PaGamO Privacy Policy

Last Updated: July 20, 2020

“PaGamO website” (hereinafter referred to as “the Service”) is a service provided by BONIO INC. (hereinafter referred to as “the Company” or “we”). We attach great importance to protecting the privacy of our Members and follow the relevant laws and regulations on the protection of privacy and personal information. In order to protect your privacy and your personal information, we have formulated a Privacy and Personal Information Protection Policy for your privacy (hereinafter referred to as “Privacy Policy”). Privacy Policy will let you know what personal information is collected and how we process this data, and tell you about your personal information.

I. Scope of the Privacy Policy
  The Privacy Policy applies to the collection, processing, use, international transfer, and protection of personal information from engaging in the website and the affiliated features or services. It does not apply to websites, web pages or applications that are linked to third parties through the Service.

II. Purpose and Method of collection
  i. Purpose of collection
    The Company collects your personal information based on the business required for member marketing, customer management, internal statistics and analysis, member management and other business registrations or business made by statutes. The specific purpose of personal information of the Personal Information Protection Act:
      1. 040 Marketing (including financial cross-selling business);
      2. 063 Non-government agency to collect or process personal information under legal obligations;
      3. 069 Contract, contract-like or other legal relation matters;
      4. 090 Consumer, Customer Management and Service;
      5. 091 Consumer Protection;
      6. 098 Business and Technical Information;
      7. 101 Information(communication) services
      8. 102 Information(communication) and database management
      9. 103 Information Communication Security and Management
      10. 142 Sports and Athletic Competition Activities;
      11. 143 Sports and Recreation Business;
      12. 146 Library and Publishing Management
      13. 152 Advertisement or commercial behavior administration;
      14. 157 Investigation, statistics and research analysis;
      15. 158 Student(member) (including graduates and studying on completion of the course) data management
      16. 159 Academic Research
      17. 171 Management of other central government agencies and affiliated organizations、Public Affairs、Supervision Administrative assistance and related business.
      18. 181 Other business operation in accordance with the business registration project or organization Prospectus;
      19. 182 Other Consulting and Consultant Services;
  ii. The company’s collection method is through you to join the membership, fill out various service forms and so on. You may choose whether or not to provide personal information and the integrity of the personal information provided, but certain website functions, services or activities must be used based on the personal information provided by you. If you do not provide complete and correct personal information, some functions, services or events on the website may not be available.

III. Collected profile categories
  When you use the Services, we would collect the following types of information. Including the information which you provided and the information we receive from your use of the Service:
  i. The classification of personal information
    1. Code 001 Type for identifying individuals: Such as name, address, phone, photo, email, etc.
    2. Code 002 Type for identifying finance: Such as bank account numbers and names, credit or debit card numbers, other personal numbers or accounts, etc.
    3. Code 003 Type for identifying in government data: Such as the number of personal ID card.
    4. Code 011 Individual description: Such as age, gender, date of birth, etc.
    5. Code 038 Occupation: Such as a driver, a principal, a teacher and other professional information.
    6. Code 051 School records:Such as the information about universities ,colleges and other school information.
    7. Code 064 Working experiences:Such As previous work and military service information.
    8. Code 132 Information unclassified:Such as files, reports, etc.
    9. The Company's website management system will record user’s information including your IP address, browser, time of browse the web, and save the relevant information according to Personal Information Protection Act. The Company will use cookies for website management and record your activity records. These cookies are stored in the browser directory of your computer. Only websites that set cookies for the Company can read their contents. You can use your browser settings to know when cookies are set or refuse cookies.
  ii. Sensitive Personal Information:
    1. C021 Family situation:such as information about marital status, children.
    2. C024 Other social relationships:such as information about friends and colleagues.
    3. C035 Leisure activities and interests:such as hobbies, sports and other information.
    4. C036 Lifestyle:Information such as the types of consumer goods used and details of services.

