Tenpay Privacy Policy

Date of the latest revision: July 14, 2023

Effective date: August 13, 2023

INTRODUCTION

This Tenpay Privacy Policy (hereinafter referred to as "Privacy Policy") applies to all payment products, services and their extended functions (hereinafter referred to as "Tenpay Services") provided by Tenpay Payment Technology Co., Ltd. ("We" or “Tenpay”). If there is any specific privacy policy or provision tailored for certain products provided by us, such specific privacy policy or provision shall prevail; for the contents not covered by the specific privacy policy or provision, this Privacy Policy shall apply. This version of Tenpay Privacy Policy is the English translation of the Chinese version of 财付通隐私政策, if there is any discrepancy between the English version and the Chinese version, the Chinese version shall prevail.

Contact information of Tenpay:

Registered Address: Room 201, Building A, No. 1 Qianwan 1st Road, Qianhai Shenzhen-Hong Kong Cooperation Zone, Shenzhen, Guangdong Province, PRC.

Office Address: Tencent Binhai Building, No.33 Haitian Second Road, Nanshan District, Shenzhen, Guangdong Province, PRC.

Customer Hotline: 95017, 0755-86013860.

Official Website: www.tenpay.com

We have always valued the personal information and privacy of our users (hereinafter referred to as "you") and will provide Tenpay Services to you in accordance with this Privacy Policy. When you use Tenpay Services, in order to fulfil our statutory obligations, or to provide services to you, or to constantly optimize the user experience in order to provide you with higher quality services, or ensure your account security, we may conduct necessary procession (including collect, store, use or provide) of your personal information. This Privacy Policy is designed to explain how we process your personal information and your rights in our personal information processing activities and how to exercise your rights.

This Privacy Policy will help you understand the following:

1. your rights

2. how we collect your personal information;

3. how we use cookies and other similar technologies;

4. how we store and protect your personal information;

5. how we use your personal information;

6. how we provide your personal information;

7. circumstances where personal information could be processed without your consent;

8. how we protect the rights and interests of minors;

9. how we update this privacy policy;

10. how to contact us.

1. YOUR RIGHTS

We cooperate with Shenzhen Tencent Computer System Co., Ltd. (the "Operator of Weixin and QQ Software", whose registered office is at 35/F., Tencent Building, Science and Technology Middle Road, Ma Ling Community, Yuehai Street, Nanshan District, Shenzhen) and link to the Weixin, QQ software and other channels operated by it to provide you with payment services such as Weixin Pay and QQ Wallet Payment, and to help users complete transactions through payment services such as the Digital Currency Electronic Payment and UnionPay QuickPass respectively provided by our cooperative institutions. We provide you with a wide range of payment products and corresponding Tenpay Services based on the Balance Payment, bank card Quick Pay and other payment methods of Weixin Pay and QQ Wallet Payment and payment methods provided by our cooperative institutions, you can use Tenpay Services at third party merchants (such as making payments for utilities expenses to public institutions and for goods or services to e-commerce merchants or offline merchants); you can manage your wealth (such as buying wealth management products from the financial institutions); or, you can transfer proceeds to others, send and receive proceeds through Red Packets or repay your credit card, etc.

During your use of Tenpay Services, to facilitate your exercise of your rights to consult, copy, correct, supplement and delete your personal information, we provide you with certain operational settings that you can refer to the following guidelines. You may also contact us through the contact information provided in Article 10 of this Policy to request the exercise of relevant rights:

(1) Consult or Copy Your Personal Information

(a) When using Weixin Pay, you can consult your personal information by entering "Me – Services - Wallet". You can also enter "Me - Services - Wallet - Transactions" to consult your transaction records of deposit-withdrawal, top-up, refund, purchasing, transferring and red packets, etc. If you want to download the transaction records of Weixin Pay, you can also enter "Me - Services - Wallet - Transactions" and then clicking the upper-right corner to enter "Frequently Asked Questions" to access "Download the Bills" to download the transaction records.

(b) When using QQ Wallet, you can consult your personal information by entering "My QQ Wallet", then clicking the upper-right corner to enter "Settings – Real-name Authentication". You can also enter "My QQ Wallet - Balance - Transactions" to consult the records of your transactions such as deposit-withdrawal, top-up, refund, purchasing, transferring and red packets.

(c) For the security of your personal information, part of your name, ID number and bank account information will be displayed as "*".

(2) Correct or Supplement Your Personal Information

(a) When using Weixin Pay, you can modify information such as gender, ID’s validity period, occupation, address and mobile number information by entering "Me – Services - Wallet – ID Info", and you can click to apply for making correction or supplement if you find your information is inaccurate or incomplete.

(b) When using QQ Wallet, you can enter "My QQ Wallet", clicking the upper-right corner to enter "Settings - Real-name Authentication" and click to modify information such as gender, ID’s validity period, occupation, address and mobile number information, and you can click to apply for making correction or supplement if you find your identity information is inaccurate or incomplete.

(c) You can contact us through our online customer service or call customer service to apply for making correction or supplement if you find that your personal information collected and stored by us is inaccurate.

(3) Delete Your Personal Information

(a) When using Weixin Pay, you can enter "Me - Services - Wallet - Transactions" to delete your transaction records one by one on the front page.

(b) When using QQ Wallet, you can enter "My QQ Wallet - Balance - Transactions" to delete your transaction records one by one on the front page.

(c) After deletion of the relevant information either by yourself or with our assistance, where the storage time limit prescribed by laws and regulations has not expired or the deletion of personal information is difficult to be realized technically, we may not able to immediately remove the corresponding information from our systems, in which case we will stop processing your personal information except for storage and taking necessary security protection measures.

(4) Disable Certain Services and Functions

(a) Disable Quick Pay Service or deposit-withdrawal functions of bank cards.

For the users of the quick pay of bank cards under Weixin Pay service, after entering Weixin, you can click "Me - Services - Wallet - Cards" → select the bank card that you intend to unlink → click the upper-right corner →click "Unlink" → enter payment password → successfully unlink bank card. For the users of the quick pay of bank cards under QQ Wallet pay service, you can click "My QQ Wallet - Balance - My Cards" → click the bank card that you intend to unlink → click the upper-right corner → click "Unlink" → click "Still Unlink" → enter payment password → successfully unlink bank card. After you have unlinked the bank card, you are no longer able to use the unlinked bank card for quick pay or use the unlinked card for withdrawal.

