1. What Information Do We Collect?
We collect and use your personal information when you interact with us, directly request products or services, contact us directly with any inquiries, participate in or opt out of any of our marketing promotions, or otherwise communicate with us.
The personal information we collect includes: a) Your basic personal information, including first and last name; b) Contact information, including your address, phone number, email, or other information that allows us to contact you; c) Copies of your identification documents; and d) Technical information, including device information used to interact with us and our service information (including IP address, geographic location, device type and model, screen resolution, application version, device language, device identification codes, device status information, and other features/data that can identify the device); and information about your visits to our website or mobile application (including browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/use, page views, and any search terms you use, as well as device logs in the event of crashes or error reports).
2. How Do We Obtain Your Information?
We collect your personal information when you browse our website, use our mobile application, inquire about any chain services, enter into contracts with us, register to receive our information; or when you communicate with us via email, phone, text message, or any other electronic means.
We also receive your personal information from other sources, including: • Any other third parties, including those that support payments and transactions through related linked services; • Subsidiaries; vendors who provide services on our behalf; • Third parties for fraud monitoring and prevention purposes or other legally required purposes; • Regarding partner personnel, from relevant partners; and • Publicly available resources. In addition to the personal information you provide, we may combine information about you obtained from different sources.
3. How Do We Use Your Information
We use the collected information to operate our business. This includes, but is not limited to: a) Exercising rights and obligations under our group rules and related documents, and managing compliance with them; b) Using, building, providing, operating, and testing products and services, providing and operating chain services and related user services, enabling transactions, and facilitating the building, provision, operation, and testing of products and services for others (including affiliates); c) Facilitating product provision for partners; d) Responding to your inquiries, feedback, claims, or disputes, or otherwise providing customer support and service; e) For research, statistical analysis, business planning, and business intelligence purposes to understand how users like you view our products and services, industry trends, usage patterns, and other factors that may affect our business; f) Contacting you regarding our service provision, contacting you regarding any communication preferences or requests you have expressed, soliciting your feedback on services or other related products and services, collecting feedback from you and your employees on our products and services, and using this feedback to improve our business and/or customize products and services; sending you information about products and services, including offers or promotions for promotional purposes (including customized offers and promotions); and contacting you for legal reasons; g) Operating marketing and advertising campaigns; h) Managing our business, including invoicing, billing, account management, reconciliation, collection, audit purposes, and internal reporting; i) For security, authentication, and risk control purposes, including managing anti-money laundering and fraud risks, conducting credit and solvency checks, assessing, detecting, investigating, preventing, remedying, or reporting data breaches, fraud, other potentially prohibited or illegal activities, and violations of our agreements and policies, industry standards, guidelines, laws, and regulations, to protect the integrity of our services, products, and platforms and maintain security. Protecting our and others' rights or property, preventing any harm or economic loss to us or others; j) Providing you with customized content; k) According to any rules, laws, regulations, subpoenas, court orders, other legal proceedings or contractual or business requirements, including disclosure of information to regulatory authorities, government officials, courts, credit card associations or other payment schemes. Such requirements may involve 'know your customer' checks, anti-money laundering, counter-terrorism financing reports, tax requirements or other commercial disputes; l) Any proposed or actual merger, acquisition, corporate restructuring, financing, joint venture sale, transfer, assignment, disposal, or similar transaction, including the sale of business, assets, or stock; and m) For everyday business purposes, compliance with laws, or other ways for which we provide specific notice at the time of collection.
4. With Whom Do We Share Information
We share your personal information to operate and manage our business, including for the purposes under Section 3. We may share your information with the following parties: a) Merchants who provide goods and services to you and their acquirers (if applicable), as well as other third parties, including merchants that support transactions through related services b) Third-party online merchants whose services or mobile applications you choose to use. c) Service providers selected by you. d) Third parties with whom you have instructed us to share information. e) Affiliated companies. f) Any agents, contractors, or third-party service providers who work with us to provide services. g) If applicable, banks and other financial institutions, bank card associations, payment networks, or other institutions, including those involved in processing payments and transactions through related services; and h) Law enforcement agencies, insurance companies, governmental and administrative or supervisory bodies, which have an obligation to disclose according to any applicable laws, regulations, or business arrangements. i) Parties involved in litigation proceedings and assessment of claims or disputes, including courts. j) Individuals and entities involved in any of our mergers, acquisitions, corporate restructuring, financing, or similar transactions, including in the case of selling all or part of our assets; and k) Our own and others' professional advisors.