IV. Base on the purpose of the service provided by the company or this website, the company will collect your personal information in the following situations:
  1. Membership(hereinafter referred to as “Membership”, including but not limited to “Player Membership”、“Teacher Membership”、“Parent Membership”、“Business Users Membership (Staff, HR, etc.)”.
    (1) Player Membership:
      When you apply for membership as a player, you will be required to fill in your personal information, including name, gender, birthday, email and other related information, and set your account and password so that you can log in to use the membership services.
    (2) Teacher Membership:
      When you apply for membership as a teacher, you will be asked to fill in your personal information, including name, gender, birthday, email, teacher ID, teaching school and other related information, and other related information, and set your account and password, so that you can log in to use the membership’s services in the future.
    (3) Parent membership:
      When you apply for membership as a parent, you will be required to fill in your personal information, including name, phone, e-mail address, address and other relevant information, and set your account and password so that you can log in to use the membership in the future Services.
    (4) Business User Membership:
      When you apply for membership as a business user, you will be asked to provide your personal information, including name, phone, e-mail address, job number, title, department, business and other related information, and set your account and password so that you can log in to use membership’s services in the future.
  2. Online events, live events, competitive events
    If you provide personal information, member account or password for participating in online events or online surveys organized by the company, you will also be protected by the privacy policy.
  3. Browse the web
    When you browse or inquire on this website or affiliated websites, the web server will automatically record the IP address, time and related records of your connection. These data are only used for network flow statistics analysis and network service optimization in order to improve the service quality of this website. These data are only used for the analysis of the total amount, and will not connect with specific individuals.
  4. Other
    In addition to the personal information you provide directly, you may also actively provide personal information at the company's partner companies, and provide your personal information to the company with your consent or for the purpose of performing the contract. This information will only be used and processed within the scope of the services you agree to or for the performance of the contract, and will not be used for other purposes.

V. Period, Parties and Ways of using the personal Information
  1. Period of using the personal information
    The Company, Facil Ltd. Co., other subsidiaries and affiliated companies will process and utilize your personal information during the operation period.
  2. Region of using the personal information
    The Taiwan region and the regions providing services on this website and its affiliated websites will not be transferred to other regions. Members' personal information will be used worldwide.
  3. Data subject using the personal information
    Except as otherwise provided by the Act, it will be used within the scope of the service you agree to and within the scope of the Service, and will not arbitrarily transfer your personal information to other third-parties for other purposes. However, based on the purpose of the performance of the contract, the Company will provide relevant information to the related companies, co-organizers and cooperative manufacturers within the scope necessary for the Company to entrust or provide relevant services.
  4. Ways of using the personal information
    In addition to the scope of the collection of personal information and the requirements of the law, the Company will use the following according to your actual needs:
    (1) Member Information
      Through the member information provided by you when you join the member, we can deliver the Services to you and to give you customer support.
    (2) Statistics and analysis
      We use the personal information provided by you and the records generated by the server during the site to improve and provide personalized the Services and to develop the Service, and serve as a basis for future design of member activities.
    (3) Promotion, marketing, and service
      We use your information to send you Service notifications and respond to you when you contact us. We also use your information to promote the marketing of the Company or our partner services, including but not limited to newsletters, emails, mobile newsletters and community website notifications. We will use the information you provide to offer your member services and benefits (for example, organizing events).
    (4) For use in government administration, or justice.
      Based on the notice from the government, we will provide all the information you have on the Service.

VI. The rights and methods for exercising personal information of members
  1. You can request to acquire, recruit or correct your personal information at any time by logging this website or by email.
  2. Right to delete– the right to ask us to delete your personal information.
  3. Right to restrict- the right to request that we temporarily or permanently stop processing all or some of your personal information.
  4. Right to object- after you agree to our use of your personal information, and you have the right to object to our processing of your personal information at any time based on your special circumstances, and through your right to object to our processing of your personal information.
  5. Right to data portability- the right to request a copy of your personal information in electronic format and the right to transmit that personal information for use in another party’s service.
  6. Right not to be subject to Automated decision-making- the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce similarly significant effect.
  7. Regarding the exercise of the relevant rights of this article, you can contact us through the website settings or by email (Email: security@bonio.com.tw).
  8. If you have any questions or dissatisfaction with the privacy policy, our terms of use, the personal information you log in or related use, holding, disclosure or transmission or you want to know more about our data protection policies and security measures, please contact our Data Protection Officer by email (Email: security@bonio.com.tw)

