or Areas of Our Website
Children’s Privacy
Security
External Links
Changes to This Privacy Statement
Your Choices
Access, Update or Correct Your Personal Information
Contact Webster

Who Is Collecting Your Information

Information collected through www.webster.net.cn is maintained by The Webster Inc., Global Webster Center, 919 North Market Street, Suite 950, Wilmington, New Castle, DE, and/or Webster’s affiliates. Webster can be reached through the contact information provided at the end of this Privacy Statement.

What Information We Collect

When you interact with Webster online or in response to Webster’s marketing communications, Webster collects “Personal Data” about you, by which we mean information that may identify you personally, either alone or in combination with other information available to Webster. Information that we collect includes the following:

Information You Provide.

      We collect the personal information you knowingly provide by completing an online form, registering for information or services, applying for a job, or otherwise sending to us. For example, if you sign up to receive e-mail communications from one of our businesses, we collect your e-mail address and any related information you provide. If you communicate with us using the “Contact Us” feature, we collect the information you provide when you complete the “Contact Us” form.

      This includes information such as your name, email or physical address, or other contact details, or other records or copies of your correspondence with us (including emails).

      If you send or receive e-mail communications from Webster, we will collect your e-mail address and any related information you provide.

      If you communicate with Webster using the “Contact Us” feature, we collect the information you provide when you complete the “Contact Us” form.

Supplemental Information.

     In some cases, Webster may also collect information about you from other sources, and combine the information that you provide us online with other information that we have due to your relationship with Webster.

      For example, if you are a Webster customer or supplier, we may use the information you have provided us both online and through our broader business relationships to improve your online experience.

Cookies and similar devices

      We and our service providers use cookies, pixels, log files and other mechanisms to gather information about your use of our website, mobile apps and social media properties.

Cookies
A cookie is a text file of letters and numbers that we store on your browser or the hard drive of your computer. Our website uses cookies—in combination with pixels, local storage objects, and similar devices—for various purposes, including to enable a faster log-in process, to make it easier for you to navigate the website, to distinguish you from other users, and to provide you with a more personalized experience. When you visit our website, strictly necessary cookies will be placed on your device; strictly necessary cookies do not require your consent. For performance, functional and targeting cookies, we request your consent before placing them on your device. At any time, you can change your preferences for performance, functional and targeting cookies by using our Cookie preference tool. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our website. The Help function of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies. For more information about managing, deleting or blocking cookies, please visit: https://www.aboutcookies.org/ how-to-manage-and-delete-cookies and https://www.allaboutcookies.org/ manage-cookies/.

Clear GIFs, pixel tags, web beacons and other technologies
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, assist us with delivering cookies on this website, collect anonymous information about the use of this website by our visitors, deliver customized or targeted content to you on this website and through our partners, and/or help us manage online advertising by collecting information related to which advertisements drive traffic to our website. We may place clear GIFs on this website directly, and we may place clear GIFs on behalf of the partner whose branding appears on this website or its service providers. The information collected by web beacons does not identify you personally. However, if you have created a user identity on one of your visits to this website, for example, by making a purchase, we may link the information we collect using web beacons to the information that identifies you personally and use it in the same ways as we use the information we collect using cookies. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, to identify when our emails are viewed, and to track whether our emails are forwarded.

Log files
Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.

Third-party analytics
Our website may also use automated devices and applications, such as Google Analytics (more info here) to evaluate the use of our website. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the information they collect about you on our website with other information they have collected for their own purposes. This Privacy Statement does not cover such uses of data by third parties. For more information on how such third parties collect and use information on our behalf, and to manage your privacy choices and advertising preferences with such third parties, please refer to their respective privacy policies—e.g., see LinkedIn’s Privacy Policy (and advertising preferences), Twitter’s Privacy Policy (and interest-based opt-out policy), Facebook's Data Policy (and ad preferences), Google’s/Youtube’s Privacy and Terms (and ad personalization settings), Instagram’s Data Policy (and ad preferences), and Adobe’s Experience Cloud Privacy Policy (and privacy choices). You can opt-out of having your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on.

