PRIVACY POLICY

Your privacy is important to us at Untitled. We respect your privacy regarding any
information we may collect from you across our website.

CHAPTER 1

GENERAL PROVISIONS

Article 1. Scope of regulation

This Privacy Policy regulates how BEST WAY CORPORATION (EWAY) and other affiliates of Best Way Corporation collect and use Customer personal information in relation to its website, products and services (hereafter referred to as “Our products”).
This Privacy Policy does not apply to any products, services, websites or any contents provided by Third Party or other Parties who use their own Privacy Policy.
This Privacy Policy includes:
1. General Provisions
2. Types of Data We collect
3. Purposes for Data Collection
4. Methods of Data Collection
5. Data Storage and Deletion Procedures
6. Limitations on Information Security Obligations
7. Policy Content Updates
8. Effective Date

Article 2. Subject of application

This Policy applies to all Customer (including related persons of Customers) related to Our products.
Our Board of Directors, officers and employees.
Other related subjects.

Article 3. Definitions

For the purposes of this Policy and within its scope, the following terms shall be understood and defined as follows:

“We” means Best Way Corporation and other affiliates of Best Way Corporation.
Affiliates mean any Parent Company, Subsidiary Company, other Subsidiary Company of the Parent Company or any Company that controls or is controlled, by Best Way Corporation.
Personal information means the information for determining the identity of particular person.
Customer means persons who are in relation to our websites, products, services.
Related persons of the Customer are persons who have a direct or indirect relationship to Customers.
The subject of personal information is the person identified from that personal information.
Processing personal information means performance of some actions including: collection, editing, use, storage, provision, sharing, spread of personal information on the internet for commercial purposes.
Personal data is information in the form of symbols, writing, numbers, images, music or similar forms in the electronic environment associated with a particular person or help identify a particular person. Personal data includes basic personal data and sensitive personal data.
Personal data is information in the form of symbols, writing, numbers, images, music or similar forms in the electronic environment associated with a particular person or help identify a particular person. Personal data includes basic personal data and sensitive personal data.

CHAPTER 2

TYPE OF DATA WE COLLECT

Article 4. Personal information we collect

We collect Customer information in provision process of our products.
The collection of Customer information when Customer perform activities related to our products shall be conducted according to this Privacy Policy and and in compliance with the data protection regulations of relevant legal jurisdictions.

Article 5. Source of information we collect

Information Sources
1. Information provided by Customer: We directly collect information from Customers through our Products that Customers access.
2. Automatic information: We automatically collect certain types of information when Customers interact with our products.
3. Information from other sources: We may gather information about Customers from other sources, including service providers, financial organizations, social networking platforms, and publicly available sources, in compliance with legal regulations.
Information from other sources: We may gather information about Customers from other sources, including service providers, financial organizations, social networking platforms, and publicly available sources, in compliance with legal regulations.

