Privacy Policy

Wintranx (hereinafter referred to as “we”) attaches great importance to the privacy and protection of personal information of users (“you”). Wintranx has developed this Privacy Policy to explain how we collect, use, store and share this information when you use our products and/or services, and how we provide you with the means to manage and protect this information. This Privacy Policy has the same legal effect as your agreement with Wintranx. Wintranx is not responsible for the privacy practices of other linked sites. This policy will help you understand the following:

1. Information collection

(1) What is the purpose of processing personal information?

We may legally process your personal information in the following circumstances, for example:

1. Create customer profiles, maintain customer records, and communicate with you (including providing you with updates on changes to products and services), meet your requests, and respond to your inquiries or feedback, and handle or investigate any complaints, claims, or disputes ;

2. Send you important notices or personalized information related to your use of our products and services;

3. Use your necessary personal information to manage the operation of the website, allow you to use the services and functions of our website, process and manage your transactions, conduct website maintenance, troubleshoot problems, and continuously improve your website experience, and adjust our website according to the terms and conditions of your relationship to provide you with services and products;

4. Identify and send you marketing materials, news and information that we think will be of interest to you, such as our latest promotional offers and upcoming products and services;

5. To provide our products or services, conduct screening, due diligence, check and verify your identity in accordance with applicable laws, regulations or directives;

6. To detect, investigate and prevent fraud and other illegal activities;

7. Use your personal information for purposes related to our legal or regulatory rights and obligations, including financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit risk), auditing and record-keeping purposes, and seeking professional the purpose of consultation (including legal advice); and

8. Keeping internal records, making decisions and improving internal purposes, such as conducting data analysis and research to improve our products and services, service safety and quality.

(2) What information we may collect

1. When you apply for Wintranx services, we need to verify your identity according to applicable laws, regulations and regulatory requirements as well as our compliance and risk control requirements. When conducting enterprise certification, you need to provide us with basic enterprise information, certificates and licenses. , as well as the identity information of the relevant natural persons of the enterprise (including legal persons, directors, actual controllers, ultimate beneficiaries and authorized persons), and photocopies or photos of relevant certificates. If you do not provide the aforementioned information, you will not be able to use Wintranx’s services.

2. When you use Wintranx’s collection service, you should provide us with your transaction information.

3. When you use Wintranx’s withdrawal/payment service, you should provide us with transaction information and corresponding withdrawal/payment information, including payee information (name, bank account number, bank name, bank unique identification code or other auxiliary information) ); order information (basic order information, commodity information, logistics information); contract information (contract/invoice and other equivalent materials).

4. In order to ensure the security and stability of the services provided to you, prevent transaction and capital risks, and in accordance with applicable laws, regulations and regulatory requirements as well as our own compliance and risk control requirements, we need to record your computer, mobile phone or Information sent to us by other access devices, or applications, including but not limited to network IP addresses, device information (including device brand, model, name, address, identification code, identifier, and other device environment and application information), Your browser version information and geographic location information.

5. Information that you provide us when you contact our support team to help us answer your questions. We also collect information about any suggestions or complaints you make to help resolve your concerns and to improve the products and services we offer you;

6. Your email and marketing preferences, including interest and market listing assignments, marketing objections, preferred language, website and application data; and, with your separate authorization and consent, through your contact mobile number and/or Contact the email address to send you SMS or email notifications of the corresponding marketing activities. If you do not agree to our collection and use of the aforementioned information, please send an email to our email address (cs@Wintranx.com) to request that we no longer send marketing activity notifications. If you do not agree to the collection and use of the aforementioned information, it will not affect our continued service You provide Wintranx services.

7. We strictly abide by the requirements of relevant laws and regulations, and will not collect or store sensitive information such as track information or chip information, verification code, validity period, and password of your bank card.

(3) Exceptions to your authorization and consent

According to the laws, regulations and regulatory requirements in jurisdictions and other relevant countries, regions and fields, the collection of your personal information does not require your authorization and consent in the following situations:

1. Related to the national security and national defense security of relevant countries, regions and fields;

2. Related to the performance of statutory duties or statutory obligations under applicable laws and regulations and relevant regulations of regulatory authorities;

2. Those related to public safety, public health, and major public interests;

3. Related to criminal investigation, prosecution, trial and execution of judgments;

4. In order to protect the life, health, property safety and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the consent of the individual;

5. The collected personal information is disclosed to the public by you;

6. Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

7. Necessary to sign and perform the contract according to your request;

8. Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and dealing with faults in products or services, identifying and dealing with fraud or misappropriation in products or services;

9. Necessary for public interest and legitimate news reporting;

10. Other situations stipulated by applicable laws and regulations.

2. How we store or protect information

1. We have taken reasonable and feasible security protection measures in line with industry standards to protect the security of your personal information and prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information. For example, when data (such as bank card information) is exchanged between your browser and the server, it is encrypted and protected by the SSL (Secure Socket Layer) protocol; we will use encryption technology to improve the security of personal information; we will use trusted protection mechanisms to prevent personal information from being maliciously attacked; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information; and we will hold security and privacy protection training courses to enhance employees’ awareness of the importance of protecting personal information.