(b) Disable credit card repayment function.

For the users of credit card repayment function under Weixin Pay service, after entering Weixin, you can click "Me – Services - Card Repay" → click the credit card for which you intend to close the repayment function → click the management icon on the right side of the credit card at the top of the page → click the "Delete Card" displayed at the bottom of the pop-up page, you will deactivate credit card repayment function upon confirmation. For the users of credit card repayment function under QQ Wallet, after entering into QQ Wallet you can click " Card Repay" → click the credit card for which you intend to close the repayment function → click "Delete this Credit Card", then you will close credit card repayment function. After you have disabled the repayment function for a credit card, you will no longer be able to use credit card repayment function to repay the deleted credit card.

(c) Refuse to receive marketing information

If you do not want us to send financial marketing information to you as stipulated in Clause 2, Article 5 of this Privacy Policy, you may refuse it by our proposed method to disable the function. After disabling the function, you will not receive financial marketing information that we send to you.

(d) Disable personalized service.

It you do not want us to provide any personalized service by automated decision-making as stipulated in Clause 3, Article 5 of this Privacy Policy, you may close it by our proposed method. After disabling the service, you may still receive product or event information or advertisement in relevant service page, but we will not provide personalized services by automated decision-making.

(5) Cancellation of Tenpay Payment Account

(a) Cancellation of Weixin Pay account. After entering Weixin, you can enter " Me – Services – Wallet – Payment Settings" → click "Weixin Pay Cancellation", and if your account meets the cancellation conditions as prompted on the page, you can continue to cancel your Weixin Pay account.

(b) Cancellation of QQ Wallet Payment account. You can enter "My QQ Wallet", clicking the upper-right corner to enter "Settings – Customer Service Center - Cancel Account", and if your account meets the cancellation conditions as prompted on the page, you can continue to cancel your QQ Wallet Payment account.

(c) After account cancellation, all the information in your relevant account will be cleared, and we will not process personal information related to such account but the information previously collected will be stored for the period to satisfy the regulatory requirements, during which the competent authorities still have the right to inspect such information.

(6) If the product page or access path related to the above guideline is changed, please follow the instructions on the updated product page. If you are not able to consult, copy, correct, supplement, transfer, delete, close or withdraw the consent to your personal information or you need us to explain the personal information processing rules, you may contact us through the contact method provided in Article 10 of this Privacy Policy or our online customer service, and we will respond to your requests in a timely manner.

(7) For the sake of the security of your account and personal information, before we start to process your request when you ask for reviewing, copying, correction, supplement, deletion, transition or withdrawal of the consent, we may take various methods to authenticate your identity, you may need to enter your payment password, conduct face recognition or provide us with information such as your name, ID number, contact information and details of your requests. Please refer to the product page for the specific requirements.

2. HOW WE COLLECT YOUR PERSONAL INFORMATION

When you use Tenpay Services, based on different circumstances, we will collect your personal information that is provided voluntarily by you or generated from your use of Tenpay Services when you use or in order for you to use the services for the purposes of implementing statutory obligations, providing services to you and ensuring the security of your account.

(1) Where information needs to be collected for the purpose of performing real name management and anti-money laundering obligations under laws and regulations;

(a) In accordance with the PRC laws and regulations and regulatory requirements on payment services, when you register a Tenpay account (including Weixin Pay account and QQ Wallet payment account) or use the Tenpay services, you need to voluntarily provide your basic identity information (including but not limited to your name, nationality, gender, occupation, address, contact information and the type, number and validity period of your identification), otherwise you will not be able to register a Tenpay account for payment or use Tenpay Services. If you need to pass multi-factor identity authentication, you should also provide the information of your linked bank card and the cellphone number recorded by the bank that issued your bank card, otherwise you will not be able to use the Tenpay Services that require multi-factor identity authentication.

(b) According to the PRC laws and regulations and regulatory requirements relating to anti-money laundering, when you register a Tenpay account or use Tenpay Services, you need to voluntarily provide your basic identity information (including name, nationality, gender, occupation, address or office address, contact information and the type, number, and validity period of your valid ID). In the cases of specific circumstances stipulated by laws, regulations or regulatory requirements, you also need to provide a colored photo or photocopy of your valid ID for our verification and records. In accordance with PRC laws, regulations or regulatory requirements, you may also need to provide other supporting identification materials or provide your identity information again. If you fail or refuse to provide such necessary information that make us fail to fulfill the anti-money laundering obligations, we may take restrictive measures or refuse to provide you with the Tenpay Services.

To verify the accuracy and completeness of the information you submit, we will verify such information with the external verification channels (including government department database, commercial bank information system and commercial database) where your information is legally stored.

(2) Circumstances in which personal information needs to be collected for your use of our payment service

In order to provide you with payment services and to perform our obligations under the laws and regulations, we need to collect your personal information directly or through Weixin and QQ software as follows:

(a) In order for you to use the Balance Payment Service based on your payment account (including Weixin Pay balance and QQ wallet balance), and to realize the account balance top-up and withdrawal, consumption, transfer, red packet functions and other extended functions based on the payment account, we will record the balance information and transaction information in your payment account. If you do not agree with our recording of the above information, you will not be able to use the Balance Payment Service.

(b) In order for you to use the bank card Quick Pay Service, and to realize the payment account top-up and withdrawal and consumption, transfer, red packet functions and other extended functions based on the use of bank card, your bank card need to be linked to your payment account, and you need to provide information such as your name, bank card number, ID number. and the cellphone number recorded by the bank. We will conduct verification of such information with the issuing banks through our cooperative clearing institutions. If you do not provide the above information, you will not be able to use the bank card Quick Pay Service, but your use of other services provided by us will not be affected.

