Privacy Policy

Terms of Service

Welcome to the OOOPEN Lab Service (the “Services”), established and operated by 超開放股份有限公司 OOOPEN Lab Inc. (collectively, “OOOPEN Lab”, the "Company", “we”, “our”, or “us”). Unless otherwise specified, the use of “you” (or similar words like “your”) and “user” or “users” refers to the person(s) or entity using the Services (as defined below), subject to these Terms (as defined below). If you accept these Terms on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that entity or other legal entity to these Terms and, in such event, “you” and “your” will refer and apply to that entity.

The Services are made available on a membership-only basis and require user registration and acceptance of these terms and conditions as stated herein, including (1) our Privacy Policy and (2) any other legal notices or other rules, policies, and procedures relating to the Services that we may publish from time to time (the “Documentation”), which shall both be incorporated herein by reference (collectively, the “Terms”).

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.

These Terms constitute a legally binding agreement between you and the Company and govern your use of the Services. You are required to read these Terms carefully prior to completing your registration or using the Services, which includes your use of (https://ooopenlab.cc/) (the “Website”).

The Services are the sole property of OOOPEN Lab. OOOPEN Lab reserves the right to make changes to the Services or updates to these Terms, including adding to or modifying the Services and suspending, discontinuing, or otherwise terminating your access to all or a portion of the Services, with or without advance notice or cause, and at any time based on OOOPEN Lab’s sole discretion.

It is your responsibility to review these Terms periodically for updates thereto. Accessing and/or using the Services in any manner constitutes your express acceptance and agreement to these Terms at all times. If you disagree with or wish to reject any portion of these Terms at any time, you will become ineligible for membership and therefore agree to immediately cease all access to and/or use of the Services. Notwithstanding the foregoing, your continued use of the Services shall mean that you expressly accept and agree to these Terms and any subsequent updates thereto upon their posting date.

MCP and ChatGPT connections

When you choose to connect OOOPEN Lab's Model Context Protocol (MCP) service through ChatGPT, the prompts or tool requests you make in ChatGPT and the quiz data returned by tools may be processed by OpenAI to provide ChatGPT and the connection.

The connection uses OOOPEN Lab platform OAuth. We use your platform account identifier, email address, and the login sessions and OAuth tokens needed to authenticate the connection.

To operate the service and analyze MCP use, OOOPEN Lab records tool-usage telemetry in mcpToolEvents, including the account identifier, tool name, result category, and request duration. Where applicable, it also records a quiz identifier, module, input-error field, recommendation or template selection, and template-lookup summaries. These events have a 90-day retention period.

1. Definition

1.1 The Company will collect the following five types of information (collectively referred to as "User Information") in accordance with this Privacy Policy.

1.1.1 “Personal Data” is any information that relates to an identified or identifiable individual. For the purposes of the GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

1.1.2 Data entered to create the Interactive Content: All data entered when using the Interactive Content module tool service.

1.1.3 Cookies: Small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

1.1.4 Google Analytics/Facebook Pixel/Plausible and other website analysis tool data: refers to the data automatically collected by the company using Google Analytics or Facebook Pixel or Plausible tools, by using this service or from the infrastructure of this website (including but not limited to: the time you spend on the web page, the use of data and other value-added services, data connection time, duration, data source and destination, etc.).Usage Data: Refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).

1.1.5 Usage Data: Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

1.2 “Data Controller”, for the purposes of the General Data Protection Regulation (the GDPR ), refers to the Company as the legal person who alone or jointly with others determines the purposes and means of the processing of Personal Data.

1.3 “Device” means any device that can access the Service such as a computer, a cell phone or a digital tablet.

1.4 “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

[For Users Located in Thailand]

Data Controller & Data Processor Definitions

1.2 "Data Controller": Refers to the entity that alone or jointly with others determines the purposes and means of personal data processing.

(1) For platform member account registration data, transaction/payment data, and operational data, the Company is the Data Controller.

(2) For player interactive content input data collected by Creators through the Services, the Creator is the Data Controller.

1.4 "Data Processor":

(1) For player interactive content input data collected by Creators, the Company is commissioned by the Creator as a technical service platform to act as a Data Processor, storing and processing data according to the Creator's settings and operations within the functionality provided by the Services.

(2) Refers to third-party vendors hired or commissioned by the Company to process data on behalf of the Company.

