Effective date: from October 16,
2018

World Health Energy Holdings
,Inc. (WHEN) (“us”, “we”, or “our”) operates the
https:// www.oto-graph.com website (the “Service”).

1. Data controller and
representative

Through its website (the
“Website”) and its mobile applications (the “Application”),
Oto Graph implements the processing of personal data listed below. Oto Graph
in EU in accordance with the Regulation No. 2016/679 on the protection of
natural persons with regard to the processing of personal data (the
“GDPR”).

Please read carefully the
following privacy policy which provides you, as the user of the Website and/or
Application (the “User” or “You”), with the relevant
information regarding the various processing of personal data implemented by Oto Graph,
in accordance with GDPR.

2. Data processing implemented by
Oto Graph

2.1 Processing of personal data
related to your visit to our website and the purchase and use of our products

When the User visits to our
Website, or purchases a Oto Graph product through the Website or the
Application, or use our products, Oto Graph implements a processing of
personal data as follows:

2.1.1 Personal data collected

Regarding this processing, Oto Graph collects the following personal data through the collection forms in the
ordering process or other processes.

Name;

Gender;

Age;

Email address;

Address;

Country;

Postal code;

Phone number;

Company name and industry you work for;

Order information, such as the
products you purchase, date and amount of the order;

Payment information such as
Credit card information (type, number, expiration date, CVV security code)/debit card information or other payment/billing information.

Information we get from your
visit to our Website, we collect information about how you visit our websites
(including the webpage that led you to a Oto Graph website, the search terms entered into a search engine which led you to a Oto Graph website);

Information we get from your use of our products. We collect information about the products that you use and how
you use them and your local device information, including but not limited to
your device information, operating system, user name, your Oto Graph ID,
location, IP address, operating log information, crash reports and the information and format of the files you are working with(with your additional consent);

Your product serial number;

Content of customer support
communications.

2.1.2 Purpose and legal basis of
the processing

Oto Graph uses the information we collect about you for the following purposes:

In order for Oto Graph to
provide the User with the ordered product(s);

For the performance of a contract to which the User is party, in accordance with Article 6.1.b of the GDPR and
the collected data are necessary in order for Kids-Protect to identify and bill
the User and to charge its bank card number;

For Verifying your identity and
Providing customer service or support;

Analyze your use of our websites and products to better understand how they are being used so we can improve our
services and the user experience and engage and retain users.

2.1.3 Recipients of the personal
data

We may also transmit your
personal information with companies that help us to run our business by
processing personal information on behalf of us for the purposes identified
above. Such companies include providers of payment processing services, server
services providers, data analysis services providers, fraud monitoring and
prevention providers, email delivery service providers, social media, and other
marketing platforms and service providers.

In addition, Oto Graph may disclose
the User’s personal data:

if Oto Graph is under a duty
to disclose or share such personal data in order to comply with any legal
obligation, or in order to protect the rights, property or safety of its business, its customers or others; and to successors in title or replacement operators of all or part of Oto Graph’s respective businesses.

2.1.4 Transfer of personal data

The collected personal data may be transferred by Oto Graph to recipients which are located outside the
European Union and such destinations may not have laws which protect the User’s
personal data to the same extent as in the European Union.

Oto Graph ensures that the
User’s personal data processed by Oto Graph or by its suppliers and partners
operating outside the European Union are treated securely and are protected
against unauthorized access, loss or destruction, unlawful processing and any
processing which is inconsistent with the purposes set out in this privacy
policy.

Please find below the relevant
information on transfer:

Oto Graph may transfer the
collected information to third party payment processors to complete the charge
process;

Oto Graph may transfer the
collected information to providers of third party email delivery service to
send promotion emails, or to other marketing platforms and service providers to
complete relevant service;

Oto Graph may use third party
track tools (such as Google Ads, Bing, bugsplat, Criteo, disqus, fabric,
Facebook, FireBase, Flurry, Google Analytics, Hotjar, LinkedIn, Pardot, Quora,
JPUSH) to track the information on how users use the products and websites,
such information will be stored in third party servers. Such third party track
tools may send the data analysis report to Kids-Protect for Oto Graph’s
above mentioned purpose;

Oto Graph may store the
collected information on the servers leased from providers of third party
server service.

2.1.5 Duration of the storage

Oto Graph will store the
collected personal data for the duration of the contract and 60 days after the termination of the contract. Beyond this duration, in order for Oto Graph to be able to demonstrate the existence of a right or a contract or a legal
obligation, the relevant personal data will be stored through intermediary
archives for a duration that will not exceed what is strictly necessary
regarding the purpose of the storage and in accordance with the applicable
legislation.

2.2 Processing of personal data
related to comments areas

When the User decides to comment
a Oto Graph product through the Website or the Application, Oto Graph implements a processing of personal data as follows:

2.2.1 Personal data collected

Regarding this processing, Oto Graph
collects the following personal data:

Email address;

Name or nickname;

profile photo;

Other potential personal
information provided by the User through its comment (age, location, etc.);

The content of your comment.

2.2.2 Purpose and legal basis of
the processing

This processing is implemented by
Oto Graph in order to improve its products and provide the consumers and
potential consumers with a better and transparent information about the Oto Graph products. Said comments and the related personal data are provided by the User
on a voluntary basis so that the processing of the collected personal data
relies on the User’s consent.

Oto Graph may use the comments
(with your relevant information) you post for marketing purpose in order for
others to better understand and use our products.

2.2.3 Recipients of the personal
data

Oto Graph may transmit the
collected personal data to third party email delivery service providers, social
medias, other marketing platforms and service providers .

2.2.4 Transfer of personal data

The collected personal data are
transferred by Oto Graph to recipients which are located outside the
European Union and such destinations may not have laws which protect the User’s
personal data to the same extent as in the European Union.

Oto Graph ensures that the
User’s personal data processed by Oto Graph or by its suppliers and partners
operating outside the European Union are treated securely and are protected
against unauthorized access, loss or destruction, unlawful processing and any
processing which is inconsistent with the purposes set out in this privacy
policy.

Please find below the relevant
information on transfer:

Oto Graph may transfer the
collected information to providers of third party email delivery service to
send promotion emails, to other marketing platforms and service providers to
complete relevant service.

Oto Graph may store the
collected information on the servers leased from providers of third party
server service.

2.2.5 Duration of the storage

Oto Graph will store the
collected personal data for not more than 5 years after the collection.

3. User’s rights

To the extent required by the law
of your jurisdiction, you may have below rights. Before you exercise below
rights, you may consult your legal counsel if the laws of your jurisdiction
stipulate below rights.

Contact Us

If you have any questions about
this Privacy Policy, please contact us:

By email: support@whengroup.com

By mail: 1825 NW Corporate Blvd,
Boca Raton, FL 33431