(c) In order for you to use the Transfer Service, you need to provide the payee’s mobile number, QQ account number, partial information of the name and transfer amount or choose a payee and provide partial information of the name as prompted on the product page. If you choose to transfer money to another person’s bank card, you need to provide the payee’s name, bank card number and the card issuing bank’s information. If you do not provide the above information, you will not be able to use the Transfer Service, but your use of other functions provided by us will not be affected. You may also fill in the transfer instructions, but without such information your use of Transfer Service will not be affected. When you use the Intra-Group Transfer Service in a group chat scenario, due to the particularity of the service scenario and the need to maintain the consistency of the service experience for users, the amount, the payee, the transfer status, the transfer time, and the receipt time of the transfer will be visible to the group members, if you do not want the group members to know the above information, you can use the Transfer Service in a single chat scenario.

(d) In order for you to use the Red Packet Service, you need to follow the instructions as prompted on the product page, select the recipient of the Red Packet and enter the amount of the Red Packet as instructed, and when sending the Red Packet in a group, you also need to enter the number of Red Packets. If you do not provide the above information, you will not be able to use the Red Packet Service, but it will not affect your use of other functions provided by us. You can also write wishes of the red packet, but without such information your use of the Red Packet Service will not be affected. When you use the Exclusive Red Packet Service in a group chat scenario, due to the particularity of the service scenario and the need to maintain the consistency of the service experience for users, the amount, the payee, the receipt status, and the receipt time of the Exclusive Red Packet will be visible to the group members, if you do not want the group members to know the above information, you can use the Red Packet Service in a single chat scenario.

(e) In order for you to use the Split Bill Service, when you launch a payment request through Split Bill function, you need to follow the instructions as prompted on the product page, select the recipient or group chat and input the total amount and number of people. If you do not provide the above information, you may not be able to initiate group payment, but it will not affect your use of other services provided by us.

(f) When you use the Credit Card Repayment Service, you need to provide the number and the holder’s name of the credit card and the repayment amount. If you do not provide the above information, you will not be able to use the Credit Card Repayment Service, but your use of other functions provided by us will not be affected.

(g) When you use the Utilities Expense Payment Service (including electricity, water, gas, fixed line, broadband, cable TV, fuel card top-up, ETC application, heating, etc.), depending on the specific service that you use, you may need to provide information such as your phone number, name, ID number and necessary expense payment information (such as payer, subscriber number, fixed number, broadband number, fuel card number, vehicle registration number, engine number or frame number). If you do not provide the above information, you will not be able to complete the corresponding utilities expense payment, but your use of other functions provided by us will not be affected. In addition, in order to determine the specific type of utilities expense in your area, we may apply for your authorization for and you may follow the instructions as prompted on the page and click agree to turn it on. If you do not agree to grant such authorization, you may manually choose your city, which will not affect your subsequent use of the Utilities Expense Payment Service provided by us.

(h) To perform the relevant obligations in accordance with the laws and regulations and to provide you with Payment and Transaction Inquiry Services, we need to record and manage your transaction information. We need to collect and record relevant transaction information directly or collect through our cooperative partners, including transaction number / transfer number, identification of both parties (such as the names, nicknames, remark names, avatars of the payer and the payee, and the name of the merchant), account number (such as payment and receipt account number, bank card number or name of issuing institution, etc.), transaction amount, transaction time, product information, payment method, delivery information, etc. If you do not agree that we record the transaction information, the transaction cannot be completed.

(i) Where you use other services or functions involve the collection of your personal information, we will explain the scope and purpose of the information collection to you through separate agreements, prompts and other means and obtain your consent, except where the consent of the individual concerned is not required according to laws and regulations. We will process and protect your information in accordance with this Privacy Policy or the corresponding service agreement. If you do not agree, you will not be able to use such service, but your use of other Tenpay Services will not be affected.

(3) Information needs to be collected for the security of your account, funds, payment and the prevention of risk

(a) In order to protect the security of your account and funds, we need to verify the transactions in the scenarios where you use the Tenpay Services to initiate such transactions. The verification methods of the transactions may include static passwords, one-time passwords, digital certificates, biometric information, etc. Depending on the transaction scenarios and security risks, we may collect authentication information such as payment password, ID number (for opening digital certificate), SMS dynamic code to verify your identity when you initiate a transaction. We may also collect biometric information (e.g. face information, palm information) when you activate and use biometric-related payment services (e.g. face payment, palm payment) in specific scenarios. You can learn the specific rules through the corresponding service agreements. If you do not activate the biometric-related payment functions, you will not be able to use the biometric-related payment services, but it will not affect your use of other payment service functions.

(b) In order for you to use the payment service safely, if your cell phone and client end software version support fingerprint recognition function, you can choose to activate the fingerprint payment function provided by us. You need to input your fingerprint information on your cell phone. Your fingerprint information is only stored on your mobile to which we will not have access. When you use fingerprint verification, the extraction and verification of your fingerprint feature information will be completed on your device end, and we will only obtain and collect the verification results from the device terminal. If you do not activate the fingerprint function, you will not be able to use the fingerprint payment, but it will not affect your use of the function that can complete the authentication by entering your password or other means.

(c) In order for you to use the payment service safely, if your mobile and client end software support face verification function, you can choose to activate the Face Pay function provided by us. You will need to input your facial information on your device and your facial information is only stored on your mobile to which we will not have access. When you use face verification, the extraction and verification of your face features will be completed on your device end, and we will only obtain and collect the verification results from the device terminal. If you do not activate the face verification function, you will not be able to use the face payment function, but it will not affect your use of the function that can complete the authentication by entering your password or other means.

(d) In order to protect the security of your account and funds, we may verify your identity in the scenarios where you need to retrieve your password, request for freezing or unfreezing your account, request for the removal of transaction restrictions, request for an electronic receipt, or do other operations. You need to provide us with some information that can verify your identity or transaction, such as a photocopy of your ID card, a photo of your hand-held ID card, your contact information, proof of the transaction, proof of your legal rights to the payment account and funds in the account, etc. (details are subject to the instruction as prompted on the page or the customer service requirements). If you do not agree to provide such information, you will not be able to complete relevant operations but it will not affect your completion of other operations or your use of other services we provide.