Do-not-track signals
Our website does not respond to do-not-track signals. For more information about do-not-track signals, please click here.You may, however, disable certain tracking as discussed above (e.g., by disabling cookies).

Additional Information for EU-based Users 

Data protection regulations in Europe require Webster to disclose additional information regarding Personal Data collected from European users, and to limit Webster’s use of such information in specific ways. This section provides additional information applicable to European Personal Data, which may not apply to users in other geographies.

Legal Basis for Processing.
European Personal Data may only be processed by Webster where and to the extent that such processing is Necessary for the performance of a contract with you, such as

      To carry out Webster’s obligations with respect to any contractual agreements between us with respect to information, products, and services that you may request from Webster;

      To process a job application; orTo fulfill any other agreements between us.

      Necessary for Webster to comply with a legal obligation, for example to meet our tax and accounting obligation

      Necessary to serve the legitimate business interests of Webster or a third party, where such use is consistent with the fundamental rights of individuals under European law, for example:

    To provide you with effective customer service or technical support, such as where you have requested information from Webster;To contact you with information regarding health and safety, applicable regulations, or stewardship of our products;

      To improve the content, functionality, performance, security and usability of our website;

      To notify you about changes to our business, products, services, or our website;

      To conduct business transactions, including purchases and sales of Webster products, or business reorganizations including the sale, transfer, change in control or merger of Webster assets or businesses.

    Subject to a valid consent you have freely provided and not withdrawn, such as opt-in consents allowing Webster to place cookies on your computer or to use your contact information for promotional advertising.

Data Subject Rights.
      European users of this website have the legal right to request Webster undertake specific actions with respect to their Personal Data, including:

      The right to request access to your Personal Data, including the right to have Webster confirm if your Personal Data is being used by Webster;

      The right to have your Personal Data corrected or erased;

      The right to object to or restrict Webster’s use of your Personal Data, for example where such information is not accurate or no longer needed;

      The right to have your Personal Data transferred from Webster to another party;

      The right to not be subject to automated decision-making or profiling based on your Personal Data;

      The right to withdraw any consent you have previously provided to Webster’s collection or use of your Personal Data; and

      The right to lodge a complaint with a supervisory authority.

Cross-Border Transfers of Data.
The information that Webster collects from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may be processed by staff operating outside the EEA who work for us, or by other entities acting as data processors on our behalf. Webster has implemented international data transfer agreements on the basis of the European Commission’s Standard Contractual Clauses in order to provide appropriate and suitable safeguards for the transfer of this information. You may request a copy of the Standard Contractual Clauses by contacting the privacy contact for your geographic region listed below.

Data Retention.
      Webster will process and store your Personal Data for the duration of our relationship with you, which may be a long term, and as long as necessary to fulfill our contractual and legal obligations. Webster will delete your data:

      When it is no longer necessary for the purposes for which that information was collected and processed;

      Upon your request or objection, provided there are no overriding legal grounds requiring Webster to maintain that information;

      When necessary to comply with Webster’s legal obligations; and

      If our collection of information was based on your consent, upon the withdrawal of your consent.

      Any requests or inquiries relating to Webster’s handling of EU information may be made by contacting us.

Additional Information for California Residents

The California Consumer Privacy Act of 2018 (the “CCPA”) requires Webster to disclose certain additional information to California residents. This Section provides such additional information applicable to visitors, users and others who reside in the State of California, which may not apply to users in other geographies.

Information We Collect.
Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	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 (Cal. Civ. Code § 1798.80(e)).	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.	YES
C. Protected classification characteristics under California 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
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, 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.	NO

Personal Information does not include:

      Publicly available information from government records.

      Deidentified or aggregated consumer information.

      Information excluded from the CCPA's scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

How We Collect Information About You.
We obtain the categories of Personal Information listed above either directly from you (e.g., from forms you complete or products and services you purchase) or indirectly from you (e.g., from observing your actions on our website).

