UPWAY China Bullion Limited（hereinafter"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 and interests 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. 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 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 employees will respect customers’ privacy and will never disclose any information to unauthorized persons.；

iv） The Client may from time to time access and make changes to the information held by Glorious Gold China in relation to the Client.personal profile；

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 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.，To assist UPWAY in analyzing and understanding 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 websites. The information collected and shared is anonymous and cannot be individually identified.；

viii） UPWAY China Bullion Limited（hereinafter"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").

II. This Privacy Policy will help you understand the following

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. But 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 product suitability and identify the abnormal status of the account.We may collect and correlate information about the services you use and how you use them, which may include:
（1）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 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 normal,We need to gain access to the phone’s device permissions including storage, device information, phone, camera, photo albums, microphone,Before obtaining these cell phone permissions APP will clearly inform the user of the purpose and scope of use of the permissions, the use of these permissions are described below:

Storage Privileges：It is used to save the files required for the normal operation of "Jinrong China".Including APP running temporary files, log information; media files saved when users voice or share.You may need to select the image files in your cell phone’s photo album.in the scenarios of posting, avatar changing, opinion feedback, etc. If you do not enable this permission, it will affect the selection of images for posting, avatar change, feedback and other scenarios, but will 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：Used to ensure that there is no interference with making/receiving calls during operation that would prevent the resumption of appropriate services.

Camera/camera permissions are used to ensure：When you use functions such as avatar image settings, screenshot feedback, and so on,You 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 does not affect your use of other services provided by the APP.

microphone authority：It is used to ensure that users can use the microphone function in private messages, so that users can send voice messages. If you don’t enable the corresponding permission, you will not be able to use the intelligent 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 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 unless we have obtained your authorization or are otherwise required by law or regulation to anonymize or de-identify such personal information. When you contact us, we may keep your correspondence/call records and content 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.

III. How we protect personal information

i）Technical measures for data security
We will use industry standard security measures, including the establishment of a reasonable system of norms, security technology to prevent unauthorized access to your information, use, modify, avoid data damage or loss.The Web Services employ a variety of encryption technologies, for example, in some Services we will utilize encryption (e.g., SSL) to protect your information,Adopt encryption technology to encrypt and save your information, and isolate it by isolation technology.At the time of information use,for exampleInformation display, information correlation calculation,We will 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 information from unauthorized use of 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 provide comprehensive security control of data through information accessor confidentiality agreements, monitoring and auditing mechanisms.

iii）UPWAY will do everything in its power to ensure that itsPersonal data collected from customersThe information is kept in a secure storage system and is accessible only by authorized employees or companies providing services on behalf of UPWAY. However, due to the open and global nature of the Internet, UPWAY may not be able to protect and maintain the confidentiality of customer’s personal information from intentional interference by a third party. If you visit a web site operated by someone else through UPWAY’s web site, your personal information is not covered by UPWAY’s personal information privacy policy.

IV. How we use personal information

We will not give, sell, rent, share or trade your personal information to any unrelated third party, unless we have your prior permission or such third party and the Application (including the Application’s affiliates), either individually or jointly, provide a service to you.and after such service has ended, it will be denied access to all such information, including all such information to which it previously had access.We may use the information we collect in the course of providing the Services to you for the following purposes:

i）Providing services to you.For example, collecting information that identifies you in order to help you complete your registration.

ii）For authentication, customer service, security, 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

V. How to delete and cancel personal accounts

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.

VI. How to withdraw consent to a privacy agreement

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 your consent to the Privacy Policy may result in your inability to use UPWAY’s products and services.

vii. terms of authorization

For the purpose of ad monitoring services, our products may integrate third-party SDKs or other similar applications.Baidu stats SDK：Required fields such as your device’s International Mobile Equipment Identifier (IMEI), iOS Advertising Identifier (IDFA), phone number, etc. need to be collected.

Ltd. is our network promotion service provider, in order to better improve and optimize the conversion effect of advertising in the customer side.，Need to collect information about your device properties(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》

Notification of AU SDK：Need to collect information about your device，To carry out the message notification AUO Tongxin (Beijing) Technology Co., Ltd. for the company’s network promotion service providers, in order to better provide the focus of the matter notification（Such as events, important industry announcements, system upgrades, etc.），Need to collect your device identifier(IMEI/Mac/android ID/IDFA/OPENUDID/GUID、SIM Cards IMSI information)。
Privacy Policy Link：《Umeng Privacy Policy》

Tencent Bugly: For Better Crash monitoring, crash analysis and other quality tracking services.Need 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.These companies will strictly comply with our data privacy and security requirements.We will not share your other personal information with them unless we have your consent.

VIII. Revision of this policy

We may revise this privacy policy from time to time.When the terms of the Privacy Guidelines change.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. Your continued use of it indicates your consent to our handling of your personal information in accordance with the updated Privacy Policy.

IX. 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 by 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) 23850868