(e) In order to perform the legal obligations including anti-money laundering, anti-telecom and online fraud, and risk management under laws and regulations, to improve the security of your use of our services and to better prevent transaction and funds risks, we will collect information such as the equipment, system network and operational behaviour related to the Tenpay Services during your use of Tenpay Services or through Weixin, QQ software and merchants transacted with you, including information of payment acceptance terminal system, unique device identifier (identification information such as MAC and IMEI of the device that can identify the device), hardware device model number, terminal system type, software installation information, software version information, software language settings, internet protocol address (IP address), mobile network information (such as Wi-Fi information), device location, your location, network log, habits of using network, and operational behaviour records of your use of the Tenpay Services. If you do not agree to our collection of the above information, the security verification of the transaction environment and the notification of transaction information could be affected.

(4) Collect personal information indirectly through a third party or services provided by a third party

(a) When you use the Tenpay Services by logging in through Weixin account or QQ account and further use the payment service provided by us. Your login information would be the account or tag for us to recognize your login and usage of Tenpay Services as well. Therefore, in order to effectively recognize your identity, you understand and agree that the Operator of Weixin and QQ Software has the right to provide us with your login information (including Weixin account and user identification information, mobile number, QQ number and email address) and agree that we can link the above information to your Tenpay account. If you do not agree to provide the login information, you will not be able to use Tenpay services via Weixin and QQ software.

(b) If you use our payment service through other channels and there is any need for us to obtain your personal information from a third party, which is not provided under this Privacy Policy, we will expressly inform you of the source, category and usage scope of such information before obtaining it. If the personal information processing activities we need to carry out exceed the scope of what agreed in agreements or your initial consent to the third party, we will request your express consent before processing your personal information except for otherwise stipulated by laws and regulations. In addition, we will also strictly comply with relevant PRC laws and regulations and require the third parties to ensure the legality of the personal information they provide.

(5) Exclusions for third parties’ collection of personal information

If you enter a third party’s product page through a product provided by us, please note that third party services are provided by third parties. Where the third party collects personal information directly from you, we suggest that you carefully review the third party's privacy policies.

3. HOW WE USE COOKIES AND OTHER SIMILAR TECHNOLOGIES

（1） When you use Tenpay Services, we may save your login status and assign you one or more "cookies" (a small text file). For example: when you access to any information or service that needs you to log in, we will save your login name encrypted in a cookie file on your device when you log in. As this is an irreversible encrypted storage, other people will not be able to recognize your login name even if they can use your device. All collection, saving and encryption work is done automatically by the system, and you do not need to do any extra work.

（2） The cookie files will be stored on your computer's hard disk or on the device's flash memory, and they can only be read by the server that set them. You can delete them at any time using a browser or operating system software with the function of clearing cookies.

（3） In order to provide you with more convenient, faster and smoother services, we provide you with the following services through cookies and other similar technologies:

(a) Remembering your account. For example, cookies may help you avoid repeating the steps of logging into your Tenpay account to use Tenpay Services.

(b) Analyzing your use of Tenpay Services. For example, we may use cookies and other technologies to know the specific purpose of your use of Tenpay Services, or which pages or services are your favorite.

(c) You can select the "do not use cookies" setting via your browser. While doing so may affect your use of Tenpay Services or prevent you from enjoying a safer, faster, smoother and more personalized service, this won’t affect your normal use of other Tenpay Services.

(d) Cookies technologies may also be used by Tenpay's third party advertising partners. The collection and use of such information by a third party through cookies is subject to the privacy policy of such third party rather than this Privacy Policy. We suggest that before you use the services provided by a third party through cookies, you should read the third party’s privacy policy carefully and decide whether you agree to their privacy policy.

4 HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION

(1) In accordance with the PRC laws and regulations, your personal information that we collect in the PRC territory will be stored in the PRC territory and are kept strictly confidential according to laws. If you use the cross-border payment services provided by us, please further read the Cross-Border Payment Service Privacy Policy.

(2) We will store your personal information for as long as it is necessary for your use of Tenpay Services within the storage period under the PRC laws and regulations or regulatory requirements. For example, we will store your information including identity information and transaction information within the period stipulated in the "Detailed Rules for the Implementation of the Administrative Measures for the Payment Services Provided by Non-financial Institutions", "Implementation Measures of the People's Bank of China for Protecting Financial Consumers' Rights and Interests", "Measures for Administration of Anti-money Laundering and Anti-terrorist Financing by Payment Institutions", and other regulations. After the period regulated by PRC laws and regulations, we will delete or anonymize your personal information in accordance with the requirements of PRC laws and regulations.

(3) In order to ensure the security of your personal information, we will take reasonable and necessary measures to protect your information at the current level of technology. We adopt physical protection, security technology, management systems and other measures to reduce the risks of loss, misuse, and unauthorized access, disclosure and change of your information, and the specific measures include de-identification, encrypted data transmission, firewalls, encrypted storage, physical access control and information access authorization control. We have set up security procedures to protect your information from unauthorized access, and all personal information is encrypted and stored in an internal system strictly protected by a firewall.

(4) In order to ensure the security of your personal information, we have established special management systems, procedures and organizations. For example, we strictly limit the scope of authorized personnel who can access to user’s personal information, require such persons to comply with confidentiality obligations and conduct audits.

(5) When you use Tenpay Services, please keep your Tenpay account and its password properly. We will identify you by your account number and password. If your Tenpay account and password are compromised, you may lose your information, and adverse legal consequences may arise out of the compromise. If you find that your Tenpay account and password has been or will be compromised, please contact us immediately so that we can take appropriate measures in time to prevent or reduce related losses.

(6) In the event of a security incident such as personal information leakage, we will initiate an emergency plan to prevent the expansion of the security incident, and promptly notify you of the above security incidents in the form of notifications, phone calls, announcements, etc. If we cannot contact you through the above methods, we will post relevant warning information through the Tenpay official website; please pay close attention to our official website.

(7) If you voluntarily cancel your Tenpay account and terminate your use of Tenpay Services, we will stop processing your personal information, unless otherwise required by PRC laws, regulations or regulatory requirements. If our products or services cease to operate, we will also stop the processing of your personal information in a timely manner. We will inform you of the suspension of operations either through direct communications with you or through an announcement on the official website of Tenpay, and your personal information stored will be deleted or anonymized except as otherwise provided by laws and regulations.