Use of Personal Information.
We may use the Personal Information we collect for any legitimate and lawful business purpose, including those listed in the Section below titled “How Webster May Use and Share Your Information.”

Sharing Personal Information.
We may share your Personal Information as described in the Section below titled “How Webster May Use and Share Your Information.”

Disclosures of Personal Information for a Business Purpose.
In the preceding twelve (12) months, Webster has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial Information.

Category F: Internet or other similar network activity.

Sales of Personal Information.
In the preceding twelve (12) months, Webster has not sold any Personal Information.

Your Rights and Choices.
The CCPA provides California residents with specific rights regarding their personal information. The following describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights.
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

      The categories of personal information we collected about you.

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

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

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

      The specific pieces of personal information we collected about you (also called a data portability request).

    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.

Deletion Request Rights.
You have the right to request that Webster delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

      Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

         Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

         Debug products to identify and repair errors that impair existing intended functionality.

         Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

         Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

         Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

         Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

         Comply with a legal obligation.

         Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

         Calling us at 1-302-416-6799

         Emailing us at webster_tech@sohu.com.

         Filling out the form in Contact us.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

      Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

      Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), 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 twelve (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. For data portability requests, 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 without hindrance. 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.

Non-Discrimination.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

      Deny you goods or services.

      Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

      Provide you a different level or quality of goods or services.

      Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How Webster May Use and Share Your Information

Subject to applicable local law, Webster may use the personal information we collect through our website for any legitimate and lawful business purpose, including but not limited to the following:

      to provide products, information and services you request;

      to provide you with effective customer service or technical support;

      to contact you with information regarding health and safety, applicable regulations, or stewardship of our products;

      to improve the content, functionality, performance and usability of our website;

      to improve our marketing and promotional efforts;

      to provide technical support and troubleshooting; and

      for security, credit or fraud prevention purposes;

      for any other purpose identified in an applicable privacy statement or other agreement you may have with Webster.

Webster may use or disclose aggregated or anonymized data about our users, if that information does not identify any individual, in Webster’s sole discretion.

Webster may share your information with Webster affiliates for the purposes set forth in this Privacy Statement. Webster may also share your information with third parties in specific cases such as:

       Our Service Providers. We may share your personal information with companies or organizations, including subsidiaries, affiliates, and other entities that perform services on our behalf, such as marketing and website support service providers.

      Business Transactions and Transfers. Webster may buy, sell, form, or otherwise reorganize one or more of its businesses or sell stock or assets, for example, as the result of a sale, merger, reorganization or liquidation. A transaction of this type may involve the disclosure of your information to prospective purchasers or partners who have signed a confidentiality agreement with Webster.

     Compliance with Laws and Protection of Our Rights and the Rights of Others. We may disclose personal information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose personal information to cooperate with a government investigation; to prevent or investigate a possible crime, such as fraud or identity theft; to enforce or apply our online terms of use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

      Other than as described above, Webster does not provide or sell your personal information to third parties.

Location of Information

Webster is a global organization with its corporate headquarters in the United States. Our servers, databases, and service providers are located in the United States and in other countries. Different countries have different privacy laws and requirements, and some, including the United States, may provide less legal protection for your personal information than others. If you object to the transfer of your information to the United States, please do not use Webster’s website or provide Webster with that information.

Use of Special Features or Areas of Our Website

This Privacy Statement may be supplemented by additional privacy statements that may be specific to individual Webster websites or features, such as our investor and career sites. Webster’s websites may include special features such as surveys, licensed content, online stores, or password protected areas, such as a customer-only area or a careers area, and these areas or websites may be subject to additional terms of use or privacy statements which may further specify additional personal information Webster may collect in these areas, why we need that information, and choices you may have about the use of that information. For more information please see our Global Customer Privacy Notice.

When you sign up to use a special feature or password-protected area, you may be asked to agree to additional terms governing your use of the special feature or password-protected area. In such cases, you may be asked to expressly consent to the additional terms, for example, by checking a box or clicking on a button marked “I agree.” (This type of agreement is known as a “click-through” agreement.) If any of the terms of a click-through agreement or another agreement between you and Webster are different than the terms of this Privacy Statement, the terms of that agreement will control over this Privacy Statement.

