Published: December 18, 2010
Updated: March 23, 2022
Effective: March 23, 2022
UPWAY Bullion Limited（hereinafter referred to as "UPWAY".）,A limited company incorporated under the laws of the Hong Kong Special Administrative Region, its successors or assigns, and the contracting party to this document (hereinafter referred to as the "Client").
UPWAY's personal data privacy policy is to protect the rights of customers in accordance with the Personal Data (Privacy) Ordinance. UPWAY pays close attention to the arrangements for the use of customer information in order to provide the best possible service to its customers and endeavors to fully comply with the personal data protection requirements under the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region. To this end, UPWAY will ensure that its employees comply with the strict standards of security and confidentiality required by law.
i） Personal data collected by UPWAY，It is used solely for the purpose of conducting business operations and other related activities of UPWAY;
ii） UPWAY is committed to ensuring that its website is secure and complies with industry standards and uses other data protection tools such as:Firewalls, authentication systems (passwords, personal identification numbers, etc.) and manipulation mechanisms to control unauthorized access to systems and data；
iii） UPWAYUPWAY will store customer's personal information in a confidential manner to protect it from being stolen, and UPWAY's employees will respect 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 and other governmental authorities in accordance with any law or regulation.；
vi） The Client agrees that UPWAY may disclose the Client's personal information to the relevant organizations as proof of identity verification when the Client accesses and withdraws funds through the payment gateway in accordance with the arrangements set out in the Network Payment System Policy.；
vii） UPWAY may set and access UPWAY Cookies on the Customer's computer.This is to help UPWAY analyze and understand the effectiveness of its marketing strategies.UPWAY and its employees may use cookies on UPWAY's products and services to track customers' browsing on UPWAY's website. The information collected and shared is anonymous and cannot be individually identified.；
viii） The Customer agrees that when UPWAY provides services to Customer Service.UPWAY may authorize the use of customer 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 monthly statements, and companies that maintain and develop software for data processing. These companies authorized by UPWAY are required to keep customers' personal information confidential.
1、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 in which you must authorize us to collect and use your personal information
i）Help you become our user
To become our user so that we can provide you with membership services, for example:Cell phone numbers are sensitive information and are collected in order to meet the real-name requirements of relevant laws and regulations. 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.。
In the process of user registration, you need to provide your name, identification number, cell phone number, bank card number, address and other information. However, if you do not provide this information, will affect your online account opening process, but will not affect the use of UPWAY platform services such as basic browsing 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）Information collected in the course of the service
In order to understand the adaptability of the product and identify abnormal status of the account, we will collect and correlate information about the services you use and the way you use them, which includes: (1) Log information: When you use the UPWAY platform services provided by our website or client, we will automatically collect details of your use of our services and keep them as a relevant web log. For example, the content of your search query, IP address, browser type, telecommunication operator, date and time of access, and records of the web pages you visit.
（2）Description of the use of user equipment rights
In order to ensure the normal operation of the APP service is normal, we need to get the phone device permissions including storage, device information, phone, camera, photo albums, microphone, etc. Before obtaining these cell phone permissions, the APP will explicitly inform the user of the use of the permissions and the scope of use of the permissions, the use of these permissions are described below:
Storage Privileges：It is used to store the files required for the proper functioning of UPWAY.Including APP running temporary files, log information; media files saved when users voice or share.As you are posting, avatar change, feedback and other scenarios, you may need to select the image files in your cell phone album.If you do not turn on the appropriate permissions, this will affect the user's ability to make image choices in scenarios such as posting, avatar replacement, and feedback, but does not affect the use of our other services.
Mobile device information rights：The user ensures the smooth realization of various message notification functions during operation, which can provide you with notifications of key issues (such as events, important industry announcements, system upgrades, etc.), notifications of service information, notifications of interactive messages, and reminders of transaction information. If you do not enable the corresponding rights, this will affect the provision of notification of key issues (such as activities, important industry announcements, system upgrades, etc.), notification of service information, notification of interactive messages, transaction information alerts and other functions, but does not affect your use of our other services.
Cell phone privileges：It is used to ensure that the operation is not interrupted by dialing/receiving calls that prevent the resumption of the appropriate services.
Camera/camera permissions are used for assurance:When you use functions such as avatar image settings, screenshot feedback, etc., theYou will need to enable camera permissions and/or album permissions (whichever feature you are using) in order for you to take live shots or picture/video uploads.If you do not enable the corresponding permissions, you will not be able to use the specific functions related to real-time shooting or picture/video uploading, but it will not affect your use of other services provided by the APP.
microphone authority：A feature used to ensure that the microphone is available to the user for private messaging so that the user can send voice messages. If you do not turn on the appropriate permissions, you will not be able to use the smart voice function, but it does not affect your use of our other services.
make a telephone call：Allow permissions are used to ensure that you can make direct calls to customer service or receive callbacks from staff to improve customer service efficiency. If you do not turn on the appropriate permissions, which will affect to you in a timely manner through the phone to answer the use, account opening, authentication and trading during the questions and problems, but does not affect your use of our other services.