1.5 "Website" refers to OOOPEN Lab, accessible from https://ooopenlab.cc/

1.6 "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

2. Website Analytics

2.1 By using the OOOPEN Lab’s Service, you agree, at your option, to authorize us to use the Google Analytics system, Facebook Pixel, Plausible or other analytics software (hereinafter collectively referred to as “Data Analytics Tools”) to obtain User Information necessary for the provision of the OOOPEN Lab’s Service.

2.2 You agree that the Company and the companies that operate Google Analytics, Facebook Pixel or other analytics software have the right to collect, process and use your User Information in accordance with this Privacy Policy. The Company may also use the functionalities of these analytics tools to serve you advertisements when you use Google, Facebook, or other social media services.

[For Users Located in Japan]

External Transmission Disclosures

2.3 The Company maintains an “External Transmission Disclosures” page for external transmissions associated with the Services. It discloses the data items transmitted by each tool, the names of the recipients, and the purposes for which the Company and the recipients use the data. This policy and the website footer provide links to that page. Where the external transmission rules under Japan’s Telecommunications Business Act apply, the Company follows the requirements of that Act.

3. Social Media Platform Account

To enable the functionality of the OOOPEN Lab’s Service, you agree to authorize the Company to collect your registration data from your Facebook, Google, LINE accounts, in order to obtain the necessary information to provide you with the service.

4. Call Recordings

To assist in training staff, improve service quality, and clarify contract matters, when you contact the Company’s customer service personnel, you agree that the Company may record your calls.

5. Collection and Use of User Information

5.1 In order to continue improving our service, the Company will collect the following personally identifiable information from you for the purposes of providing services, marketing, advertising, profitability, and business analysis. Personally identifiable information may include, but is not limited to:

5.1.1 Name

5.1.2 Gender

5.1.3 Date of Birth

5.1.4 Nationality

5.1.5 ID Number or Passport Number

5.1.6 Mobile Phone Number

5.1.7 FAX Number

5.1.8 E-mail

5.1.9 Residential Address or Contact Address

5.1.10 Credit Card Information

5.1.11 Bank Account

5.1.12 Your Website Usage Records (Cookies), Browser Cookies, Transaction Records on the OOOPEN Lab's Service, Usage Data Records, Time Spent on the Website and Mouse Usage Statistics or other Internet Usage Records

5.1.13 Within the scope necessary to use this service, if you do not reside in California, USA, you voluntarily provide the company or self-release public medical records, medical treatment, genes, sexual life, health examinations, criminal records and other personal information stipulated in Article 6 of the Personal Data Protection Act

5.1.14 Other information required by the Data Analytics Tools mentioned in the Article 2 to analyze your user experience

5.1.15 Other data necessary for providing the OOOPEN Lab's Service

5.2 For the duration of your membership on the Website, including any period of dispute with the Company, the Company will process and use the User Information collected in the preceding paragraph within the Republic of China, Taiwan or the country or region where the Company’s overseas branch is located for the following purposes:

5.2.1 To facilitate your access to the OOOPEN Lab's Service

5.2.2 To provide you with promotional materials for products or services offered by the Company or its partners; to offer relevant discounts or promotions in response to various services; or for other advertising or business management purposes

5.2.3 Trend analysis

5.2.4 Consumer behavior research (including but not limited to: studying operational behavior data, conducting interview invitations, etc.)

5.2.5 Advertising, profit, and business analysis

5.2.6 Legal transactions of personal information

5.2.7 Membership management and services

5.2.8 Consumer and customer management and services

5.2.9 Consumer protection

5.2.10 Processing any payment instructions you request; inquiring about payment information; collecting payments from you; or providing other financial services

5.2.11 Business and technical information

5.2.12 Information (communication) services

5.2.13 Information (communications) and database management

5.2.14 Analyzing your usage of the OOOPEN Lab's Service, assessing your credit or payment status, or conducting other investigations, statistics, and research analyses

5.2.15 Prevention and deterrence of criminal activities

5.2.16 Compliance with relevant laws and regulations

5.2.17 Other operations within the scope of business as defined in the business registration or articles of association

5.3 You may choose how much information you wish to disclose to the OOOPEN Lab’s Service. However, you may not be able to utilize the full services of the OOOPEN Lab’s Service if you choose not to provide certain information. If you fail to provide the information necessary to use the OOOPEN Lab’s Service, the Company may be unable to provide the full scope of services of the OOOPEN Lab’s Service without any compensation or indemnity.