Article 6. Specific types of information we collect

Personal data includes both basic personal data and sensitive personal data.
1. Basic personal data includes:
  1. First name, middle name, last name, and other names (if any);
  2. Date of birth; Date of death or date of disappearance;
  3. Gender;
  4. Place of birth, place of birth registration, permanent address, temporary address, current address, contact address;
  5. Nationality;
  6. Images of individuals;
  7. Phone number, ID card number, personal identification number, passport number, driver's license number, license plate number, personal tax code number, social insurance number, health insurance card number;
  8. Marital status;
  9. Information about family relationships (parents, children);
  10. Information about individual digital accounts; Personal data reflects activities and history of activities in cyberspace;
  11. Other information that pertains to a particular person or helps identify a particular person.
2. Sensitive personal data is personal data associated with an individual's privacy rights that, when violated, will directly affect the individual's legitimate rights and interests, including
  1. Political opinions, religious beliefs;
  2. Health status and personal life recorded in medical records, excluding blood type information;
  3. Information related to racial origin and ethnic origin;
  4. Information about an individual's inherited or acquired genetic characteristics;
  5. Information about physical attributes and biological characteristics of individuals;
  6. Information about individual's sex life and sexual orientation;
  7. Data on crimes and criminal acts collected and stored by law enforcement agencies;
  8. Customer information of credit institution, branch of foreign bank, organization providing intermediary payment services, other permitted organizations, including: Customer identity information according to the regulation, account information, information of deposit, asset, transaction, information about the organizations, individuals who are guarantor at credit institutions, branch of foreign bank, organization providing intermediary payment service;
  9. Data about an individual's location determined through location services;
  10. Other personal data regulated by law to be specific and requiring necessary security measures.
Browser data
1. Data related to technical systems such as devices, operating systems, browsers can include: language, access time, browser version, account name and other types of data, as well as other relevant information.
2. Data related to Customer’s areas of interest: advertising information, cookie data, browser history, behavior with direct marketing information and other types of related data as well as other relevant information
Customer database
Social network link
Cookies
1. Cookies are used to allow us or Third Parties, with our permission, to collect or share information related to Customer use of Our products. These features will help us improve the products and services we provide, as well as in delivering improved experiences when customers interact with us.
2. Cookies are unique identifiers sent by our server to the Customer's computer or mobile device when accessing our website. This information is used to track and deliver content tailored to Customer’s interests and to perform data analysis and or monitor the use of our products and services.

We may simultaneously collect various types of information and aggregate customer data to perform assessments and analyses in compliance with applicable legal regulations.

CHAPTER 3

PURPOSES FOR DATA COLLECTION

Article 7. Purposes for Data Collection

We may utilize the personal information of the customer to provide and optimize our products, thereby enhancing customer experiences.

To operate and provide our products, we may use Customer’s personal information to operate, process and analyze our products.
To measure, evaluate and improve our products: we may use Customer’s personal information to measure usage, analyze performance, fix errors, support and develop our products.
The processing of this information is based on our legitimate interests in measuring, evaluating, and improving our products.
To provide recommendations and personalize Customer’s experiences when interacting with and using our products: We may utilize the customer's personal information to suggest our products of potential interest, identify customer preferences, and personalize customer experiences with our products.
The processing of this information is based on:
1. Our desire to provide personalized recommendations and experiences to our Customer and
2. Customer's consent to comply with applicable legal requirements.
To comply with legal obligations: in some cases, we are legally obliged to collect, use or store Customer personal information or need to process certain types of personal information to ensure legal compliance.
Processing of this information is necessary for us to comply with relevant legal obligations for Our legitimate interests in the security and collection of data in compliance with applicable legal regulations.
To contact customers: We may use the customer's personal information to establish contact with the customer regarding our products through various communication methods and to respond to inquiries and address customer complaints. This includes reaching out to customers and their relevant parties to convey necessary or urgent information.
The purposes of processing this information are necessary to:
1. Enable us to carry out the duties and obligations in compliance with our Customer Rights and Protection Policy;
2. Serve our legitimate interests in meeting customer requests and ensuring the delivery of our products to customers with the best possible experience while still adhering to legal regulations concerning the collection and security of personal information data;
3. Ensure compliance with our legal obligations to provide required legal notices to Customers.
For marketing and advertising purposes : We may use the customer's personal information to promote our products in accordance with legal regulations. We may collect and analyze the gathered information to personalize our products in line with customer interests, thus displaying advertisements of our products based on customer preferences.
The purposes of processing this information are based on;
1. Our lawful rights and interests in marketing our products, and
2. Customer's consent as required by applicable regulations.
To prevent fraud, money laundering, and terrorist financing, and detect other risks for Customers: We may use Customer personal information to prevent and detect fraud or fraud risks to protect customers, ourselves, and other relevant entities.
The processing of this information is based on:
1. Our obligation to take measures to comply with the legal regulatory documents that apply to us, and
2. The desire to provide a safer experience environment for customers