5. HOW WE USE YOUR PERSONAL INFORMATION

(1) Based on the relevant laws and regulations, regulatory requirements and agreements, we will use your personal information in the following circumstances, with adequate information security measures to ensure the security of personal information:

(a) for the purpose of the above collection and for the provision of Tenpay Services by us to you.

(b) for identity verification, customer service, anti-money laundering customer due diligence, anti-money laundering beneficial owner identification, security precautions, risk warning, transaction monitoring, prevention or prohibition of illegal activities, archiving and backup purposes and other purposes under laws and regulations and related to services.

(c) for data analysis, application study, comprehensive statistics and business decisions after being processed by de-identification, anonymization, and other security methods.

(d) for resolution of the disputes related to you.

(2) In order to improve the user experience of our products and services, we may use the information we collect for the purposes such as marketing, improvement of user experience or market research. If you agree to our use of the information we collect for the aforesaid purposes, you may get a better user experience, receive marketing information that may be of interest to you, or participate in our market research activities. If you do not agree to our use of your information to send marketing information to you, you can click here to learn more about the specific circumstances and unsubscribe; if you do not agree to our use of your information for the purposes such as marketing, improvement of user experience or market research, you can call our customer service hotline or follow our instructions to make adjustments or unsubscribe. If you choose to unsubscribe, we will not continue to use the information we collect to send marketing information to you and you will still be able to use the products and services we provide in accordance with the agreement.

(3) In order to meet your requirements on personalized services, we may also use the information we collected to display product information or commercial marketing information on relevant pages by automated decision-making. If you do not wish to have product information or commercial marketing information displayed based on your personal characteristics, you can click here to learn more and disable it, or follow the instructions on the product page for disabling. The aforesaid automated decision-making method refers to activities where a computer program automatically analyses and evaluates the behavior and interests of individuals and makes decisions.

(4) If we intend to use your personal information for purposes other than those specified in agreements or this Privacy Policy, or the use exceeds the scope of the purposes indicated to you when collecting such information and is not directly or reasonably related to such purposes, we will obtain your consent again before such use, in accordance with the laws and regulations, except in cases where individual consent is not required by laws and regulations. For example, we may obtain your consent by requesting that you click “Agree”.

6. HOW WE PROVIDE YOUR PERSONAL INFORMATION

(1) Provision to Third Parties

We will keep your personal information strictly confidential, and in order to provide you with services, to perform our obligations under the laws and regulations, or have obtained your consent, upon the occurrence of one of the following situations, we may disclose your personal information with third party entities, third parties include our affiliates, cooperative financial institutions, government authorities and our partners (the "Third Parties"). Before disclosing any personal information to Third Parties, we will evaluate in accordance with laws and regulations, execute relevant legal documents with third parties and take protective measures to protect your personal information and require them to process your personal information in a manner complying with the laws and regulations. Where your consent is required, we will inform you in accordance with the relevant provisions and obtain your consent in the form of you clicking to confirm the agreements or click to confirm in specific scenarios, specifically:

(a) In order for you to use certain of our services or product functions, where we need the assistance of Third Parties or provide services jointly with Third Parties’ products, we can only provide such services to you after providing necessary information to the Third Party. For example, to facilitate your use of our payment services, when you register for a payment account or use services such as Red Packets, Transfer and Split Bill, or we send service notifications through Weixin and QQ Software, we will provide the necessary information, such as the user identification information of both parties to the transaction and their status associated with their Weixin account or QQ account, payment methods, order information, transaction status, to the Operator of Weixin and QQ Software.

(b) In order to comply with the laws and regulations process your bank card transactions and provide you with bank card Quick Pay services, we will provide the issuing banks with your transaction information, including the transaction type, the name of the merchants who provide the goods or service, name and account of the payer and the payee, date of the transaction, time of the transaction and the amount of the transaction through clearing institutions. If you do not agree that we provide the clearing institutions and issuing bank with such information, you will not be able to use our payment services.

(c) In order to process the payment and receipt of your funds, we may provide your information to the counterparty of your transaction. For example, when a Third Party transfer to your Tenpay account through Tenpay Services, your mobile number, QQ number and name associated with your Tenpay account may be provided to us and we will provide certain portions of your registration information to the Third Party for the Third Party to confirm whether the receipt information is correct. When you use our services to make a payment to recipient or domestic or overseas merchants, we will send necessary information such as user identification information and transaction information to the recipient, the cooperative institutions, and the merchants in assistance to complete the transaction; we may also send necessary risk information to transaction-related cooperative institutions and merchants to prevent transaction risks. If you do not agree that we provide such information to the third party, you may not be able to use our payment services.

(d) When you use the Tenpay Services through any Third Parties, we may also share some necessary information about you with the Third Parties where necessary. If you do not agree to provide such information, you may not be able to use the services provided by the Third Parties. For example, when you purchase goods or services through the platforms of any Third Parties and pay for them through Tenpay Services, we may provide and send relevant payment information to the Third Parties to help you complete the transaction.

(e) When you log in any Third Parties’ website through your Tenpay account, we may provide some of your personal information to the Third Parties based on your explicit authorization in order to facilitate your use of the Third Parties’ websites. Such Third Parties’ websites are subject to their own privacy policies. Therefore, before providing your personal information to the Third Parties, we suggest you carefully read the personal information processing rules of the Third Parties’ website.

(f) We may cooperate with Third Parties to organize joint marketing campaigns and where you participate in such campaigns, we may share with them certain information generated during the campaigns and information that are necessary to facilitate your participation in these campaigns, so that such Third Parties can contact you and award you prize. We will clearly inform you of the category of personal information that needs to be provided to any Third Parties on the rules page of such campaigns or through agreement or other methods of communication.

(g) Where there is a complaint filed against you by other users, or where you are filing a complaint (e.g. denying a transaction), we will provide your identity information, transaction information and other relevant information to the consumer protection agency, cooperative banks, clearing institutions, self-regulatory organizations and relevant regulatory authorities that handle the complaints to resolve disputes about the complaints, except as otherwise explicitly prohibited by the PRC laws and regulations.

(h) In order to comply with the laws and regulations, implement the regulatory requirements, maintain sound financial order or prevent telecom and online fraud and other illegal activities such as fraud, and reduce the credit risk and maintain the safe and stable operation of the services provided, we may exchange necessary risk information with financial-related organizations (including cooperative banks, clearing institutions, payment institutions and self-regulatory organization) or Operator of Weixin and QQ Software.

