1. About this Policy and its Scope

ELGENS CO., LTD. (翔立光科技股份有限公司; “ELGENS”, “we”, “our” or “us”) respects your privacy. This Policy explains how we collect, use, disclose, retain, and protect personal data when you visit https://www.elgens.com.tw/, use its contact or resource download features, or contact us about our business to business (B2B) products and services. This Policy applies to website visitors and business contacts, including representatives of prospective and existing customers, distributors, suppliers, and partners.

When ELGENS determines the purposes and means of processing, ELGENS is responsible for the processing activities described in this Policy. Separate notices may apply to job applications, contractual customer systems, independent services provided by partners, or activities with a separate specific notice. “Personal data” includes information that identifies or can reasonably identify a person; a work email address or online identifier may still be personal data even when used in a business context.

2. Personal Data We Collect

Information you provide. Depending on how you interact with us, this may include your name, company, job title or role, business email address, phone number, country and city, product or project interests, the reason for contacting us, a quotation or technical inquiry, messages, and other correspondence. If you request a resource or certificate through a download that requires an email address, we may process your business email address and information related to the requested file and its delivery. If we offer a newsletter or event registration and you complete the registration, we may process the contact information and preferences needed for that activity. For customer service or a commercial relationship, we may also process relevant order, support, warranty, product serial number, or delivery information where actually provided.

Information received from others. To the extent permitted by law, we may receive your business contact details from your organization, distributors, customers, partners, event organizers, or publicly available professional sources. We will provide any additional source information or collection notice required by applicable law.

Information collected when you use the website. Our website and service providers may process your IP address, the approximate location derived from it, device and browser details, language, referral source, pages and links used, file downloads, date and time, site search terms, consent choices, and security or diagnostic logs. If enabled, analytics and embedded services may use cookies or similar identifiers. We do not need your exact GPS location to operate this public website.

Anonymous and de-identified data. Statistical data is considered anonymous only when a specific individual cannot reasonably be identified. If a person can be identified when the data is combined with other information, we will continue to process it as personal data under this Policy and applicable law.

Please do not enter passwords, financial credentials, sensitive personal data, or defense sensitive information in public form fields or site search. Required fields should be identified at collection. If you do not provide information needed to respond to an inquiry or deliver the requested service, we may be unable to complete it; optional marketing choices are handled separately from business inquiries.

3. Why We Use Personal Data

We process relevant data to:

• answer inquiries, arrange product or technical discussions, prepare quotations, and respond to requests;
• deliver requested materials and, where applicable, administer business relationships, orders, support, warranties, and service matters;
• operate, maintain, troubleshoot, and secure the website, prevent abuse, and protect our rights and those of others;
• understand website performance and improve content and services, subject to the applicable choices for analytics tools and similar technologies;
• send newsletters, product updates, or other relevant business communications only to the extent permitted by law, and manage subscriptions and objections; and
• comply with legal, accounting, procurement, export control, and other compliance obligations, and bring or defend legal claims.

Legal bases depend on the relevant activity and applicable law. If the EU or UK General Data Protection Regulation (GDPR) applies to particular processing, legal bases may include steps you ask us to take before entering into a contract or performing a contract, compliance with a legal obligation, our legitimate interests in responding to business inquiries and operating a secure B2B website, or consent obtained for activities that require it, such as certain optional technologies or marketing. When relying on legitimate interests, we assess the interests involved. Under Taiwan’s Personal Data Protection Act, we collect and use data for specified purposes on grounds permitted by that Act and, where applicable, provide the collection notice required by law. We do not treat submission of an inquiry or continued browsing as consent to unrelated marketing.

4. Business Communications and Downloads

If you request a quotation, product information, or support, we use your information to respond and follow up on that request. We send product news or event information only to the extent permitted by applicable law and your preferences. You can unsubscribe through a link in a marketing message, if available, or write to [email protected]. We may retain the minimum information needed to honor an opt out. Transactional or service communications necessary for a request or relationship are handled separately from optional marketing.

