云闪付隐私政策

　　This privacy notice (the “Privacy Notice” or “Notice”) explains why

　　and how UnionPay International Co. Ltd (“UPI” or “we”) may process your personal information when

　　you use the UnionPay mobile wallet application (the “UnionPay App”)

　　● What does “personal information” mean?

　　Personal information means any information that can be linked directly or indirectly to identified or

　　identifiable individuals.

　　● Who is UPI?

　　UPI is a company incorporated under the laws of the People’s Republic of China

　　(“PRC”) with its registered office at Floor 2-7, No.6 Dongfang Road, Pudong New

　　District, Shanghai, PRC.

　　If you have any questions in relation to data protection matters, you can contact us by email at

　　apphelp@unionpayintl.com or call the UnionPay official hotline at 866-567-5516.

　　● Why does UPI process personal information

　　UPI operates the UnionPay App for providing payment and other related services to users.

　　● Do you have a UPI account? View our Gramm-Leach-Bliley Consumer Notice below.

　　If you have created an account with us, our Gramm-Leach-Bliley Consumer Privacy Notice (the “GLB

　　Notice”) applies to you. The GLB Notice contains important information about your choices

　　regarding how we share non-public information for marketing purposes, and how you can limit such

　　sharing. Please consult the GLB Notice below, right at the end of this Privacy Notice.

　　● What information is contained in this Privacy Notice?

　　You will find relevant information on the personal data we process about you, the purposes and legal

　　bases for the processing of this data and your rights.

　　You will find below the purposes for which UPI collects personal information:

　　● Processing your registration with us as a user of UnionPay App and creating and maintaining your

　　account with us;

　　● Verifying your identity when binding cards to UnionPay App;

　　● Providing you with relevant products or services in UnionPay App;

　　● Marketing activities, including marketing by us, our affiliates, and our partners in the UnionPay

　　App,

　　online, via email or SMS, or otherwise;

　　● Providing you with location-specific options, functionalities, or offers;

　　● Communicating with you and responding to your requests, including by providing customer support and

　　enabling you to interact with UPI through social media;

　　● Operating, evaluating, and improving our business, including improving our services and developing

　　new

　　functions;

　　● Doing internal research, reporting and analysis;

　　● Protecting against, identifying and preventing fraud and other prohibited or illegal activity,

　　claims

　　and other liabilities;

　　● Establishing, exercising, and defending legal claims;

　　● Monitoring compliance issues and ensure compliance with our policies, terms, and obligations,

　　including

　　conducting internal investigations and audits

　　● Compliance with our obligations, applicable laws and regulations, and/or subpoenas, court orders or

　　other legal process or requirements applicable to us.

　　The types of personal information we process are the following:

　　● Registration and account information (including name, phone number, email address, machine or

　　mobile ID, password);

　　● Card Information for binding cards (including card number, expiration date, card verification code

　　(CVC), and tokenized versions of the foregoing);

　　● Transaction data and/or commercial information collected when you make payments with the UnionPay

　　App or purchase items within the UnionPay App (i.e., personal account number, date/time/amount of

　　the transaction, name and location of merchant, items purchased, and shipping and billing

　　addresses);

　　● Information about your interaction with the UnionPay App collected automatically by the UnionPay

　　App when you use the App (including geolocation data, device type, device identification number,

　　time zone, language setting, browser type, and IP address);

　　● Information about your use of participation in coupons or promotional offers available in the

　　UnionPay App; Information collected in connection with verifying your identity and/or preventing

　　suspicious activities or fraud;

　　● Any information you provide to us when you communicate with us, including audio recordings when you

　　call us as permitted by law;

　　● Social networking information and information from your social media profiles, if you interact with

　　us through social media.

　　● Inferences drawn from any of the information identified above about you, your activity, or your

　　preferences.

　　We collect personal information about you from the following categories of sources:

　　● Directly from you, for example when you provide personal information to us (such as a credit card

　　number) or use the UnionPay App.

　　● From our service providers, such as providers who assist us with tokenizing your payment

　　information.

　　● From persons who help you make payments through the UnionPay App, such as financial institutions,

　　credit or debit card brands, payment processors, or merchants.

　　● From partners who help us provide advertising or promotions to you.

　　● From social media platforms, if you interact with us through social media.

　　Accessing your personal data

　　We understand that you may like to know what personal data we hold about you. We are happy to assist

　　you with your request. To protect your personal data, however, we require that you prove your

　　identity to us at the time your request is made: you can contact us in writing via email at

　　apphelp@unionpayintl.com or letter including your signature and a copy of a signed government issued

　　identification document.