(i) In order to prevent the risk of fraud, safeguard transaction security, and protect your personal and property safety from being infringed upon, in specific transaction scenarios, we will work with the operating entities of WeChat and QQ software to provide you with services such as order status alerts and transaction progress confirmation, etc. When you use such services, we will provide the operating entities of WeChat and QQ software with the user identification information related to your transaction, order information (including order number, order amount, order time, order status, etc.).

(j) When the administrative authorities or judiciary authorities inquire your identity information, account information, transaction information and other payment information according to the requirements of the PRC laws, regulations and regulatory requirements, we will provide the above information accordingly.

(k) We may also provide your personal information with Third Parties according to other agreements between you and us on information sharing or when have obtained your separate consent under specific situation.

(2) Entrusted processing

In order to promote the quality and efficiency of information processing, we may entrust the competent cooperative organizations to process the information on behalf of us to the extent entitled by laws. We will abide by the relevant provisions of the PRC laws and regulations on entrusted processing, thoroughly examine and evaluate the capacity of such cooperative institutions to protect personal information, require the cooperative institutions to abide by strict confidentiality obligations through written agreements, auditing and other manners, take technique measures to desensitize the information which is entrusted to be processed, and prohibit the entrusted party from using the information for any purposes other than those stipulated by laws and regulations and agreed by the parties or any purposes without your authorization. Upon the termination of entrustment, we will request the cooperative organization cease to store the relevant information.

(3) Transfer

In the event of any merger, division, dissolution acquisition, asset transfer, asset reorganization or declaration of bankruptcy, etc., where your personal information is involved to be transferred to any Third Parties, we will inform you of the name and contact information of the recipient and require the new company or organization holding your personal information to continue to be bound by this Privacy Policy.

(4) Public Disclosure

We will not disclose your personal information to the public. If public disclosure is necessary, we will inform you of the purpose of such public disclosure, the type of the disclosed information and sensitive information which may be involved, as well as obtain your separate consent except for otherwise stipulated by laws and regulations.

7. CIRCUMSTANCES WHERE PERSONAL INFORMATION COULD BE PROCESSED WITHOUT YOUR CONSENT

According to the relevant laws and regulations, we may process your personal information without your consent under following circumstances:

(1) necessary for the conclusion or performance of the contract between you and us;

(2) necessary for us to perform statutory duties or obligations;

(3) necessary for the response to a public health emergency or for the protection of the life, health and property safety of you or other natural persons;

(4) processing within the reasonable scope of any personal information for the purposes of news reporting, supervision by public opinions for the public interest and other activities;

(5) processing within the reasonable scope of any personal information that you disclose or that has been lawfully disclosed;

(6) other circumstances stipulated by laws and regulations that do not require your consent.

8. HOW WE PROTECT THE RIGHTS OF MINORS

(1) We place special emphasis on protection of personal information of minors. According to the PRC laws and regulations, if you are a minor under 18 years old, we suggest that you should ask your parent(s) or guardian(s) to carefully read this Privacy Policy; provide us with your personal information only after obtaining the consent of your parent(s) or guardian(s), and use our services under the guidance of your parent(s) or guardian(s). If your parent(s) or guardian(s) disagree with the provision of your personal information to us or your use of Tenpay Services, please stop providing your personal information to us or using our services immediately and notify us as soon as possible so that we can take effective measures.

(2) If you are a minor under 18 years old, for the collection of your information with the consent of your parent(s) or guardian(s), we will only use such information when permitted by PRC laws and regulations as well as with the explicit consent of your parent(s) or guardian(s).

(3) If you are a parent or guardian of a minor, when you have any questions about the personal information of the minor under your guardianship, please contact us through the contact information stipulated in Article 10 of this Privacy Policy.

(4) We also formulated the Tenpay Children's Privacy Protection Statement for the protection of the personal information of children. Children and their guardian(s) should read the Tenpay Children's Privacy Protection Statement carefully before enacting and using our payment services.

9. HOW WE UPDATE THIS PRIVACY POLICY

(1) When there is any major change affecting this Privacy Policy, we will update this Privacy Policy and notify you promptly in any of the following ways:

(a) sending you pop-up alerts when you log in to relevant client-end application or you use Tenpay Services;

(b) sending you pop-up alerts when you update your application;

(c) sending you short message notifications, emails, etc. when you use Tenpay Services;

(d) posting an announcement on Tenpay's official website.

(2) Major changes affecting this Privacy Policy include any of the followings:

(a) major changes of our service model, such as the purpose of processing personal information, categories of the personal information processed, and the ways we use personal information;

(b) major changes of our corporate status, such as ownership change caused by business adjustments, bankruptcy or mergers etc.;

(c) changes to the parties to which we disclose or provide personal information;

(d) changes to the time period of retention or the deadline of destruction of personal information;

(e) major changes of the method or access which the users can exercise their rights in respect of their personal information;

(f) changes to the internal departments for personal information protection, contact information or complaint channels; and

(g) high risk as indicated by the personal information protection assessment.

10. CONTACT US

If you have any questions about this Privacy Policy, or any related complaints or advice, please call 0755-86013860. You can also send your questions to Tenpay_dataprivacy@tencent.com, or mail to the following address: Financial Legal and Compliance Department, Tencent Binhai Building, No.33 Haitian Second Road, Nanshan District, Shenzhen, Guangdong, PRC, post code: 518064. We will review your questions as soon as possible, deal with them promptly after verifying your identity, and reply to you within fifteen days or the period required by PRC laws and regulations.

Tenpay Payment Technology Co., Ltd.

Cross-Border Payment Service Privacy Policy

This Cross-Border Payment Service Privacy Policy (hereinafter referred to as “Privacy Policy”) applies to the cross-border payment service provided by Tenpay Payment Technology Co., Ltd. (“we” or “Tenpay”) through WeChat software for transactions between users who have enabled WeChat Pay services (hereinafter referred to as “you”) and entities located outside the territory of the PRC (for the purposes of this Privacy Policy, referring to countries and regions outside mainland China, including Hong Kong, Macau, and Taiwan) (hereinafter referred to as “Service”).