Except as described above, we will not share your personal information in the normal course of business unless we have obtained your explicit authorization or consent in advance. Notwithstanding the foregoing, sharing, transferring, or publicly disclosing your personal information does not require your prior authorization or consent in the following circumstances: a) Directly related to national security or national defense security b) Circumstances directly related to public safety, public health, or significant public interests c) Necessary to protect your or other individuals' significant legitimate interests, such as life and property, but it is difficult to obtain your consent d) Personal information you have decided to disclose to the public yourself e) Personal information collected from legally and publicly disclosed information f) Information necessary for entering into and performing contracts at the request of the personal information subject g) In other circumstances stipulated by laws and regulations.
According to the Personal Data Protection Act 2012 ('PDPA'), sharing or transferring personal data refers to personal data of an individual who can be identified from (a) that data; or (b) that data and other information which the organization has or is likely to have access to. Anonymous data will not be considered personal data if the affiliated group takes measures to prevent re-identification. To align with global data protection legislation, we have taken strict measures to treat such pseudonymized data as equivalent to personal data in cases where re-identification is not possible. Sharing, transferring, or publicly disclosing such de-identified data does not require separate notification to you or your consent.
5. How We Store and Protect Your Information
We retain your information only for as long as necessary to provide you with services and will not retain or process your information beyond the time required by law.
We have established a comprehensive information security management system and access controls, and will take reasonable and feasible security measures and technical means to store and protect your personal information according to industry standards to prevent loss, unauthorized access, public disclosure, use, modification, destruction, loss, or leakage of your information, in compliance with applicable data protection and privacy laws and regulations. Notwithstanding the above, we may retain your information for up to 7 years to ensure that any contractual disputes can be resolved. We will take all reasonable and feasible measures to protect your personal information.
6. How We Handle Information of Minors
Our services are not directed at children under 18 years of age, and we do not knowingly collect information from children under 18. If you are under 18, please do not use our services or submit any personal information to us.
7. Third-Party Information Services
We may provide links to third-party websites and services (including our partners' websites, services, and mobile applications) to facilitate information processing. These services and websites may operate independently of us and have different data protection and privacy practices than we do. We are not responsible for the content and privacy practices of these other websites and services, and we encourage you to review the privacy policies of these websites.
8. Information Transfer
With multiple offices globally, your information may be processed outside the country where you reside. Regardless of where your information is processed, we will take appropriate measures to ensure that your personal information is protected and secure under applicable data protection and privacy laws and regulations.
9. Your Rights Regarding Personal Information Processing
When you use the services or interact with our affiliates through our products or services, you agree that we may receive, use, aggregate, and analyze your personal information as needed for business and cooperation purposes. According to applicable data protection and privacy laws and regulations, you may have the right to: Ask us about the processing of your personal information, including requesting a copy of your personal information. Request correction and/or (in certain circumstances) deletion of your personal information. In certain circumstances, request restriction of or object to the processing of your personal information. Withdraw your consent to the processing of your personal information; and In cases where we use your personal information based on consent or performance of a contract, request to receive or have transferred to another organization in machine-readable form the personal information you have provided to us; and If you have the option to share your personal information with us, you can always choose not to do so. You also have the right to withdraw any consent previously given to us to share your personal information. However, choosing not to share your personal information with us or withdrawing your consent for us to use this information may mean that we cannot take necessary actions to achieve the stated processing purposes, or that you cannot take advantage of our services and products. Please note that withdrawing your consent does not affect the lawfulness of processing based on consent before its withdrawal.
10. COOKIES
We may use 'cookies,' which are small data files sent to your browser when you enter our website, to store and track information about you. These cookies are used to track information such as the number and frequency of users, user profiles, and their preferred websites. While these cookies can tell us when you enter our website and which pages you visit, they cannot read data from your hard drive. You can choose to accept or reject cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to reject cookies if you prefer. This may prevent you from fully using the website's features.
11. Contact Us
If you have any questions or requests regarding the privacy of your personal information, please contact us through online customer service. As required by applicable law, please note that we may take measures to request further information from you to verify your identity before allowing you to access information or take action at your request to exercise your rights. You can choose to accept or reject cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to reject cookies if you prefer. This may prevent you from fully using the website's features.
12. Privacy Policy Amendments
We may change or amend this Privacy Policy from time to time. We will notify you of any substantive or significant changes to this Privacy Policy by updating this webpage, sending push notifications, emails or letters, calling you, or posting announcements on our website. You can also view the latest Privacy Policy on our website's homepage.