2. We have an industry-leading data security management system with data as the core and around the data life cycle, which improves the security of the entire system from multiple dimensions such as organizational construction, system design, personnel management, and product technology. We are certified by the PCI DSS International Data Security Standard.

3. We have formulated contingency plans for personal information security incidents, and regularly organize relevant internal personnel to conduct emergency response training and emergency drills, so that they can master job responsibilities and emergency response strategies and procedures. In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and the measures you can take to prevent and reduce risks on your own. Recommendations, remedies for you, etc. We will promptly notify you of the relevant information of the event by email/short message, etc. When it is difficult to inform the personal information subjects one by one, we will take a reasonable and effective way to publish an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

3. Information retention period

We only retain your personal information for a period of time that is necessary and reasonable for the purpose of providing our services to you or within the time limit prescribed by laws, regulations and supervision.

After you terminate the use of our services, we will immediately stop the collection and use of your information, unless otherwise stipulated by laws, regulations or regulatory authorities.

4. How we use information

In order to comply with national laws and regulations and regulatory requirements, as well as to provide you with services and improve service quality, or to protect the security of your accounts and funds, we will use your information in the following situations:

1. To achieve the purposes described in the “Information Collection” section of this Privacy Policy;

2. In order to ensure the stability and security of the service, protect the security of your account and funds, and fulfill legal obligations such as anti-money laundering and other compliance obligations, we will use your information for identity verification, security prevention, fraud/theft/theft Suspicious transaction detection, prevention and prohibition of illegal activity, segregation or risk reduction, documentation and preservation;

3. Report to relevant departments in accordance with applicable laws and regulations or regulatory requirements;

4. Invite you to participate in our service-related customer and product research;

5. We will desensitize and de-identify your information for comprehensive statistics, analysis and processing in order to provide you with more accurate, personalized, smooth and convenient services, or to help us evaluate, improve or design services and operational activities ;

5. How we provide your information externally

(1) Sharing

1. We will keep your information strictly confidential in accordance with the provisions of this Privacy Policy. Except as otherwise provided by applicable laws, regulations and regulatory authorities, we only share your information with third parties in the following circumstances:

(1) For the purpose of enabling you to complete the transaction, provide your counterparty with transaction identification information and relevant payment information, and your counterparty can view some of your information during the payment process or after successful payment;

(2) With your explicit consent or authorization in advance, we will share your information with relevant Wintranx third parties within the scope of your authorization to the extent permitted by applicable laws and regulations;

(3) Provided in accordance with applicable laws and regulations, the requirements of legal procedures, mandatory administrative or judicial requirements;

(4) To the extent permitted by laws and regulations, it is necessary to protect Wintranx or Wintranx affiliates or Wintranx cooperative third parties, you or other Wintranx users or the public interest, property or safety from damage;

(5) Some products or services may be provided by Wintranx cooperative third parties or jointly provided by us and Wintranx cooperative third parties. Therefore, only by sharing your information can we realize the core functions of our products and/or services or provide the services you need. products or services;

(6) If you choose to participate in the marketing and promotion activities jointly carried out by us and the relevant Wintranx cooperative third party, we may share the necessary information generated during the activity to complete the activity, so that the Wintranx cooperative third party can promptly notify you. To provide services, rights or benefits, we will provide specific further notices on the relevant activity rules page or through other channels in accordance with the requirements of laws and regulations;

(7) In accordance with the relevant agreements signed with you or the requirements of other legal documents;

(8) Use based on social and public interests that comply with applicable laws and regulations.

2. According to the foregoing provisions of this article, we may provide your personal information to the following objects:

(1) companies within our group;

(2) Service providers and partners we cooperate with, such as payment companies, acquirers, bank partners, payment system operators that process your transactions, in order to provide you with our products and services;

(3) Service providers and partners we work with to conduct identity due diligence and verification, transaction monitoring, fraud scanning, and to detect, prevent or otherwise resolve fraud, security or technical issues, protect our customers or the public’s No damage to rights, property or safety, or as necessary to serve our legitimate business interests;

(4) our advertising and analytics providers and related service providers to improve our commercial services;

(5) any subsidiary, joint venture or other affiliated company;

(6) other third parties authorized by you;

3. For companies, organizations and individuals with whom we share personal information, we will evaluate the legality, legitimacy and necessity of the information collected by such third parties, and sign agreements with them to require third parties to strictly abide by relevant laws and regulations and Regulatory requirements and take steps to protect your personal information.

(2) Entrusted processing

We may entrust authorized partners to process your personal information in order to provide you with corresponding products or services. However, we will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share personal information necessary to provide products or services. If our partners use your personal information for purposes not entrusted by us, they will obtain your consent separately.