Please note that this Service is an extension of WeChat Pay services beyond the territory of the PRC. Therefore, for matters not covered by this Privacy Policy, the Tenpay Privacy Policy shall prevail. In case of any inconsistency or conflict between the terms of this Privacy Policy and the terms of the Tenpay Privacy Policy, this Privacy Policy shall prevail.

1. Provision of Personal Information

(1) In order to perform the WeChat Payment System User Service Agreement that you have entered into with us and to provide you with the Service, we will cooperate with domestic banks to process your cross-border transaction funds, and may provide your personal information for domestic banks as required so that domestic banks can complete cross-border payment settlements and fulfill legal obligations related to anti-money laundering, risk control and international balance of payments declaration. If you do not agree to the provision of such information, you will not be able to use the Service.

- In cases where we act as an agent for you to apply to domestic banks for purchase and payment of foreign exchange, for the purpose of completing the purchase of foreign exchange and cross-border payment of funds, we will provide your personal basic information (name, nationality, address, mobile number), personal identification information (ID type, ID number), and personal financial information (transaction information including transaction order number, payment order number, item name, quantity, transaction date and time, currency, amount, logistics information) for Bank of China Limited and Industrial and Commercial Bank of China Limited..

- In cases where we do not act as an agent for you to apply to domestic banks for purchase and payment of foreign exchange, for the purpose of completing cross-border transaction fund settlements, we will provide your personal basic information (name, mobile number), personal identification information (ID type, ID number), and personal financial information (account information and transaction information including transaction order number, payment order number, item name, quantity, transaction date and time, currency, amount, logistics information) to Industrial and Commercial Bank of China Limited and China CITIC Bank Corporation Limited.

(2) In order to process your transaction funds, domestic banks will collect, store and use the aforementioned personal information. We will conduct the personal information protection impact assessment and record the processing details in accordance with the Personal Information Protection Law before providing the aforementioned personal information to domestic banks. We will only share your information for legitimate, proper, necessary, specific and explicit purposes as stated in this Privacy Policy. Domestic banks will only have access to the information necessary for performing their responsibilities related to cross-border transaction fund settlements, and they are prohibited from using such information for any other purposes. The names and contact information of the domestic banks are as follows. You may contact these domestic banks to further claim your personal information rights in connection with the processing activities of personal information:

Industrial and Commercial Bank of China Limited

Contact number: 95588

China CITIC Bank Corporation Limited

Contact number: 95558

Bank of China Limited

Contact number: 95566

2. Cross-Border Transfer of Personal Information

(1) In order to perform the WeChat Payment System User Service Agreement that you have entered into with us and to provide you with the Service, we will directly settle transaction funds to overseas merchants or settle transaction funds to overseas merchants through our overseas cooperating entities or overseas affiliates. During this process, after implementing appropriate encryption measures, we will provide the following personal information about you to overseas merchants, overseas cooperating entities and overseas affiliates (collectively referred to as “Overseas Recipients”), among which, bolded data are your sensitive personal information, and without processing your such sensitive personal information in the aforementioned manner, we will be unable to provide you with this Service. If your sensitive personal information is leaked or illegally processed, it may result in harm to your personal and property rights. Therefore, we have adopted appropriate administrative and technical security measures to protect your sensitive personal information as required by law. If you do not agree to the provision of such information, you will not be able to use this Service:

(a) In order to facilitate the completion of cross-border transaction fund settlements, we will collect, generate, and cross-border transfer your personal financial information (transaction information, specifically including order number, transaction amount, currency, transaction time, transaction type) and online identity information (personal information subject account) to overseas merchants or overseas cooperating entities. Overseas merchants or overseas cooperating entities will store, use your aforementioned personal information and encrypt sensitive information in compliance with the laws. Overseas cooperating entities will also transfer your aforementioned personal information to the relevant overseas merchants involved in the transactions. Due to the substantial number of our overseas cooperating entities and overseas merchants, if you need to know the names and contact details of the overseas merchants or overseas cooperating entities involved in your cross-border transactions and further claim your personal information rights (such as inquiry, replication, explanation, correction, supplementation, etc.), you may consult via wxpayglobal@tencent.com.

(b) In order to facilitate cross-border transaction fund settlements and reduce cross-border settlement costs, we may cooperate with our overseas affiliates, WeChat Pay Hong Kong Ltd. (hereinafter referred to as “WPHK”), or Zhenxing Technology Limited (hereinafter referred to as “Zhenxing”). For this purpose, we will provide your personal financial information (financial transaction information, specifically including transaction order number, merchant order number, transaction amount (foreign currency), transaction amount (RMB), transaction currency, selling currency (RMB), transaction time, transaction type, trade type) for WPHK or Zhenxing located in Hong Kong, China. WPHK or Zhenxing will store, use your aforementioned personal information, and encrypt sensitive information in compliance with the laws, and transfer your aforementioned personal information to overseas banks they cooperate with. WPHK’s customer service email is hkpay@wechat.com, and Zhenxing’s personal information protection contact email is wisefx_personaldata@tencent.com. You may contact WPHK or Zhenxing via the aforementioned emails to claim your personal information rights (such as inquiry, replication, explanation, correction, supplementation, etc.).

(c) If you participate in overseas entities’ marketing activities (including but not limited to our overseas cooperating entities, overseas merchants and overseas governments) conducted through us or in cooperation with us, and in order to complete your participation in such marketing activities, we will cross-border transfer your personal financial information (transaction information, including order number, currency, discount amount, coupon quantity) to Zhenxing for the purpose of settling the promotional funds related to the marketing activities. Zhenxing will store and use your aforementioned personal information. Zhenxing’s personal information protection contact email is wisefx_personaldata@tencent.com. You may contact Zhenxing via the aforementioned email to claim your personal information rights (such as inquiry, replication, explanation, correction, supplementation, etc.).