5.4 The Company will collect, process, and use your personal information in a good faith manner. Any collection, processing, or use of your personal information will be reasonably related to the purpose of collection as specified in the Privacy Policy and will not exceed the scope necessary for the specific purpose. The extent of information collected will be proportionate with respect to the scope necessary to achieve the specific purposes stated.

5.5 Usage Data

5.5.1 Usage Data is collected automatically when using the Service.

5.5.2 Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

5.5.3 When You access the Service by or through a mobile device, the Company may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

5.5.4 The Company may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

5.6 The cookies set on the Company’s website are only used to collect your browsing history and do not collect your personal information. These cookies are below:

5.6.1 Tracking Technologies and Cookies

The Company uses Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies The Company uses may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity). Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

5.6.2 The Company uses both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

Type:Session Cookies

Administered by:Us

Purpose:These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

Type:Persistent Cookies

Administered by:Us

Purpose:These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

Type:Persistent Cookies

Administered by:Us

Purpose:These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

• Tracking and Performance Cookies

Type:Persistent Cookies

Administered by:Third-Parties

Purpose:These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

5.7 In the majority of cases, services will be paired with those provided by GOOGLE/Meta Pixel and are subject to GOOGLE/Meta's cookie policies. If you refuse to allow access to Cookies or decline to consent to the Company's or GOOGLE/Meta Pixel's cookie policies, the Company may be unable to provide the full range of services. You fully understand and agree that the Company shall not be liable for any compensation or damages.

For GOOGLE's cookie policy, please refer to: https://policies.google.com/technologies/cookies

For Meta's cookie policy, please refer to: https://www.facebook.com/privacy/policies/cookies

6. Sharing of User Information

6.1 You agree that the Company may share your User Information with third parties under the following circumstances:

6.1.1 Sharing with service providers: In order to provide you with the OOOPEN Lab's Service, the Company may share your User Information with service providers, partners or business associates in connection with the OOOPEN Lab's Service. This may be done by recording and analyzing your use of the services provided by the Company to improve the quality of the services provided by the Company or to contact you

6.1.2 Sharing with financial institutions: We may share your user data with banks, financial institutions, and credit reporting agencies to provide you with financial services

6.1.3 Sharing with business partners: The Company may share your User Information with business partners in order to provide you with a particular product, service or promotional information

6.1.4 With other members: To provide you our service, the Company may share User Information among members. When you use the OOOPEN Lab's Service to share your personal information and interact with other members, the information provided by you will be viewed by other members and may be publicly disseminated outside the Website

6.1.5 Sharing with professional consultants: We may share your User Information with our collaborating professional consultants

6.1.6 Sharing with affiliates: The Company may share your User Information with the Company's parent company, subsidiaries, branches, or other companies with which the Company has other controlling or subordinate relationships

6.1.7 Sharing with law enforcement agencies: We may, in accordance with the law, provide administrative or judicial authorities with the user data you have stored while using our service

6.1.8 Business transfers: The Company may share or transfer your User Information in the event of a merger, sale of the Company's assets, acquisition of all or part of the Company's business by a third party, or in the course of the foregoing negotiations

6.2 In addition to the preceding paragraphs, if the Company wishes to share your personal information to a third party in any other way, the Company shall obtain your prior consent.

6.3 You agree that the Company may process and utilize your personal data for the purpose of market analysis. In accordance with the provisions of Article 5, "Collection and Use of User Data," your personal data may be used by the Company for market analysis, optimization, or marketing purposes related to its services.

6.4 When third parties use your User Information, they should comply with the privacy terms or policies provided by the third party. However, the Company cannot guarantee that third parties will comply with this Privacy Policy.

7. Retention of User Information

7.1 The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. The Company will retain and use your Personal Data for an extended period of time to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws, the court orders or the request of the administration), resolve disputes, and enforce our legal agreements and policies.

7.2 The Company will retain your Usage Data for internal analysis in order to enhance the security and convenience of the OOOPEN Lab’s Service. The retention period of this data is not limited to the previous period. You may request the Company to delete all links, copies, duplicates, and ensure data portability of your personal information.