Some files, such as technical resources or certificates, may be delivered through an email request or a time limited link. We use the information needed to deliver the requested material, manage access, and protect the service. Requesting a download does not itself subscribe you to marketing. When you access a hosted file, a third party file host may receive technical request information.

5. Cookies, Analytics, and Third-Party Content

Cookies and similar technologies can support essential site functions, remember your choices, measure website use, or load optional third party content. The technologies actually used may change with the website configuration. Where required by law, we will request your choice before using non essential technologies and provide a way to change or withdraw that choice. You can also manage cookies in your browser, although disabling essential technologies may affect the functions you request.

Analytics. This website uses Google Analytics 4 (GA4) to understand visits, page and content performance, and interactions. Subject to your choices and applicable law, GA4 may use first party cookies such as _ga and _ga_* and process page, event, device, and browser information. If Google Tag Manager (GTM) is deployed, it is used to manage tags; the presence of GTM alone does not identify every tag that may collect data. We prohibit transmitting names, email addresses, phone numbers, form responses, confidential information, or other directly identifying information to Google Analytics. We take steps to prevent such information from being transmitted through site search terms, page URLs, or event parameters.

Consent and embedded content. Where applicable, a consent banner or preference control explains the purposes of optional technologies and lets you change your choices. If Google’s Consent Mode is implemented, it relays your choices to Google tags; Consent Mode itself is not a consent banner. Depending on the configuration, limited signals may still be sent even when consent is denied, so refusing consent does not necessarily mean that no data will be transmitted. This website may include Google hosted forms, Google reCAPTCHA, YouTube videos, maps, or linked or hosted documents. Loading or using these services may disclose technical information to the relevant provider. Where required by law, optional embedded content is enabled only after the applicable choice is made or the content is clicked. Plain links to social media websites generally open those websites’ independent services after you select them. Please refer to the relevant provider’s privacy notice for its independent processing activities.

Where required by law, ELGENS will describe the technologies currently enabled on the website’s cookie information or preference interface, including providers, purposes, and storage periods. Unless advertising, remarketing, or sale or sharing arrangements have actually been enabled and disclosed, we will not describe them as active arrangements.

Cookie categories and duration. Essential technologies are used for basic website operation and security; analytics technologies, such as GA4 when actually enabled, are used to measure visits and interactions; and some optional video or other embedded content may set cookies through third parties. Other functional or advertising technologies will be used only if actually enabled and lawfully disclosed. Cookies may be session cookies that expire when you close your browser or persistent cookies that remain until they expire or are deleted; actual names, purposes, providers, and expiration periods are described based on the technologies enabled on the website at the relevant time.

How to manage cookies. You can view, block, or delete cookies in your browser settings; the steps differ by browser, so please consult the official instructions for Chrome Cookie Settings, Microsoft Edge Cookie Settings, Firefox Cookie Settings, and Safari Cookie Settings. Deleting cookies may sign you out of the website or clear stored preferences, and blocking some cookies may affect site functionality. Browser settings do not replace the website’s cookie consent or preference mechanism; if the website provides one, you can use it to change or withdraw your choice regarding optional technologies.

6. When We Disclose Personal Data

We disclose relevant information only as appropriate for the stated purposes, including to:

• vendors acting for us, such as website hosting, cloud and Google hosted form services, analytics, email delivery, security, technical support, and file hosting providers; their roles and applicable contractual safeguards are governed by the relevant arrangements;
• distributors, logistics providers, business partners, or professional advisers when needed to handle an inquiry, transaction, service, or legal claim;
• courts, regulators, law enforcement or export control authorities where disclosure is legally required or permitted; and
• parties to a proposed or completed merger, acquisition, financing, or similar business transaction, subject to appropriate confidentiality and use restrictions.

Some third parties process information independently under their own notices rather than solely on our instructions. Whether a disclosure constitutes a “sale” or “sharing” of personal data depends on applicable law and the services actually enabled. Where a regional law requires an additional notice or choice, we will provide it.