VII. Personal information sharing and disclosure
  1. We do not sell or share your personal information with any third parties. We will only disclose or share your personal information in the following circumstances with your consent. You can also partially disclose your personal data through the service settings. You understand that the public data can be spread broadly and you give your consent that we are not responsible for the subsequent use or misuse by unintended third party recipients.
    1. When our website (PaGamO), our company (Bonio), Fácil, subsidiaries and related companies host online events, competitions and other activities, we may share user data with third parties who need access to such personal data to carry out work.
    2. When you sign up for PaGamO and enter a class, the teacher can export for education and administration purposes your personal information, including the name, school, class and the amount of time you spent on the platform.
    3. When you access this platform via brand-related activities or corporate education, we may share your personal data under a contract between the two parties.
  2. We may use certain trusted third-party companies and personal services to help us provide, analyze, and improve services (including, but not limited to, data storage, maintenance services, database management, network analysis, payment processing, and service functions Improvement). These third parties may have access to your personal information, but only when performing such operations on our behalf, and subject to similar provisions to this privacy policy.
  3. We will also share your personal information with third-party applications after obtaining your consent. For example, when you choose to access our services through applications, etc., we do not control how such third parties use your personal information. Take any responsibility for the data, so make sure that the app is trusted and that its privacy policy is acceptable to you.
  4. In the following cases, we will check the member's personal information, including but not limited to commodity transaction records and telecommunication records, etc. And may provide it to the relevant government agency, or a third party who claims that their rights and interests have been infringed, and provides reasonable evidence, If necessary, may suspend your account, access rights, and suspension of all or part of the service to you:
    (1) Obtain your explicit authorization in advance.
    (2) We must obtain your personal information in order to provide the products or services you need.
    (3) Disclosure of personal information in accordance with the provisions of this clause.
    (4) Comply with laws and regulations, or in accordance with orders or requirements of judicial authorities or other relevant government agencies.
    (5) In order to implement this clause, or you may violate the terms of this agreement or other agreed matters or infringe the rights of third parties.
    (6) The purpose is to maintain the security of the service system or the legitimate rights and interests of the operator.
    (7) To protect the legitimate rights and interests of other service users or other third parties.
    (8) To protect the legitimate rights and interests of the company and its affiliates.
    (9) To maintain the normal operation of this service system.

VIII. International transfer of personal information
  If you are not a user located in Taiwan, for the purposes and activities of Articles 3 to 6, we need to transfer your personal information to Taiwan / Japan or the region / country where the service provider maintains the facility. You agree to collect, use and transmit such personal information to the regions / countries where Taiwan and Japan or their service providers maintain facilities, and you understand that whether they are transmitted to Taiwan / Japan or the regions / countries where their service providers maintain facilities , We will take appropriate safeguards to protect your data.

IX. Information about minors under seven years of age
  This service may not apply to minors under seven years of age. We will not knowingly collect or retain personal information of minors under seven years of age, and the service is not provided to persons under seven years of age. If minors under seven years of age has impersonated another person or forged personal information to establish and use an account, we will remove or delete all personal information provided by minors under seven years of age.

X. Data Controller and Data Protection Officer
  Your personal information collected by our company is controlled by the BONIO INC.(address:11F.-1, No. 9, Sec. 2, Roosevelt Rd., Zhongzheng Dist., Taipei City 100, Taiwan (R.O.C.), you can contact our Data Protection Officer at the following email address: security@bonio.com.tw).

XI. Personal information security maintenance
  1. Regarding your personal information files, the company will adopt appropriate security measures and try our best to handle security maintenance matters with reasonable technology and measures in accordance with relevant laws and regulations to prevent your personal information from being stolen, tampered with, damaged, lost or lost Leaks and other events that harmed members' rights and interests occurred.
  2. In accordance with the privacy policy, you can notify our data protection officer (Email: security@bonio.com.tw) at any time by email to revoke your consent to our use, storage, disclosure or transmission of your personal information. However, please note that withdrawal of such consents may prevent us from continuing to provide services or fulfill our contractual obligations, including but not limited to terminating your use of this website.

XII. Personal information preservation and deletion
  1. Only when we must provide you with services and necessary business purposes, for example, we only retain your personal information such as maintaining the effectiveness of the services of this website, making data-driven business decisions related to new features and products, complying with our legal obligations, and resolving disputes. As long as you are a user of this website service, we will continue to retain some of your personal information. For example, we keep your account information.
  2. If you request, we will delete or anonymize the data, making it impossible for others to identify you through the data, unless the law allows or requires us to maintain certain personal information, circumstances include:
    (1) If your account has unresolved issues, such as outstanding balances on your account or unresolved claims or disputes, we will retain the necessary personal information until the issue is resolved.
    (2) If we must retain personal information to fulfil our legal, tax, auditing and accounting obligations, we will retain the necessary personal information for the period required by applicable law.
    (3) In response to our legitimate business interests, such as preventing fraud or maintaining user safety.

XIII. Changes to the privacy policy
  We may occasionally make changes to this Policy. When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Service or by sending you an email. We may notify you in advance. When you continue to use this website or its affiliated features or services after any modification or change of the privacy policy, it means that you have read, understood and agree to accept the modified or changed content of the privacy policy.