　　UPI reserves the right to decline access to your personal data under certain circumstances as

　　permitted by law. If your personal data is not disclosed to you, you will be provided with the

　　reasons for this non-disclosure.

　　Other rights

　　You may also be entitled to:

　　? object to the processing of your personal data;

　　? request the restriction of the processing of your personal data;

　　? request the correction and/or deletion of your personal data;

　　? withdraw your consent to the processing of your personal data (where UPI is processing your

　　personal information based on your consent);

　　? lodge a complaint with a supervisory authority; and

　　Where you are given the option to share personal data with UPI, you can always choose not to do

　　so.

　　If you object to the processing of your personal data, or if you have provided your consent to

　　processing and you later choose to withdraw it, we will respect that choice.

　　This could mean that we will be unable to perform the actions necessary to achieve the purposes of

　　processing data for you as described above (see article 2) and that you may be unable to use our

　　services.

　　After you have chosen to withdraw your consent, UPI may be able to continue to process your personal

　　data to the extent required or otherwise permitted by law.

　　If at any time you wish to exercise any of these rights, you can contact us by email at

　　apphelp@unionpayintl.com or call the UnionPay official hotline at 866-567-5516.

　　The recipients of your personal information may include:

　　● UPI’s establishments and affiliates;

　　● UPI’s processors and other contractors, suppliers and service providers;

　　● Companies that may assist us in analyzing personal information, improving the UnionPay App or your

　　experience on it, marketing products or services, or providing promotions to you;

　　● Other financial institutions we have partnered with to jointly create and offer products or

　　services;

　　● Companies involved in helping you make payments with the UnionPay App, including acquiring banks

　　(such as the bank you are withdrawing cash from, or the bank of the merchant you are paying in

　　exchange for goods or services), the issuing banks (such as the bank that issued your card), credit

　　card brands, payment processors, and merchants;

　　● Law enforcement authorities or other public or governmental agencies, bodies, or officials, or

　　other third parties pursuant to a subpoena, a court order or other legal process or requirement

　　applicable to UPI or UPI’s affiliates;

　　● With other third parties for our business purposes or as permitted or required by law.

　　We make efforts designed to ensure that such recipients undertake measures to keep your personal data

　　confidential.

　　UPI may use your personal information (including your contact numbers) for direct marketing to you,

　　as permitted by applicable law. This includes sending you marketing communications about updates,

　　and the latest offers and promotions about UPI’s goods, services, or activities or, as appropriate,

　　those of UPI affiliates or other companies with whom UPI has partnered. UnionPay may not so use or

　　provide your personal data except as permitted by applicable law.

　　These communications may be sent by app, in accordance with applicable laws. If you create an

　　account with UPI, you have the option to stop us from sharing your personal information with

　　affiliates and non-affiliates for marketing purposes. Please see our GLB Notice below to find out

　　what sharing you can stop, and how to exercise your right to stop such sharing.

　　UPI has installed security measures designed to prevent access to your personal information by

　　unauthorized persons. We have authorised and trained staff for processing personal information. As

　　such, staff of UPI and third parties who are authorized to have access to your personal information

　　are required to comply with non-disclosure obligations.

　　Technical and organisational measures have been implemented that are designed to prevent from

　　unauthorised or unlawful processing of personal information and against accidental or unlawful

　　destruction, loss, alteration, unauthorised disclosure of, or access to personal information.

　　The UnionPay App may use cookies and tracking technologies to operate the App and to target

　　advertising that may be of interest to you. For further information, please refer to UPI’s cookie

　　policy.

　　Your personal information will be stored for the period of time required or permitted by applicable

　　law. This may involve retaining information following your transaction. We make efforts to delete

　　your personal information once it is no longer required for any of the purposes described above.

　　In order to determine the amount of time we will store your personal information we take into

　　consideration the role and function of the information, type of products and services, nature of the

　　relationship between you and us, and statutory requirements of retention period made by applicable

　　laws and regulations.

　　You may find links to access the websites of other companies or app on UnionPay App. We recommend

　　that you read the privacy policies of these other websites or app, as this Privacy Notice does not

　　apply to the processing of your personal information by them and UPI is not responsible for the

　　processing of your personal information on external websites.

　　The UPI Mobile App is not designed to respond to “Do Not Track” requests.

　　We may update this Privacy Notice from time to time – in particular in case of changes to our

　　business or practices, changes of law, in response to guidance from competent authorities or as

　　required by UPI’s internal policies. The updated Privacy Statement will be effective as of the

　　published effective date.?We may also share with you the updated Privacy Notice through the UnionPay

　　App.