CHAPTER 4

METHODS OF DATA COLLECTION

Article 8. Methods of Data Collection

Data processing
1. Data processing encompasses one or more operations involving data, including but not limited to collection, recording, analysis, validation, storage, modification, disclosure, combination, access, retrieval, erasure, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, annulment, or other related activities.
2. Processing of Customer data will be carried out in accordance with the data collection purposes mentioned in this Privacy Policy.
3. Data processing relies on the explicit, voluntary, and affirmative consent of the customer in accordance with this Privacy Policy, our Customer Rights and Protection Policy, and applicable legal provisions.
4. Data processing relies on the explicit, voluntary, and affirmative consent of the customer in accordance with this Privacy Policy, our Customer Rights and Protection Policy, and applicable legal provisions.
Collect data directly from Customer
1. When Customers register an account on Our Website
2. When Customers fill out survey information
3. When Customers interact with us through contact and communication
4. Collection from Cookies
5. Collection from other sources in compliance with legal regulations.
Direct Data Collection from Third Parties, including service providers for analytics and surveys, advertising businesses, marketing entities, search tools, Affiliates, and Third parties related to our business services.

CHAPTER 5

HOW PERSONAL DATA INFORMATION IS STORED, PROTECTED, AND DESTROYED

Article 9. Data Storage and Deletion Procedures

We store and protect customer information according to the following principles:
1. Compliance with the data storage and protection methods as defined in this Privacy Policy and adherence to relevant legal regulations.
2. The company and/or third parties permitted by the company to collect, store, and protect customer information must ensure the safety and security of customer information as per the provisions in this Privacy Policy, Customer Rights and Protection Policy, and compliance with other relevant legal regulations.
3. In cases where third parties are permitted by the company to carry out the storage and protection of customer information, such storage and protection shall adhere to the policies of the third party rather than this policy, and it will be the independent responsibility of the respective third party.
Customer information can be deleted from our storage system upon request from the customer in the following cases:
1. Customer information can be deleted from our storage system upon request from the customer in the following cases:
2. When the Customers withdraws their consent
3. When the Customer realizes that the Customer information is being collected and used for the wrong purpose that the Customer initially agreed to
We will not perform deletion of information upon customer request in the following cases:
1. Compliance with legal regulations on storing Customer information
2. Information is considered public information according to the law.

CHAPTER 7

CASES OF PROCESSING PERSONAL INFORMATION WITHOUT CUSTOMER CONSENT

Article 10. Cases where we process data without the Customer's consent

In an emergency, it is necessary to immediately process relevant Customer information to protect the life, health, and property of the Customer or others. In such case, we and the relevant Parties are responsible for explaining the emergency situation.
Processing Customer information is mandatory and confidential according to law or at the request of competent authorities.
Processing Customer information according to legal requests of competent authorities in emergencies related to national defense, national security, riots, terrorism and crime.

CHAPTER 8

LIMITATION OF OUR RESPONSIBILITY FOR CUSTOMER INFORMATION PROTECTION

Article 11. Limitation of our responsibility to protect Customer information

We commit to the best of our abilities and within the scope of legal compliance to ensure the highest level of security for customer information in terms of personnel, technology, and other relevant factors. It is important to note that this commitment does not apply in cases of force majeure.
Our products may be linked to third-party products with our authorization. These linked products have their own Privacy Policies and independent security measures, over which we have no control or influence. We shall not assume any responsibility for the content, security measures, or the absence of security measures, or the operations of these linked products. Therefore, we strongly advise Customers to thoroughly review the Privacy Policies of these linked products before using them or providing any information.

CHAPTER 9

POLICY UPDATE

Article 12. Policy Update

We reserve the right to regulate, modify, or supplement the contents of this Privacy Policy at any time while ensuring compliance with prevailing legal regulations.
Any changes to this Privacy Policy will be communicated to customers through the posting of such modifications or a revised Privacy Policy. To the extent permitted by law, Customer's continued use, and access to our products, is considered an agreement to the alterations made in this Privacy Policy.
This Privacy Policy takes effect from the date it is approved by management and publicly announced on our system.
Other issues arising out of this Policy shall be resolved according to our Policy of Right and Customer Protection or related regulation.