一. Overview of privacy and personal information protection

i) The personal data collected by UPWAY will only be used by UPWAY for the purpose of conducting its business operations and other related activities;

ii) UPWAY is committed to ensuring that the Website is secure and complies with industry standards and uses other data protection tools such as firewalls, authentication systems (passwords and personal identification numbers, etc.) and manipulation mechanisms to control unauthorized access to the system and to the Data;

iii) UPWAY will store customer's personal information in a confidential manner to protect the customer's personal information from being misappropriated, and UPWAY's employees will respect the customer's privacy and will never disclose any information to unauthorized persons;

iv) The Customer may from time to time access and correct his/her personal data held by UPWAY;

v） The Client agrees that UPWAY will disclose all information (and other information) about the Client to regulatory authorities and other governmental bodies in accordance with any law or regulatory requirement;

vi） The Customer agrees that UPWAY may disclose the Customer's personal data to the relevant organizations as proof of identity verification when the Customer makes deposits and withdrawals through the payment gateway in accordance with the arrangements set out in the Internet Payment System Policy;

vii) UPWAY may set and access UPWAY Cookies on customers' computers to assist UPWAY in analyzing and understanding the effectiveness of relevant marketing strategies. UPWAY and its employees may use cookies on UPWAY's products and services to track customers' browsing of UPWAY's websites, and the information collected and shared is anonymous and not individually identifiable. The information collected and shared is anonymous and not individually identifiable;

viii) When the Customer consents to UPWAY providing services to the Customer, UPWAY may authorize the use of the Customer's Personal Data by companies that are not affiliated with UPWAY, including companies that provide services on behalf of UPWAY on a contractual basis, such as companies that create and mail statements, maintain and develop software for data processing, etc. These companies authorized by UPWAY are required to maintain the confidentiality of the customer's personal data.

二. How we collect and use your information

We may collect and use your personal information for the following purposes as described in this Privacy Policy.
(一)Circumstances under which you must authorize us to collect and use your personal information

i）Help you become our user
In order to become our users, so that we can provide you with member services, for example: cell phone number is sensitive information, the collection of such information is to meet the relevant laws and regulations of the network real name system requirements. If you do not provide such information, you may not be able to use our services normally. If you only need to use basic services such as browsing, you do not need to register as our user and provide the above information.
During the registration process, if you provide the following additional information to complete your personal data, it will help us to provide you with more personalized services such as birthday privileges: your real name, gender, date of birth, place of residence, your real avatar, nickname. However, if you do not provide this information, it will affect your use of personalized services, but will not affect the use of the UPWAY platform services such as basic browsing and other functions.
When you voluntarily cancel your account, we will anonymize or delete your personal information as soon as possible in accordance with the requirements of applicable laws and regulations.

ii）Showing and pushing information for you
In order to provide you with personalized information search and transaction services, we will extract your browsing and search history, device information, location information, your browsing and search preferences, behavioral habits, interests (which you can select in your account settings), location information and other characteristics, and indirectly carry out crowd profiling based on the characteristics of the labels, which is used to display the information about the services you are interested in to you.

iii）Information collected in the course of the service
In order to provide you with more customized page displays and search results, to understand product suitability, and to identify account anomalies, we may collect and correlate information about the services you use and how you use them, including.
Device Information:We receive and record information about your device (such as device model, operating system version, device settings, unique device identifier and other hardware and software characteristics), its location (such as IP address, GPS location, and sensor information such as Wi-Fi access points, Bluetooth, and base stations that can provide such information), and the location of the device, based on the specific permissions that you have granted during the installation and use of the software. ).
Log messages:When you use the UPWAY platform services provided by our website or client, we will automatically collect details of your usage of our services and keep them as relevant web logs. For example, the content of your search query, IP address, browser type, telecommunication operator, date and time of access, and the web pages you visit.

Please note that device information, log information, etc. alone cannot identify a specific natural person. If we combine such non-personal information with other information for the purpose of identifying a specific natural person or use it in conjunction with personal information, such non-personal information will be treated as personal information for the duration of such combined use and will be anonymized and de-identified unless we have obtained your authorization or are otherwise required by law or regulation to do so.
When you contact us, we may keep records of your correspondence/calls and their contents or information such as the contact details you have left, in order to contact you or help you to solve your problems, or to record the solutions and results of related problems.

UPWAY will make every effort to ensure that the personal information collected by UPWAY is kept in a secure storage system and is accessible only by authorized employees or companies providing services on behalf of UPWAY, but given the public and global nature of the Internet, UPWAY may not be able to protect and keep confidential the personal information of its customers from intentional interference by third parties. When UPWAY's web site is accessed through a web site operated by another party, the customer's personal information is not covered by UPWAY's personal information privacy policy.

三、How to contact us

i）If you have any questions, comments or suggestions regarding this Privacy Policy or matters relating to your personal information, please contact us by visiting our online customer service system or calling any of our customer service numbers.

ii）Address: 21/F, Nina Tower 2, 8 Yeung Uk Road, Tsuen Wan, N.T., Hong Kong.

iii）Information Security Contact Phone Number：(+852) 2385 0868