Last updated: 2021-12-20
Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.
Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.
What information do we need to provide the Service?
If you are subject to this Privacy Policy, certain personal information will be collected and processed in order for us to facilitate your use of Weixin in a Relevant Jurisdiction (as defined below). If you need to get in touch with us, then we will also retain some information so that we can get back in touch with you and address your concerns. We also use your information for account and transaction verification, security purposes and to support and improve the Service. More Information.
Who do we share your information with?
We only share your information with third parties or affiliates where necessary. For example, certain information will be shared with third party merchants that you conduct a transaction with using the Service. We may also use a third party service provider to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the Service. We may also be required by a court or legal obligation to disclose certain information in some circumstances. More Information.
Where do we process your information?
The personal information that we collect from you will be transferred to, stored at, and processed in the PRC under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC. More Information.
How long do we keep hold of your information?
We retain your information for the period during which you maintain an account for the Service, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. More Information.
How can I exercise my rights over my information?
If this Privacy Policy applies to you then you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.
How to get in touch with us
Questions, comments and requests regarding this policy are welcomed and should be addressed to wechatpayprivacy@tencent.com.
How will we notify you of changes?
Any changes we will make to this Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this Privacy Policy.

1. INTRODUCTION

WeChat Pay Europe B.V. (“we”, “our”, “us”) is committed to protecting and respecting your privacy. We are a company established in the Netherlands with registered address at Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands.

This Privacy Policy explains when, how and why we collect and process your personal information in connection with your use of Weixin Pay in the European Economic Area (the “EEA”), the United Kingdom of Great Britain and Northern Ireland (the “UK”), or Switzerland (together, the “Relevant Jurisdictions” and each a “Relevant Jurisdiction”).

Weixin Pay is the fund transfer service provided by Tenpay Payment Technology Co. Ltd. (“Tenpay”) via the WeChat or Weixin application and the Weixin public platform. When you use Weixin Pay in the Relevant Jurisdiction (the “Service”), for the purpose of the General Data Protection Regulation, we are the data controller of the personal information collected and processed under this Privacy Policy.

Note: This Privacy Policy only applies to users who have the Weixin Pay functionality and who ordinarily reside in a Relevant Jurisdiction. In order to have the Weixin Pay functionality, you must have a bank account in the People’s Republic of China (“PRC”) and have entered into the WeChat Payment User Service Agreement[CN1] . In order to use the Weixin Pay functionality in the Relevant Jurisdictions, you must have entered into the supplementary European WeChat Payment Addendum [CN2] by expressly acknowledging a notification regarding your use of Weixin Pay in the Relevant Jurisdictions. If you do not ordinarily reside in a Relevant Jurisdiction, this Privacy Policy does not apply to you; please refer to the standard Weixin Pay privacy policy here.

Please read this Privacy Policy carefully – it is important for you to understand how we collect and use your personal information, and how you can control it. If you do not agree with this Privacy Policy, you should not use the Service.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at wechatpayprivacy@tencent.com.

2. What types of personal information do we collect and how do we use it?

This section describes the different types of personal information we collect from you and how we use it.

Personal Information

Use

Information you provide to us (either directly or through Tenpay)

Account Information. Your name, WeChat or Weixin ID, open ID, phone number linked to your WeChat or Weixin ID, profile photo, nickname, and mobile telephone number.

Legal Basis: Necessary to perform our contract with you to provide the Service.

We use this information to enable your Weixin Pay account for use of the Service.

Biometric data. Voice data which you provide to us for payment account security authentication and identification purposes.

Legal Basis: We collect this information with your consent.

We use this information for payment account security authentication and identification purposes.

Location Information. Frequent login location, registration location, current location.

Legal Basis: It is in our legitimate interest to determine whether you are located in a Relevant Jurisdiction and ensure that your account is kept secure.

We use this information to:

· determine you are in a Relevant Jurisdiction (such that this Privacy Policy applies to you);

· protect and secure your account and your transactions.

KYC Information. Your name, bank card number and expiration date, and identification information.

Legal Basis: Necessary to perform our contract with you to provide the Service.

We use this information to:

· verify your identity; and

· comply with our legal obligations.

Payment Data. Your payment card number, expiry, CVC, and cardholder name.

Legal Basis: Necessary to perform our contract with you to provide the Service.

We use this information:

· to facilitate your transactions;

· for security and verification purposes.

Transaction Data. Date, time, transaction amount, open ID, and transaction ID.

We use this information to maintain a record of your transaction history and preserve our legal rights.

Customer support and feedback information. Information you provide to us when you communicate with our customer service or otherwise provide information to us through the Service.

Legal Basis: Necessary to perform our contract with you to provide and support the Service.

We use this information to:

· improve our services;

· communicate with you (if you provide your contact information);

· administer and provide services and customer support per your request;

· provide troubleshooting, such as addressing and remediating technical issues and bugs.