8. Transfer of Your Personal Data

8.1 Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

[For Users Located in Japan]

Cross-Border Data Processing

8.1 To provide the Services, the Company uses Google Cloud Platform (GCP) cloud regions in Taiwan (asia-east1) and Hong Kong (asia-east2) to store and process your personal data. The personal data protection systems in the countries or regions where the data is stored or processed may differ from those in your location. The Company handles the data in accordance with applicable laws. Where providing data to an overseas third party legally requires the data subject’s consent, the Company will, before providing the data, explain the recipient’s country or region, its personal data protection system, and the safeguards adopted by the recipient, and obtain the necessary consent.

8.2 Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

[For Users Located in Thailand]

Cross-Border Data Transfer & Security Standards

The Company may transfer personal data of Thai users to servers located in Google Cloud Platform (GCP) Taiwan region (asia-east1) and Hong Kong region (asia-east2) for storage and processing. The Company strictly complies with Sections 28 and 29 of the Thai PDPA, adopting Standard Contractual Clauses (SCCs) recognized by the Personal Data Protection Committee (PDPC) or appropriate safeguards.

8.3 The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

9. Disclosure of Your Personal Data

9.1 The Company is obligated to keep confidential your transaction records and other relevant information that it knows or holds due to transactions, and can only use them in compliance with the User Terms and this Privacy Policy.

9.2 If the Company violates the obligations stated above and improperly uses the data, resulting in harm to you, it shall be liable for compensation in accordance with relevant laws such as the Consumer Protection Act. However, this does not apply in cases below:

9.2.1 Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

9.2.2 Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

9.2.3 Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

10. Data Security

10.1 The company uses Google Cloud Platform servers and other firewalls, encryption technology, sophisticated technical equipment and security protection measures to save your user information to prevent your personal information from being stolen, tampered with, damaged, lost or leaked.

10.2 However, you understand that neither Internet transmission nor electronic storage is 100% secure and agree that the Company will not be liable if your personal information is stolen, altered, damaged, destroyed or leaked by a third party despite the security measures the Company has taken to protect it.

10.3 For the security of your data, you understand that when transferring files, messages, passwords or processing other data when using this service, you need to pay attention to data security to avoid malicious intrusion or theft of your data by third parties.

11. Detailed Information on the Processing of Your Personal Data

The Service Providers the Company uses may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on our Service in accordance with their Privacy Policies.

11.1 Analytics

The Company may use third-party Service providers to monitor and analyze the use of our Service.

• Google Analytics,

• Facebook Pixel,

• Plausible, and;

• Other website analysis tool

11.2 Email Marketing

The Company may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us

11.3 Payments

The Company may provide paid products and/or services within the Service. In that case, The Company may use third-party services for payment processing (e.g. payment processors).

The Company will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by Payment Card Industry Data Security Standards (PCI-DSS) as managed by the PCI Security Standards Council (PCI SSC), which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

12. Advertising and Links to Third Party Websites or Resources

12.1 The Company has the right to place or embed advertisements or provide any links to third party websites or resources in the OOOPEN Lab’s Service. However, the Company is not responsible for the content, products, or services on the advertisements or linked third party websites or resources listed or embedded in the OOOPEN Lab’s Service. You agree to bear all risks arising from the use of any third-party website or resource, and you are solely responsible for such use.

12.2 You agree that the Company may from time to time send electronic newsletters, product or service messages (EDM) to the e-mail you provide to the Company. After you have replied to the refusal to accept marketing in the manner prescribed by the Company and confirmed by the Company, the Company will cease to send further marketing messages.

12.3 You acknowledge and agree that all cooperation projects via the OOOPEN Lab’s Service are authorized to be used by the Company or the OOOPEN Lab’s Service as a way to promote and market the Company and the Platform’s services. The utilization methods include but are not limited to: publicly transmitting cooperation projects on the Company’s social media platforms, and showcasing them in promotional presentations during speeches.

13. Change to this Privacy Policy

13.1 The Company will update this Privacy Policy every 12 months.

13.2 You agree that the Company has the right to change or adjust the contents of this Privacy Policy at any time. The Company will announce the changes on the Website and/or the Services and notify you by email to the email address listed on your member account. By continuing to use the Services, you agree to be bound by all changes to this Privacy Policy.

13.3 If you do not agree to any of the adjustments or changes of this Privacy Policy, or the country or territory to which you belong excludes all or part of the contents of these Terms, you agree to immediately cease use of the Website and the Services.