MAC address authority：For remembering your identity, analyzing your use of our services and optimizing advertising.
positional authority：You can turn on the location permission to view or access services in your current area. If you do not enable this permission, you will not receive notifications based on your current location, but it will not affect your ability to use other services.
Read the clipboard:for data transmission.You can copy and move the contents of a document to the "clipboard" within the application, providing you with the ability to copy and paste the contents of the document. And when you use the clipboard, we will get your incoming data to optimize the advertisement.。
Please note that device information, log information, etc. alone cannot identify a specific natural person. If we use such non-personal information in combination with other information for the purpose of identifying a specific natural person or in combination 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. When you contact us, we may keep your correspondence/call records and contents or the contact information you leave, etc., in order to contact you or help you to solve the problem, or to record the handling of the relevant issues and the results.
i) Data Security Technical Measures
We will adopt industry standard security measures, including the establishment of a reasonable system of norms, security technology toprevent your information from unauthorized access to use, modify, avoid data damage or loss.The Web Services employ a variety of encryption techniques, for example, in some services we will utilize encryption (e.g., SSL) to protect your informationWe use encryption technology to store your information in an encrypted format,and isolate it through segregation technology. When the information is used,exampleInformation Display、Information linkage calculationsWe use a variety of data desensitization techniques to enhance the security of information in use. Strict data access rights control and multiple authentication techniques are used to protect the information and avoid unauthorized use of the data.
ii) Other security measures we take to protect information
We manage and regulate the storage and use of information through the establishment of a data classification and grading system, data security management standards, and data security development standards. We have comprehensive data security controls through confidentiality agreements for information contacts, monitoring and auditing mechanisms.
iii) UPWAY will make every effort to ensure that the Customer's personal information collected by UPWAY is properly stored in a storage system and is accessible only by authorized employees or companies providing services on behalf of UPWAY, but given the open and global nature of the Internet, UPWAY may not be able to protect and keep confidential the Customer's personal information from intentional interference by third parties. 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.
We will not provide, sell, rent, share or trade your personal information with any unaffiliated third party unless we have your prior permission or such third party and the Application (including the Application's Affiliates), individually or collectively, provide you with a service, and after such service is terminated, such third party is prohibited from accessing such information, including all such information to which it previously had access. We may use the information we collect inthe course of providing the Services to you for the following purposes:
i) Provide services to you. For example,collecting information that identifies you in order to help you complete your registration .。
ii) for authentication, customer service, security precautions, archival and back-up purposes in connection with the provision of our services and to ensure the security of the products and services we provide to you.
iii) Help us improve our existing services.
iv) Notify you of news
When you take the initiative to delete, cancel the account, you can click on My - More - More Business - Investor Account Cancellation to cancel the account, there will be a freeze period of 15 days after the initiation of the cancellation, such as logging in to the account again during the freeze period the account will be withdrawn from this application.
UPWAY reserves the right to revoke your consent to the Privacy Policy until the date of revocation, at which time UPWAY guarantees that it will not do so.Note: Withdrawal of consent to the Privacy Policy will result in the inability to use UPWAY products and services.
For the purpose of ad monitoring services, our products may integrate third-party SDKs or other similar applications. Baidu Statistics SDK:Required fields such as your device's International Mobile Equipment Identifier (IMEI), iOS Advertising Identifier (IDFA), phone number, etc. need to be collected。
Beijing Baidu Netcom Technology Co., Ltd. is our network promotion service provider, in order to better improve and optimize the conversion effect of advertisement placement on the customer's side.Need to collect information about your device attributes (your hardware model, operating system version, device configuration, unique device identifier cuid, International Mobile Equipment Identity IMEI, network device hardware address MAC, advertising identifier IDFA, network connection type)。
Privacy Policy Link：《Baidu Statistics Privacy Policy》
AUO notification SDK:need to collect your device information, message notification AUO Tongxin (Beijing) Technology Co., Ltd. for the company's network promotion service providers, in order to better provide the notification of key matters (such as activities, industry important announcements, system upgrades, etc.).Need to collect your device identifier (IMEI/Mac/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information)。
Privacy Policy Link：《AU Privacy Policy》
Tencent Bugly: For better Crash monitoring, crash analysis and other quality tracking services, theNeed to collect your Crash information and thread stack, ROM/RAM/SD card capacity, network/language and other status App information: package name, version, belongs to the process name, device information: IMEI and other device identification。
Privacy Policy Link：《Tencent Bugly User Agreement》
For the security of your information, we have agreed to strict data security and confidentiality obligations with third-party SDK service providers, and these companies will strictly adhere to our data privacy and security requirements.We will not share your other personal information with you unless we have your consent to do so.。
We may revise this Privacy Policy from time to time. When the terms of the Privacy Guidelines are changed.We will notify you of changes to our Privacy Guidelines by means of a notification alert when we update the version of our website, and will inform you of the effective date.Please read the revised Privacy Policy carefully, and your continued use of it indicates your consent to our handling of your personal information in accordance with the updated Privacy Policy.
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）Contact address：21/F, Nina Tower 2, 8 Yeung Uk Road, Tsuen Wan, N.T., Hong Kong
iii）Information Security Contact Phone Number：(+852) 23850868