Children's Privacy

Webster’s website is not intended for children under 16 years of age, and Webster does not knowingly collect information from children to sell or promote our products or services. No one under the age of 16 may provide information to Webster on or through our website, and if we learn that we have received information from a child under the age of 16, we will delete that information.

Webster may host educational programs in science for students and teachers in our communities, but we do not invite minors to contact us or provide us with personal information. Visitors must be 18 years of age or older to submit registration or survey information. Parents or legal guardians may register to obtain information or participate in a survey on behalf of their children.

If you believe a child under the age of eighteen has sent personal contact information to Webster, please contact us immediately and we will use reasonable efforts to promptly remove that information from our systems.

Security

We take commercially reasonable precautions to protect the confidentiality, integrity and security of your personal information. We urge users to be careful with personal information while using the Internet.

SSL Protection. Many Webster websites, including Webster.com, are able to provide a secure connection between your computer and our server be established. We use an encryption technology called Secure Socket Layers (SSL). A secure connection is maintained until you leave the secure area of the site. Although we use SSL encryption to safeguard the confidentiality of personal information as it travels over the Internet, “perfect security” does not exist on the Internet and we cannot guarantee the safety of transmitting personal information over the Internet.

Password Protection. You are responsible for maintaining the confidentiality of your passwords. We have the right to assume that anyone accessing one of our websites using a password assigned to you has the right to do so. You will be solely responsible for the activities of anyone accessing our website using a password assigned to you, even if the individual is not, in fact authorized by you. If you have reason to believe that your password has been compromised or used without authorization, you must promptly change it using the functionality provided on the site or notify Webster that your account has been compromised.

External Links

Some of our websites may contain links to other websites on the Internet that are not under the control of or maintained by Webster. Such links do not constitute an endorsement by Webster of those websites, the content displayed, or the persons or entities associated with them. By visiting a linked website from a Webster website, you acknowledge that Webster is providing these links to you only as a convenience and you agree that Webster is not responsible for the content of such websites. External sites are governed by their own terms and policies and are not governed by Webster's Privacy Statement, Terms of Use, Accessibility Statement, or other terms and policies.

Changes to This Privacy Statement

We reserve the right to modify this Privacy Statement and related business practices at any time by posting updated text on this site and updated effective date at the bottom of this page. As we add new features and functionality to our websites or Webster policies or applicable laws evolve, we may need to update or revise this Privacy Statement. We reserve the right to do so, at any time and without prior notice, by posting a revised version on our website. These changes will be effective as of the date we post a revised version on our website.

If we make changes to this Privacy Statement that materially change how we treat your personal data, we will make a reasonable effort to notify you promptly through reasonable means.

Your Choices

We respect your right to make choices about how you would like to interact with Webster and the extent of the personal information you choose to share with Webster. In some cases, we will ask you to indicate your choices at the time we collect your personal information. If you have previously agreed to receive email or marketing communications from Webster, you may "opt-out" at any time by using the unsubscribe feature included in the e-mails we send.

Access, Update or Correct Your Personal Information

If you have created an account or a personal profile on one of our websites, you may be able to access and update some or all of your personal information on your account settings or profile page. If you wish to access, update or correct other personal information, please contact us. We will contact you and may ask you for additional information to verify your identity. In most cases, we will update information as requested. In some cases, however, we may limit or deny your request if permitted or required by law or if we are unable to verify your identity.

Contact Webster

If you have any questions about this Privacy Statement or our privacy practices, you may contact us by phone at the numbers listed at https://www.webster.net.cn. You may also contact us via email.

If you have concerns that someone affiliated with Webster has used your information in a manner that is not appropriate, you may also contact us in Webster website. You can also be accessed using an online form that provides the option of submitting a written report. In addition, you always have the option of contacting with the online form or via email webster_tech@sohu.com.

 

 

 

Effective Date: December 12, 2019