(d) If you are involved in cross-border transaction-related disputes with overseas merchants and submit a complaint to Tenpay, in order to assist you in resolving the dispute with the overseas merchants, we may collect, use, and cross-border transfer your personal financial information (transaction information, specifically including order number, currency, amount, transaction time), online identity information (personal information subject account), and basic personal information (personal name, personal phone number, email address) for the overseas merchants or our overseas cooperating entities (specific types of personal information and data will be communicated separately with you at that time) so that the overseas merchants or our overseas cooperating entities can check the information and resolve the dispute. The relevant overseas merchants or our overseas cooperating entities will store, use your personal information and encrypt sensitive information in compliance with the laws. Our overseas cooperating entities will also transfer your personal information to the relevant overseas merchants. If you need to know the names, contact details of the relevant overseas merchants or overseas cooperating entities, and further claim your personal information rights (such as inquiry, replication, explanation, correction, supplementation, etc.), you may consult via wxpayglobal@tencent.com.

(2) We will conduct the personal information protection impact assessment and record the processing details in accordance with the Personal Information Protection Law in advance. We will only cross-border transfer your personal information for legitimate, proper, necessary, specific and explicit purposes as stated in this Privacy Policy. Overseas Recipients will only have access to the information necessary for performing their responsibilities, and they are prohibited from using such information for any purposes other than completing your cross-border transaction fund settlements. The overseas recipients will store personal information for the shortest period necessary to achieve the processing purpose.

(3) According to overseas laws and for the purpose of completing this Service, there may be cases where your personal information is re-transferred after being transferred abroad. In such cases, we will require that the re-transfer of your personal information by the Overseas Recipients be strictly limited to the purpose of completing your cross-border transaction fund settlements, and both the Overseas Recipients and third parties involved shall comply with applicable laws and regulations to ensure the security and compliant use of your personal information. You may further inquire with the Overseas Recipients about the names and contact information of the third parties, methods and procedures for exercising your rights as a personal information subject regarding the re-transfer of personal information, to safeguard your legitimate rights and interests concerning personal information.

(4) The countries/regions of the Overseas Recipients and the recipients of the retransmission may have different data protection laws or may not have relevant laws at all. In such cases, we will ensure that your personal information receives an equivalent level of protection as it would within the territory of the PRC. If you do not agree to the cross-border transfer of your personal information or if you would like to obtain more information, please contact us in accordance with the Tenpay Privacy Policy, we will handle your correspondence appropriately, and please note that the cross-border payment service will be unavailable if you do not agree to the cross-border transfer of your personal information.

International Card Payment Service Privacy Policy

This International Card Payment Service Privacy Policy (hereinafter referred to as “this Privacy Policy”) applies to the international card (also known as “Foreign Card”) payment service (hereinafter referred to as “International Card Payment Service” or “Service”) provided by Tenpay Payment Technology Co., Ltd. (hereinafter referred to as “we”) to users who add international cards to WeChat Pay (hereinafter referred to as “you”). In accordance with the PRC laws, regulations and relevant regulatory requirements, if you only bind an international card and have not completed real-name authentication, you can only use the quick pay service for consumption payments and are unable to use the balance payment service or the quick payment service for functions such as recharging, transferring, or receiving transfers to the “Balance”.

Please note that this Service is provided on the basis of WeChat Pay, to enable this Service, you need to enable WeChat Pay and open a WeChat Pay account in advance. Therefore, the WeChat Payment System User Service Agreement and Tenpay Privacy Policy that you have already entered into apply to this Service. The Tenpay Privacy Policy is a general rule for processing users’ personal information. Therefore, for matters not covered by this Privacy Policy, the Tenpay Privacy Policy shall prevail. In case of any inconsistency or conflict between the terms of this Privacy Policy and the terms of the Tenpay Privacy Policy , this Privacy Policy shall prevail.

1. Provision of Personal Information

In order to perform the WeChat Payment System User Service Agreement that you have entered into with us and to provide you with the Service, we will cooperate with domestic banks to process the cross-border transaction funds from your use of international card payments, and may provide your personal information for domestic banks as required so that domestic banks can complete the international card cross-border payment settlements and fulfill legal obligations related to foreign exchange data reporting, international balance of payments declaration and review of transaction authenticity and legality. If you do not agree to the provision of your personal information, you will not be able to use the International Card Payment Service. The personal information we will provide for domestic banks includes:

Ÿ Personal basic information: name (Chinese and English), payer type, country/region code

Ÿ Personal identification information: ID type, ID number

Ÿ Personal financial information: account information (card number), authentication information (term of international card, CVV), financial transaction information (business number, transaction number, transaction type, transaction time, payment currency, amount)

In order to process your transaction funds under international card payment, domestic banks will collect, store and use the aforementioned personal information. We will conduct the personal information protection impact assessment and record the processing details in accordance with the Personal Information Protection Law before providing the aforementioned personal information to domestic banks. We will only share your information for legitimate, proper, necessary, specific and explicit purposes as stated in this Privacy Policy. Domestic banks will only have access to the information necessary for performing their responsibilities related to cross-border transaction fund settlements, and they are prohibited from using such information for any other purposes. Please refer to the “List of Domestic Banks ” for the names and contact information of the domestic banks. You may contact these domestic banks to further claim your personal information rights.

2. Cross-Border Transfer of Personal Information

In order to provide you with the International Card Payment Service, you understand and agree that, after our provision of your personal information to domestic banks, domestic banks will cross-border transfer part of your personal information to the international card organizations so that domestic banks can complete the international card cross-border payment settlements as required by the international card organizations. The personal information to be provided by domestic banks to the international card organizations includes:

Ÿ Personal basic information: name

Ÿ Personal financial information: account information (card number), authentication information (term of international card, CVV)

In order to complete the international card payment cross-border settlements, the international card organizations will re-transfer the aforementioned personal information to the issuing bank of your international card.

We will conduct the personal information protection impact assessment and record the processing details in accordance with the Personal Information Protection Law in advance. The domestic banks will perform their compliance obligations relating to cross-border transfer of personal information in accordance with relevant laws and regulations. You may contact domestic banks (see the “List of Domestic Banks ”) for the names and contact information of the international card organizations and contact the international card organizations to further claim your personal information rights.

If you do not agree to the cross-border transfer of your personal information or if you would like to obtain more information, please contact us in accordance with the Tenpay Privacy Policy, we will handle your correspondence appropriately, and please note that the International Card Payment Service will be unavailable if you do not agree to the cross-border transfer of your personal information.