14. Right to Personal Data Requests

14.1 You may exercise the following rights with respect to the personal data you provide to the Company by contacting the company through the contact information provided in Article 20 of this Privacy Policy. If sent in writing, the Company will process the request within 30 days of receipt, or notify the reasons for the delay in writing (including but not limited to email) if unable to process within 30 days:

14.1.1 To make inquiries or requests for access

14.1.2 To request a copy

14.1.3 Request for supplement or correction

14.1.4 Request to stop collecting, processing or using

14.1.5 Request for deletion and agree to follow the operating procedures and processing time established by the Company

14.1.6 Request to cease sending advertising messages from the Company or third parties

14.1.7 Review the Company’s policies and practices regarding personal data

[For Users Located in Thailand]

Data Subject Rights Supplement

If the Company processes personal data based on your consent, you have the right to withdraw consent at any time (without affecting the lawfulness of processing prior to withdrawal). Additionally, if you believe the Company's processing of your personal data violates the Thai PDPA, you have the right to lodge a complaint with the Thai Personal Data Protection Committee (PDPC).

14.2 If you exercise your rights as stipulated in the preceding paragraph or authorize others to do so on your behalf, you should provide identifiable identification documents.

14.3 If you exercise your rights as stipulated in 14.1, you shall bear the reasonable processing fees set by the Company. However, if you apply for access to correct personal data, you shall not be required to bear the processing fees. If you reside in California, USA, you can exercise your rights as stipulated in 14.1 twice per year without cost.

14.4 If you request that the Company stop collecting, processing, or using your Personal Data or request to delete the Personal Data provided by you by the first paragraph, the result/effect of exercising such data rights may cause the Company to be unable to provide the full scope of services. The Company will not assume any legal liability.

15. Special Provisions for Minors

15.1 The Company’s websites, applications, affiliated website activities, and other online activities are not specifically designed for minors/children. When minors use the Company’s services and consent to the collection and use of their personal information by the Company, such consent must be given with the approval of their legal representative or guardian. If you are a minor with limited legal capacity, you must have your legal representative or guardian read this Privacy Policy and obtain their consent before registering for and using the Company’s websites, applications, affiliated website activities, and other online activities or clicking the "Agree" (or similar wording) button. If you are legally incapable, your legal representative or guardian must read this Privacy Policy and act on your behalf to register for and use the Company’s websites, applications, affiliated website activities, and other online activities or click the "Agree" (or similar wording) button before you may register and use the services. Once you begin using the Company’s websites, applications, affiliated website activities, and other online activities, it will be deemed that your legal representative or guardian has read, understood, and agreed to the terms of this Privacy Policy. The legal representative or guardian may at any time request the Company to cease the collection, processing, and use of personal data related to a specific account.

15.2 Matters not covered herein shall be handled in accordance with applicable laws and regulations.

16. Electronic Consent

You agree to use this document as an electronic record mentioned in Article 4 of the Electronic Signature Act of the Republic of China to exercise your consent rights specified in Section 5.1.13.

17. Supplementary Clauses

Any unfinished parts of this Privacy Policy may be supplemented in accordance with the Company’s User Terms of Service and the laws of the Republic of China.

18. GDPR Privacy Rights [For European Market and Residents]

18.1 Legal Basis for Processing Personal Data under GDPR

The Company may process Personal Data under the following conditions:

18.1.1 Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

18.1.2 Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

18.1.3 Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

18.1.4 Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

18.1.5 Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

18.1.6 Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

18.2 Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

18.2.1 Request access to Your Personal Data.

The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

18.2.2 Request correction of the Personal Data that We hold about You.

You have the right to have any incomplete or inaccurate information We hold about You corrected.

18.2.3 Object to processing of Your Personal Data.

This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

18.2.4 Request erasure of Your Personal Data.

You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

18.2.5 Request the transfer of Your Personal Data.

We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

18.2.6 Withdraw Your consent.

You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

18.3 Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

18.4 Children’s Privacy

The Company’s services are primarily intended for individuals aged 18 and above. If you are at least 13 years old but under 18, you may only use the services if your legal guardian has read, understood, and agreed to all the terms of this Privacy Policy.

The Company does not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If the Company becomes aware that the Company has collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If the Company needs to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, the Company may require Your parent’s consent before the Company collects and uses that information.

