Privacy and Personal Data Protection Policy
Last update: September 23, 2026
Globe Union Industrial Corp., its subsidiaries and affiliated companies (collectively, “We” or the “Company”) highly respect and are committed to protecting the privacy and personal data of individuals. To protect and manage the privacy and personal data obtained by the Company, we have established this Privacy and Personal Data Protection Policy (the “Policy”) in accordance with “Personal Data Protection Act” and “Enforcement Rules of the Personal Data Protection Act”. Our overseas subsidiaries may adopt local privacy and personal data protection policies in compliance with applicable laws, and such policies shall form part of this Policy.
We manage the collection, processing, and use of personal data in accordance with this Policy to ensure data security and prevent unauthorized disclosure or misuse. We also require our suppliers, contractors, external consultants, and other partners to comply with this Policy in order to jointly uphold and protect privacy and personal data.
1. Scope
This Policy applies to the Company and to its employees, customers, suppliers, employees of the Company’s customers and suppliers, users of the Company’s websites, products or services, job applicants, visitors, investors, shareholders, and other individuals who have business interactions with the Company (collectively referred to as the “Data Subject”).
2. Definition of Personal Data
For the purposes of this Policy, “personal data” includes, but is not limited to, the Data Subject’s name, gender, date of birth, national identification number, passport number, characteristics, fingerprints, marital status, family, education, occupation, medical records, medical information, genetic data, sex life, health examination records, criminal records, contact information, financial status, social activities, data collected through our website cookies, as well as job applicants’ education, work experience, and professional certifications, or any other information that may directly or indirectly identify a specific individual. The definition and scope of personal data shall be subject to any amendments made in accordance with changes to applicable laws or regulations or requirements of competent authorities. Unless otherwise defined herein, terms used in this Policy shall be interpreted in accordance with the “Personal Data Protection Act” and “Enforcement Rules of the Personal Data Protection Act”.
3. Collection of Personal Data
We may collect personal data from Data Subjects, publicly available sources, or third parties legally authorized to provide such information for the purposes of providing products and services, managing our websites, conducting business operations, fulfilling contractual obligations, recruiting talent, maintaining relationships with customers and suppliers, complying with legal and regulatory requirements, and other legitimate business purposes.
Unless otherwise required by applicable laws or necessary for a legitimate purpose, we do not proactively collect, process, or use special categories of personal data, including medical records, healthcare records, genetic data, information concerning sex life, health examination records, or criminal records.
If a Data Subject chooses not to provide personal data, we may be unable to provide certain products or services, respond to requests or inquiries, or otherwise fulfill the purposes for which such personal data is required.
4. Protection of Children's Privacy
We are committed to protecting the privacy and personal data of children. Except where permitted or required by applicable laws, we do not knowingly collect personal data from children under the age of 14 (or such higher minimum age as may be required under applicable local laws). If we become aware that we have collected personal data from a child under the applicable age without the consent of the child’s parent, legal representative, or guardian, we will take appropriate measures within a reasonable period of time, including ceasing the collection, processing, and use of such personal data, and deleting or anonymizing the data in accordance with applicable laws and regulations.
5. Purpose of Collection, Process and Use of Personal Data
Subject to applicable laws and regulations, we may collect, process, and use personal data for the purposes of providing products and services, managing our websites, conducting business operations, recruiting personnel, maintaining relationships with customers and suppliers, conducting business communications and marketing activities, fulfilling contractual obligations, and complying with legal and regulatory requirements (collectively, the “Specified Purposes”).
The collection, processing, and use of personal data will not exceed the scope necessary to achieve the Specified Purposes, and we will ensure that such activities have a legitimate, reasonable, and relevant connection to such Specified Purposes.
6. Third Party Websites
Our websites may contain links to third-party websites, which are not governed by this Policy. Before using any third-party website or providing personal data thereto, Data Subjects are encouraged to review the applicable privacy policy and terms and conditions of such website. We are not responsible for the collection, processing, use, protection, or other handling of personal data by any third-party website.
7. Sharing of Personal Data and with Whom We Share Personal Data
Within the scope of the Specified Purposes and as permitted by applicable laws and regulations, we may provide or transfer personal data to our subsidiaries, affiliated companies, service providers, business partners, or other third parties engaged to process personal data on our behalf. Such sharing or transfer may be necessary to assist us in providing products and services, managing our websites, conducting business operations, providing customer support, performing data analytics, maintaining information systems, or carrying out other related business activities.
