• Privacy Policy

    Introduction

    We attaches great importance to protection of your personal information. When you are using the Company’s service, the Company may collect and use your relevant information. The Policy will help you learn more about the ways that the Company collects, uses, stores and shares such information when you are using the Company’s service as well as the methods provided by the Company for you to access, update, control and protect such information. You are expected to read the Policy carefully. Your use or continued use of the Company’s service means your consent to the Company’s collection, use, storage and sharing of your relevant information in the manner provided in the Policy.


    I. Scope of Application

    Unless otherwise specified, all services provided by the Company for you are governed by the Privacy Policy (“Policy”).


    II. Information provided by You

    Your relevant information provided to the Company subject to your agreement and authorization during your use of the Company’s service, including but not limited to: name, bank card number, number of valid identity certificate, mobile phone number, fixed-line telephone number and bank card transaction, for [precision marketing, product data modeling and data application service].

    Shared information provided by you to other parties through the Company’s service subject to your agreement and authorization, and information stored by you during your use of the Company’s service.

    Shared information concerning you provided by other parties during their use of the Company’s service, subject to your agreement and authorization.


    III. Information Collection

    While you are using various services provided by the Company, you agree and irrevocably authorize the Company to collect relevant information provided by you. Therefore, you are expected to provide your relevant information correctly and in detail during registration, and timely update your registration material.

    During provision of service, the Company may also use personal information provided by you in combination with other legally collected information, and you may decide whether or not to provide relevant information to the Company. If you refuse to provide relevant information, you may be denied access to the service provided by the Company.


    IV. Information Use

    Without prejudice to relevant laws and regulations, in order to enable the Company to provide better service for you, the Company will use your relevant information for advertising, data analysis, data research, product service design and other purposes that may help improve the Company’s existing services.

    You agree and authorize the Company to use, analyze, handle and process your information to the extent permitted by laws and regulations, and allow the Company to sublicense and transmit your user information to other third parties for use, analysis, handling and processing. Subject to your authorization and agreement, the Company will conduct information interaction with its partners using security technologies and programs (e.g., data encryption channel) that comply with the requirements of national laws and regulations. Meanwhile, the Company causes its partners to use your user information in compliance with relevant laws and regulations and maintain the confidentiality of your information.


    V. Collection and Use of Information of Non-Specific Objects

    In addition to information provided by you, the Company will collect and use various kinds of information that the identity of specific natural persons cannot be recognized or the activities of specific natural persons cannot be reflected without further information (“Information of Non-Specific Objects”). Additionally, the Company will, according to the requirement on its provision of services, conduct technical processing of personal information provided by you, such as using de-identification and other security measures, so that the Company will be unable to identify your identity without additional information and thus share or use such information as information of non-specific objects. The Company may collect, use, transfer, shared and disclose the foregoing information of non-specific objects for the purpose of precision marketing.

    The following are some examples of information of non-specific objects that the Company may collect and handle and how the Company use such information:

    The Company may collect information like occupation, language, post code, area code, device identifier, referral URL, location and the time zone when the user uses the Company’s product, so that the Company could better understand customer behavior to improve and enhance the Company’s service.

    The Company may obtain and collect other relevant information about you on the Company’s website, through collaboration service with other parties and through other products or service used by you. The Company will put together such information to help the Company provide more useful information for customers and understand in which part of the Company’s website, products and services customers are most interested.


    VI. Use of Cookie and Similar Techniques

    Cookie (cookie generally includes identifier, site name and some numbers and characters) and similar techniques are common techniques used on Internet. When you are using any service provided by the Company, the Company may use relevant techniques to send you one or more cookies or anonymous identifier in order to collect and store information generated during your use of the Company’s product.

    You may freely decide whether or not to disable the cookie in the browser. If you opt to disable the cookie, you may be denied access to service provided by the Company. The Company has no control over any website displayed in the search result of the Company’s website, any website incorporating the Company’s application program, product or service, or any link in the Company’s various services. Those websites may place their own cookies or other files in your computer to collect your data or require you to provide personal information.

    In certain business functions, the Company may make decisions simply through non-artificial automatic decision-making mechanisms including information system and algorithm. If such decision materially affects your legitimate rights and interests, you are entitled to request the Company to make explanations and the Company will also provide an appropriate remedy.


    VII. Sharing, Transfer or Public Disclosure of Information

    Information Sharing

    We will not share your personal information with any company, organization and individual other than the Company except under the following circumstances:

    Sharing after explicit consent: In order to help the Company provide better service for you, after obtaining your explicit consent, the Company may share your personal information with other business related parties and use such information in accordance with relevant provisions of the Privacy Policy.

    The Company may share your personal information with other parties in accordance with the stipulations of laws and regulations, or in accordance with mandatory requirement of government departments in charge.

    Sharing with the Company’s affiliates: We will share necessary personal information with the Company’s affiliates (e.g., China UnionPay), and subject to the purpose stated in the Privacy Policy, if any such affiliates intends to change the purpose of handling personal information, will solicit your authorization and consent again.