Promotion information. Personal information you provide to us when you choose to participate in a promotion, and the number of times a link to a type of promotion is clicked on.

Legal Basis: We use this information pursuant to our contract with you to provide you with the promotion (including any associated rewards).

We use this information to:

· communicate with you (if you provide your contact information);

· better understand how you access and use the Service;

· develop new and improve existing services;

· improve the Service and respond to customer requests and preferences;

· carry out any purpose enumerated in the promotion itself which will be notified to you prior to you participating in the promotion.

Information generated as part of the Service

Technical Information. Your IP address, device information (comprising identifier, name, and type of operating system, mobile network information), and browser type.

Legal Basis: It is in our legitimate interest to ensure the security of our Service and improve our Service.

We use this information:

· to personalise the Service to ensure content is presented in the most effective manner for you and your device;

· to improve our services, including the functionality of the Service;

· for security and verification purposes;

· to identify and address bugs and assess service functionality for optimisation.

Log Data. Log data and statistics relating to your use of the Service.

Legal Basis: It is in our legitimate interest to ensure the security of our Service and improve our Service.

We use this information to:

· maintain a record of your log-in and actions in relation to your use of the Service;

· improve the Service, including the functionality of the Service;

· monitor and analyse trends, usage and activity in connection with the Service to improve the Service;

· for security and verification purposes.

Pseudonymised and Aggregated Data. We pseudonymise and aggregate certain personal information to improve the Service.

Legal Basis: It is in our legitimate interest to ensure the security of our services, manage registrations and improve the Service.

We use this information to:

· understand how to improve the Service for our users;

· conduct data analysis, testing, research, statistical and survey analysis.

In order to administer the Service, we are required to comply with certain legal obligations. This means that we use the personal information you provide in order to protect you from fraud, and we monitor certain transactions as required by law.

3. How do we share your personal information?

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties such as (a) merchants you transact with, and (b) service providers that provide services in support of the Service, including payment processing and remittance partners located in the PRC and other countries, in order to provide remittance services, acquiring institutions, banks and payment services providers located in the countries tied to your Weixin Pay account, to facilitate payments made via the Service, and providers of cloud services that process information on their servers to store the personal information you provide and for disaster recovery services. All such third parties are prohibited from retaining, using, or disclosing your personal information for any purpose other than in connection with their transaction with you, or for providing us with their services, as the case may be, and subject to applicable laws and regulations.

· Companies within the Tencent corporate group who process your personal information in order to operate the Service, including to facilitate fund transfers. All related group companies may only use your personal information in accordance with this Privacy Policy.

• Regulators, judicial authorities, law enforcement agencies, state banks and financial authorities, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
• enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your personal information to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

4. Where do we store your personal information?

The personal information that we collect from you will be transferred to, stored at, and processed in the PRC under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC. Your personal information is also processed by staff operating outside the Relevant Jurisdictions who work for us or our affiliates. Such staff are engaged in, among other things, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

5. The security of your personal information

We are committed to maintaining the privacy and integrity of your personal information. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Service or over email; any transmission is at your own risk.

Once we have received your personal information, we will take appropriate technical and organisational measures to safeguard your personal information against loss, theft and unauthorised use, access or modification.

6. How long do we store your personal information?

We do not keep your personal information for longer than is necessary to fulfil the purpose for which it is or is to be used, unless we are required to do so under applicable laws and regulations. We are legally obliged to retain your customer information and transaction history for six years following the date of deletion of your Weixin Pay account.

After you have deleted your Weixin Pay account, except where we are legally obliged to retain information, we will store your information in an aggregated and anonymised format.

7. Your rights

Users in the the Relevant Jurisdictions that are subject to this Privacy Policy have rights in relation to the personal information. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please email wechatpayprivacy@tencent.com.

You have the following rights in relation to your personal information:

· Access: to enquire and access personal information held by us and details about how we use it and who we share it with;

· Portability: where we process personal information provided by you and processed by us based on contract or consent, you have the right to receive or ask us to provide your personal information (subject to any applicable laws and regulations) to a third party in a structured, commonly used and machine-readable format;

· Correction: to correct any personal informatioin held about you that is inaccurate and have incomplete data completed (including by the provision of a supplementary statement). Where you request correction, please explain in detail why you believe the personal information we hold about you is inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the relevant data as described below;

· Erasure: that we erase your personal information in certain circumstances;

· Restriction of processing to storage only: to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances;

· Objection: in certain circumstances, the right to restrict or object to our processing of your personal information (e.g. where you request correction or erasure, you also have a right to restrict processing of the relevant data while your request is considered;

· Withdrawing consent: you can withdraw your consent at any time by emailing us at wechatpayprivacy@tencent.com; and

· Complaints: in the event that you wish to make a complaint about how we process your personal information, please email wechatpayprivacy@tencent.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your local data protection authority.

8. Changes

Any changes we will make to this Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this Privacy Policy.

9. Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to wechatpayprivacy@tencent.com.