Such third parties may collect, process, and use personal data only in accordance with our instructions, authorization, or contractual arrangements, and only to the extent necessary to fulfill the Specified Purposes. They are also required to implement appropriate confidentiality, administrative, technical, and security measures to protect personal data and ensure its security.
In addition, we may disclose personal data to competent regulatory authorities, administrative agencies, judicial authorities, courts, or other parties legally entitled to obtain such information, where required to comply with applicable laws, regulations, legal processes, or other legal obligations, and only to the extent necessary.
In connection with a merger, acquisition, divestiture, asset transfer, corporate reorganization, investment transaction, or other similar business activity, we may also provide personal data, to the extent necessary, to the relevant transaction parties and their advisors. In such cases, we will require those parties to implement appropriate measures to protect personal data in accordance with applicable laws and regulations.
Except as described above, or where otherwise permitted or required by applicable laws, we will not provide or transfer personal data to any third party without the Data Subject’s consent.
8. Retention and Use Period
We retain personal data in accordance with the Specified Purposes, applicable laws and regulations, and business needs. In determining the appropriate retention period, we take into account factors such as the volume, nature, and sensitivity of the personal data, the risk of unauthorized or improper use or disclosure, whether the personal data is related to any litigation, dispute, or other legal proceeding, and the need to fulfill contractual obligations. We will ensure that the collection, processing, use, and retention of personal data do not exceed the period reasonably necessary to fulfill the Specified Purposes.
When the Specified Purposes for collecting, processing, and using personal data no longer exist, the applicable retention period expires, or the personal data is no longer reasonably relevant to such purposes, we will, on our own initiative or upon the Data Subject’s request, cease collecting, processing, and using the personal data and permanently delete, destroy, or anonymize such personal data in accordance with applicable laws and regulations.
9. Cross-border Transfer
Personal data may be transferred and used among our subsidiaries and affiliated companies located in different countries or regions, to the extent necessary to fulfill the Specified Purposes set forth in this Policy and in compliance with applicable laws and regulations. We will ensure that any cross-border transfer, access, processing, or use of personal data is conducted in accordance with this Policy and the applicable privacy and personal data protection laws and regulations of the jurisdictions involved.
10. Protection of Personal Data
We will implement appropriate security measures to protect the personal data in our possession against improper use and unauthorized access, disclosure, alteration, or destruction.
11. Rights of the Data Subject
The Data Subject has the following rights with respect to his/her personal data:
- to request access to and review his/her personal data;
- to request a copy of their personal data, which will generally be provided once in electronic form;
- to request the supplementation or correction of his/her personal data;
- to request the cessation of the collection, processing, or use of his/her personal data; and
- to request the deletion or destruction of his/her personal data.
To protect the rights and interests of Data Subjects and to avoid disputes, we may require requests to be submitted in writing or through other verifiable means and may verify the identity of the requester before processing such requests. Where otherwise provided by applicable laws, necessary for compliance with legal obligations, dispute resolution, or the establishment, exercise, or defense of legal claims, we may retain all or part of the personal data as permitted by law and may not be able to fully comply with a Data Subject’s request.
12. Cookie
To provide optimal services, our website uses cookies or similar technologies for purposes such as website traffic analysis, including your IP address, browser type and operating system. If you do not wish to accept cookies, you may adjust your browser settings at any time to refuse cookies; however, this may result in certain functions of our website not operating properly.
13. Training
We conduct regular training on privacy and personal data protection for all employees and evaluate the effectiveness of such training.
14. Implementation and Amendment of This Statement
We reserve the right to amend this Policy from time to time to comply with applicable laws and regulations and to address our actual personal data protection requirements. Any revisions to this Policy will be announced and posted on our website and shall become effective upon publication. The Data Subject’s continued use of our website or related services following the publication of any revised Policy constitutes acknowledgment and acceptance of such revisions. If the Data Subject does not agree to the revised Policy, the Data Subject should discontinue the use of our website and related services.
15. Contact us
If you have any questions about this Policy, or wish to exercise your rights or submit a request, notice, complaint, or inquiry under this Policy, please contact us through the “Contact Us” section of our website or contact the responsible department of the Company through the following contact details:
Legal Department, Globe Union Industrial Corp.
Email: legal@globeunion.com
We will handle such matters promptly and within a reasonable period of time in accordance with applicable laws and our internal procedures.