    Sharing with third parties cooperating with the Company: After a third party cooperating with the Company obtains your authorization and consent, the Company may provide such third party with products and services relating to information provided by you. If the provision of services relating to information of non-specific objects is required, you agree that the Company may, after examining and verifying the third party’s qualification, decide at its discretion whether or not to conduct relevant cooperation business to the extent as stated in the Policy and required by laws and regulations.

    For companies, organizations and individuals with whom we share personal information, we will sign a strict confidentiality agreement with them and thus cause them to treat personal information in accordance with the Company’s instructions and any other relevant secrecy and security measure.

    Information Transfer

    We will not transfer your personal information to any company, organization and individual except under the following circumstances:

    Transfer after explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.

    In case of any merger, acquisition or bankruptcy liquidation, if transfer of personal information is involved, we will cause the new company or organization possessing your personal information to be continually bound by the Privacy Policy. Otherwise, we will request such company or organization to solicit your authorization and consent again.

    Information Disclosure

    Once you are aware that any third party is engaged in collection and use of information relating to you and provision of data products and services in the name of the Company, you are expected to contact the Company in a timely fashion. The Company will make its best efforts to assist you in handling such information security event, and timely inform you of the result of event handling. If the event is severe enough, the Company will investigate the legal liability of the responsible party.

    You shall acknowledge and understand that the Company will provide your relevant information at the request of relevant units or for the information of public security after your explicit consent or in accordance with mandatory requirements of laws, legal procedures, litigations or government departments in charge. The Company will not be held liable for any disclosure under such circumstances.


    VIII. Information Security and Protection

    The Company attaches great importance to your information security. The Company will use and retain your information to the extent as stated in the Policy and required by laws and regulations, and it will use various security technologies and programs to prevent any loss, improper use, unauthorized reading or disclosure of information. For instance, in some services, the Company will employ encryption techniques (e.g., SSL) to protection information relating to you. To ensure the security of your relevant information, the Company will sign a confidentiality agreement with related parties given access to such information, and strictly implement data security protection measures.

    However, you are also expected to understand that due to technical restrictions and potential malicious methods of various kinds, in the Internet industry, even the adoption of the best possible security measures cannot always guarantee 100% information security. Therefore, although the Company has taken standard industry practice to protect your personal information, the following event may happen.

    Any content available on Internet or provided by any third party provide may harm your system security. The Company strongly recommend that you should use anti-virus software, individual firewall and other measures to protect your system security.

    In any of the following circumstances, you may request the Company to delete the personal information provided by you for the Company:

    If the Company’s handling of such personal information violates laws and regulations;

    If the Company’s collection and use of such personal information violates the agreement reached with you;

    If the Company’s handling of such personal information violates the agreement reached with you.

    If the Company decides to respond to your deletion request, the Company will also simultaneously notify other third parties that have obtained your personal information from the Company, requesting them to delete relevant information timely, unless otherwise required by laws and regulations, or such third party obtains your separate authorization.


    IX. Special Tips on Minors’ Use of Service

    The Company provides services for people aged 18 or above only. If you are less than 18 years old, you are expected to use the Company’s relevant services under the consent, guidance and supervision of your parents or guardians.

    With respect to collection of minors’ personal information with consent of their parents or guardians, the Company will use or publicly disclose such information only to the extent as permitted by laws, explicitly consented by parents or guardians or necessitated by protection of minors.

    No minors may use the Company’s relevant service with consent of their parents or guardians. Although local law and custom has different definitions of minor, the Company regards any person aged less than 18 as a minor.

    If the Company is aware that it has collected personal information of minors without prior provable parental consent, it will try its best to delete relevant data as soon as possible.


    X. Change of Policy

    The Company may revise the Policy in good time and such revision shall constitute a part of the Policy. The Company will, before effectiveness of such revision, keep you timely informed of the latest version of the Privacy Policy by giving a prompt at a conspicuous position at the homepage, or sending you an email, or otherwise notifying you. In such case, your continued use of the Company’s service means your consent to be bound by the revised Policy. If such revision results in any substantial reduction of your rights under the Policy, you are expected to contact the Company timely.


    XI. Cross-border Information Transmission

    The Company will store your personal information collected and generated during its domestic operation within the People’s Republic of China, and will not transmit such information to any place outside China unless otherwise required by laws and regulations and with your consent and authorization.


    XII. Contact Us

    If you have any doubt, opinion or suggestion about the Privacy Policy, please send an email to [office@unionpaysmart.com] to contact the Company timely. The Company will generally reply within [5] days after receipt of such email.

    If you are not satisfied with the Company’s reply and especially the Company’s handling of personal information impairs your legitimate rights and interests, you may find out a solution through the following external approaches:

    (1) make a complaint or tip-off to such departments as network information administration, public security and market supervision administration;

    (2) bring a lawsuit before the People’s Court of Pudong New Area, Shanghai.