19. California Privacy Rights Act, CPRA [For Residents of California]

19.1 If you are a California resident, you have privacy rights below:

19.1.1 Right to correction: You have the right to request to correct inaccurate personal information if you discover that it is incorrect. If you are a registered member, you can correct your information in the My Profile section of My Account. Alternatively, use one of the contact methods outlined in this policy.

19.1.2 Right to know about automated decision making: You can ask for information on how automated decision technologies work and their likely outcomes.

19.1.3 Right to Know What Personal Information is Sold or Shared: You have the right to know Personal Information the Company has sold or shared about you during the previous 12 months, including: (i) Business or commercial purpose(s) for selling your Personal Information, (ii) Categories of third parties with whom we share the Personal Information, (iii) Categories of Personal Information we have sold and categories of third parties to whom the information was sold, (iv) Categories of Personal Information we disclosed about you for a business purpose.

19.1.4 Right to limit the use of sensitive personal information: The categories of data that the Company collects and discloses for a business purpose include 'sensitive personal information' as defined under the CPRA. The Company does not use or disclose sensitive personal information for any purpose not expressly permitted by the CPRA.

19.1.5 Right to Delete: You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions. Upon receiving your deletion request, the Company must notify service providers and contractors, who are also required to notify their downstream entities. The Company must also notify third parties to whom it has sold or shared personal information, except where such notification is impossible or would involve a disproportionate cost.

19.1.6 Right to Access: You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell, free of charge, limited to twice per year.

19.1.7 Right to Opt-Out: You have the option to opt-out of having their personal information sold or shared with third parties, including for cross-context behavioral advertising. You can also refuse to have your personal information used to make automated conclusions, such as profiling for targeted behavioral advertising.

19.1.8 Right to Data Portability: You have the right to request that the Company send certain pieces of personal information to another entity. This transmission, however, must be technically feasible for the Company.

19.1.9 Right to Non-Discrimination: The Company must not discriminate against users who exercise their CPRA rights.

19.2 If you are a minor under 18 and have a profile on the Website, you may ask the Company to remove reviews or other content that you posted on the site by writing to the Company’s contact information. To strengthen the personal information choice of minors, the Company shall not make another request within twelve months if a minor refuses to provide personal information.

19.3 Do Not Sell or Share My Personal Information Requests

You may submit your request through the following methods:

By sending us an email: [email protected], for more details, please see this instruction page.

19.4 The Company will complete requests to limit the use or disclosure of personal information within 15 days of receipt. For requests to know, access, correct, or delete data, the Company acknowledges receipt of the request within 10 days of receiving it. Thereafter, the request must be completed within 45 days or upon extension with explanation, 90 days from the request.

19.5 The Company will not discriminate or retaliate against you if you choose to exercise any of these privacy rights.

19.6 Authorized Agents.

If you would like to enter a request on behalf of a California resident, please submit the request via the Company’s contact information. Upon submission, you will be required to upload documentation showing proof of written permission from the customer authorizing you to submit a request on their behalf. We reserve the right to require customers to confirm their requests and/or identity.

19.7 Annual Reporting for 2025

• Access Requests. In 2025, we received 0 requests from candidates to initiate the data access process.

• Deletion Requests. In 2025, we received two requests from candidates to delete their data.

• Correction Requests. In 2025, we received nine requests from candidates to correct their data

• Opt-Out of Sale/Sharing Requests. Information about our candidates is an important part of our business, and we are not in the business of selling candidate's personal information to others.

• Limit Use of Sensitive Information Requests. In 2025, we are unaware of any requests by candidates to limit the use of sensitive information.

20. Contact Us

If you have any questions about this Privacy Policy, You can contact us

• By visiting this page on our website: https://ooopenlab.cc/en/about

• By sending us an email: [email protected]

[For Users Located in Thailand]

Data Controller Physical Address

Company Physical Address: 9F., No. 18, Sec. 1, Wuchang St., Zhongzheng Dist., Taipei City, Taiwan.

[For Users Located in Japan]

Personal Information Handling Business Operator Disclosures

Article 20 Contact Information:

Inquiries regarding this policy, personal data handling, data subject rights requests, and complaints are handled by the following window:

• Address: 9F., No. 18, Sec. 1, Wuchang St., Zhongzheng Dist., Taipei City, Taiwan

• Representative: Yu-Hsuan Liu (劉又瑄)

• Telephone: 02-2741-6989