7. International Processing

ELGENS is based in Taiwan. Depending on the vendors we use and the location of your contact or requested service, personal data may be stored in or accessed from other countries. Those destinations and their level of protection may differ from those in your country. Where applicable law requires an international transfer mechanism, we will use an appropriate lawful mechanism and additional safeguards where necessary. You can ask [email protected] for information about the relevant recipients and safeguards. Providing information through a website form is not, by itself, a waiver of applicable transfer protections.

8. Retention

We retain personal data only for as long as reasonably necessary for the purposes described above, taking account of the status of an inquiry or business relationship, the period needed to deliver a resource or provide a service, security and audit needs, legal and contractual recordkeeping duties, limitation periods, and any relevant dispute or legal hold. Marketing information is retained in line with applicable permission or objection and may include a limited suppression record. Analytics data is subject to the retention settings of the deployed analytics service; cookies have their own lifetimes. Protected backups may be deleted on a separate cycle. When the relevant period ends, we delete or anonymize data where reasonably possible, unless a lawful reason requires longer retention. You may contact us for more information about the relevant retention criteria.

9. Security and Defense-Sensitive Information

We use technical and organizational safeguards proportionate to the risks, which may include access controls, limited permissions, security maintenance, and measures to protect information in transit and at rest where appropriate. No method of transmission or storage can be completely secure. If an incident involving personal data occurs, we will address it and provide any notifications required within the time period required by applicable law.

Do not send classified information, controlled unclassified information (CUI), export controlled or ITAR/EAR restricted data, defense sensitive technical data, controlled drawings or specifications, source code, login credentials, passwords, or keys, operational details, or vulnerability information through general website forms, site search, or ordinary email. A public form or email address is not an approved secure channel for controlled data. If such data must be shared, first arrange an authorized method with ELGENS and obtain any required disclosure or export authorization. We may restrict access to or isolate information received through an inappropriate channel and handle it in accordance with applicable security and legal requirements.

10. Your Privacy Rights

Subject to applicable law and any permitted exceptions, you may request access to, review, or obtain a copy of personal data; correction or supplementation of personal data; cessation of the collection, processing, or use of personal data; or deletion of personal data. If particular processing is subject to the EU or UK GDPR, additional rights may include restriction of processing, data portability, objection, including objection to direct marketing, withdrawal of consent, and rights related to certain decisions that have significant effects and are made solely by automated processing. Where applicable, you may lodge a complaint with the competent data protection authority. Other jurisdictions may provide additional rights.

To make a request, contact [email protected] with the subject “Privacy Request.” We may ask for information reasonably necessary to verify your identity and request. We will respond within the applicable statutory period and explain any lawful refusal or extension. Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal; opting out of optional marketing does not prevent necessary service communications.

11. Children and Sensitive Personal Data

This B2B website is not directed to children, and we do not knowingly collect children’s personal data through ordinary business functions. If you believe a child has submitted information to us, please contact us so we can review and handle it as required by law. Unless ELGENS expressly requests it through an appropriate channel with a specific notice, please do not submit health, biometric, identification document, financial account, or other sensitive personal data through a general inquiry.

12. Third-Party Websites

This website may link to third party websites, including video, social media, document hosting, distributor, or event websites. When you leave this website, the operator’s privacy notice governs its independent activities. This does not relieve ELGENS of its responsibility for service providers processing personal data on our instructions.

13. Changes to this Policy

We may update this Policy to reflect changes in our services, technologies, or legal requirements. We will post the updated version and its revision date here and provide additional notice where required. Where a new purpose legally requires consent, we will obtain that consent rather than treating continued use of the website as consent.

14. Contact ELGENS

For questions, privacy requests, or concerns about this Policy, please contact:

ELGENS CO., LTD.
5F-8, No. 492, Bannan Rd., Zhonghe Dist., New Taipei City 235602, Taiwan (R.O.C.)
Email: [email protected] (subject: “Privacy Request”)
Website: https://www.elgens.com.tw/