(3) Transfer

We will not transfer your personal information to any companies, organizations and individuals, except in the following cases:

1. Obtain your express written consent or authorization in advance;

2. Provided in accordance with applicable laws and regulations, requirements of legal procedures, mandatory administrative or judicial requirements;

3. Provided as required by the relevant agreement signed with you or other legal documents;

4. When it comes to mergers, acquisitions, asset transfers or similar transactions, if it involves the transfer of personal information, we will require new companies and organizations that hold your personal information to continue to be bound by this Privacy Policy, otherwise, we will require The company or organization seeks your authorization and consent again.

(IV) Public disclosure

We will only publicly disclose your personal information under the following circumstances and on the premise of taking industry-standard security protection measures:

1. According to your needs, disclose the personal information you designate in the disclosure method that you expressly agree to;

2. When it is necessary to provide your personal information according to the requirements of applicable laws and regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your personal information according to the required type and disclosure method of personal information. Under the premise of compliance with applicable laws and regulations, when we receive the above request for information disclosure, we will require such authorities and departments to issue corresponding legal documents, such as subpoenas or investigation letters. We strongly believe in being as transparent as possible about the information we are asked to provide, to the extent permitted by law. We carefully review public disclosure requests to ensure they have a legitimate basis and are limited to data law enforcement has a legitimate right to obtain for specific investigative purposes. To the extent permitted by applicable laws and regulations, the files we disclose are protected by encryption keys.

(5) According to the relevant laws and regulations, we may share, transfer and publicly disclose your personal information without your consent in the following circumstances:

1. Related to fulfilling the obligations stipulated by laws and regulations and regulatory authorities;

2. Those directly related to national security and national defense security;

3. Those directly related to public safety, public health and major public interests;

4. Those directly related to criminal investigation, prosecution, trial and execution of judgments;

5. In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain your consent;

6. Your personal information disclosed to the public by yourself;

7. Personal information collected from legally publicly disclosed information.

6. Your rights

You have certain rights with respect to your personal data. You have the right to request access and correction of your data. If you would like to exercise these rights, please contact us.

You can also withdraw consent. Withdrawing your consent may affect our ability to provide services to you. If you would like to exercise any of your rights, please contact us. If you wish to request access to all personal data we hold about you, you may need to prove your identity.

If you have an account with any of our services, you will generally be able to review and edit the profile in your account by accessing your account and updating your information directly. You may also contact us if you do not have an account or if you have questions about account information or other personal data.

7. Protection of Children's Personal Information

Our products, websites and services are intended for adults. We strictly abide by the relevant laws and regulations of relevant countries, and only collect and process the personal information of children (in this Privacy Policy, “children” refers to minors under the age of 14) on the basis of the authorization and consent of parents or other guardians. If we discover that we have collected personal information from a child without first obtaining verifiable parental or other guardian consent, we will endeavour to delete the data as soon as possible. In the case of children’s personal information collected with the consent of a parent or guardian, we will only use or publicly disclose this information as permitted by law, expressly consented by a parent or other guardian, or necessary to protect the child.

8. Transfer your personal information to other countries

In view of the fact that we provide Wintranx services to you worldwide, to the extent permitted by relevant laws and regulations, on the basis of your authorization and consent, your personal information may need to be transmitted to Wintranx affiliates and Wintranx cooperative third parties. On the premise of meeting the relevant regulations and requirements of laws and regulations, we will use our best commercially reasonable efforts to take measures to ensure that your information transfer and disclosure comply with the requirements of local laws and regulations. At the same time, we will also take all reasonable and necessary steps ( Including but not limited to encrypted transmission, restricting the scope of access, signing a data processing agreement with the data recipient or a cooperation agreement containing data processing terms to clarify the data protection responsibilities and obligations of both parties, etc.), to ensure that your personal information is handled securely and in compliance with this Privacy Policy Protection Agreement.

By using our website and services, you agree to the transfer of your personal data to other countries, including countries with different data protection rules than yours. We make no representation that our website and services are appropriate or available in any particular jurisdiction.

9. Policy Update

Our privacy policy will be changed according to product updates and legal and regulatory requirements. When there are major changes to this policy, we will notify you in a timely manner by means of pop-up reminders, message pushes, email notifications or announcements on our official website. The circumstances that constitute major changes include but are not limited to:

1. Significant changes in the scope and mode of services we provide;

2. Significant changes have taken place in our business entities, organizational structure, ownership structure, etc.;

3. The main objects to which personal information is provided, transferred or publicly disclosed changes;

4. Significant changes in your rights to participate in the processing of personal information and the way they are exercised;

5. Our responsible department responsible for personal information security, its contact information, and complaint channels have changed;

6. Other changes that may have a significant impact on your personal information rights.

You can view this policy by clicking “Privacy Policy” on our official website. If you have any questions, comments or suggestions regarding this Privacy Policy or matters related to your personal information, please contact us by email marketing@wintranx.com.

10. Your consent

Your use of Wintranx means that you accept this Privacy Policy. You agree that the personal information you provide and that we collect from time to time may be used and disclosed to the appropriate persons for the above purposes in accordance with this Privacy Policy.

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