Welcome to WeChat Pay Hong Kong!

This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with WeChat Pay Hong Kong, the fund transfer service administered by us and provided by a third party service provider via the WeChat application and the WeChat public platform (“WeChat Pay HK” or the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

This Service has been developed by WeChat Pay Hong Kong Limited, a member of the Tencent group (“we”, “us”, “our”).

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is WeChat Pay Hong Kong Limited. The registered address of WeChat Pay Hong Kong Limited is Level 29, Three Pacific Place, 1 Queen's Road East, Wanchai, Hong Kong.

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 wechatpayhk_privacy@wechat.com.

This Privacy Policy only applies to users of WeChat Pay HK.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high-level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party).

· Account information: This is personal information you give to us when you set up an account to register for the Service, such as your registered Hong Kong mobile phone number and/or your People’s Republic of China, Hong Kong, Macau, or Taiwan credit card details, as well as personal information you give to us in connection with your use of the Service, such as your name, WeChat nickname, profile picture, WeChat Pay HK password, FPS identifier, email address, and location data (“Account Information”).

Customer due diligence information: This is personal information you give to us such as your date of birth, gender, nationality, occupation, source of assets, passport or identity card and information thereon, physical address, and proof of address (such as a utilities bill, bank statement or employment contract) (“CDD Information”), where additional account security or identity verification is required to comply with our internal policies and regulatory obligations.

Customer support and feedback information: This is information that you provide to us when you communicate with our customer service, when you give us reviews or feedback or otherwise provide information to us through the Service (“Customer Support and Feedback Information”).

Third party deposit protection information: If you apply for third party deposit protection and/or make a claim, the relevant third party may provide information to us in connection with your application and/or claim, such as a description of the claim, proof of loss (e.g., police report, bank statement), and your selected method of receiving payment (“Deposit Protection Information”).

Remittance information: This is information that you give to us about your counterparty when you conduct remittances, such as their name, passport or identity card number, date of birth, gender, nationality, bank account name and number, phone number, address, remittance ID, purpose of remittance, relationship to you, and any other information you provide to us in connection with your remittance transaction (“Remittance Information”). In giving us instructions in respect of a remittance transaction, you warrant that you have obtained your counterparty’s consent to our processing of their personal information, including sharing their personal information with third parties and transferring their personal information to places outside of Hong Kong in order to provide the remittance service.

2. Information about you generated as part of the Service

We automatically collect certain personal information from you when you use the Service, namely:

· your device information, including brand, type of operating system, cellular and/or wireless network information, and standard web information, such as your browser type (“Device Information”);

· your use of promotions within the Service, such as the types of promotions participated in or redeemed and number of times a link to a type of promotion is clicked on;

· log data and statistics relating to your use of the Service; and

· when you conduct transactions using WeChat Pay HK, we will process information such as your Account Information, payment method, bank information, counterparty, amount transacted, Remittance Information, time and date of your transaction, your WeChat Pay HK account balance, and other account-related identifiers (“Transaction Data”) in order to facilitate and validate your transaction, maintain a record of your transaction history, monitor transactions on the Service and notify you of erroneous or failed transactions and suspicious activity, and maintain the security of WeChat Pay HK.

2. Children

If we agree to provide Services to minors (i.e. persons under the age of 18), we may be required to process personal information from such minors where such personal information is necessary for the provision of the Services. In this case, we will process such personal information according to this Privacy Policy and applicable laws and guidelines. If you are acting as a parent or guardian of such minor(s) and (i) wish to withdraw any consent you previously provided to us with respect to our processing of the minor’s personal information or (ii) have any questions regarding our processing of such personal information, please contact us at wechatpayhk_privacy@wechat.com.

3. How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

Personal Information	Use
Information you provide to us (either directly or through a third party).
Account Information	We use this information to: · create your account for the Service in accordance with your request; · facilitate transactions; · administer and provide services and customer support per your request; · notify you of erroneous or failed transactions and suspicious activity; · validate your application for third party deposit protection and your claim requests; · identify our users; · send service-related notifications; · send general promotions; and · send direct marketing to you (except if you have objected to such use).
CDD Information	We may collect this information if additional account security or identity verification is required to comply with our internal policies and regulatory obligations. If collected, and except if you have objected to such use, we may use this information to send direct marketing to you (such as birthday promotions).
Deposit Protection Information	We use this information to verify whether the information provided by the relevant third party deposit protection provider matches our records.
Information generated as part of the Service
Device Information	We use this information: · to personalise our 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; and · to identify and address bugs and assess service functionality for optimisation.
Types of promotions participated in or redeemed and number of times a link to a type of promotion is clicked on	We use this information to provide more personalised promotions.
Information about promotions and other benefits shared with or received from your contacts	We use this information: · to maintain a record of actions of your account; · to provide more personalised promotions to you and your contacts; · to improve our Service, including the functionality of the Service; and · for security and verification purposes.
Log data and statistics relating to your use of the Service	We use this information: · to maintain a record of log-in and actions of your account; · to improve our Service, including the functionality of the Service; · for security and verification purposes; · to validate your application for third party deposit protection and your claim requests; and · to send service-related notifications.
Transaction Data	We use this information: · to facilitate your transactions; · to maintain a record of your transaction history; · for security and verification purposes; · to monitor transactions on the Service and to notify you in the event of erroneous or failed transactions and suspicious activity; · to validate your application for third party deposit protection and your claim requests; · to send general promotions; and · send direct marketing to you (except if you have objected to such use).
Customer Support and Feedback Information	We use this information to: · improve our services; · communicate with you (via telephone, SMS, email or WeChat); · administer and provide services and customer support per your request; and · provide troubleshooting, such as addressing and remediating technical issues and bugs.
Personal information you provide to us when you choose to participate in a survey or promotion.	We use this information to: · improve our services; · communicate with you (via telephone, SMS, email or WeChat); · better understand how you access and use WeChat Pay HK; · develop new and improve existing services; · improve WeChat Pay HK and respond to customer requests and preferences; and · carry out any purpose enumerated in the survey or promotion itself which will be notified to you prior to you completing the survey or participating in the promotion.

We may aggregate the personal information we process about you for analytical purposes so that we can better understand usage trends in order to develop, improve, and market the Service. We may provide such aggregated data (which does not contain personal information) to third parties, subject to applicable laws and regulations.

In order to administer the Service, we are required to comply with certain legal obligations. This means that we will use the personal information we process about you in order to protect you from fraud, and we will monitor certain transactions as required by law and as set out in the WeChat Pay Hong Kong Stored Value and Payment Processing Service Agreement.

4. How We Store and Share Your Personal Information

We take appropriate measures to safeguard your rights in accordance with this Privacy Policy.

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, or which are accessible through, the Service (such as partner financial institutions, payment processing and remittance partners, acquiring institutions, deposit protection providers, and cloud service providers). 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 their services, as the case may be, and subject to applicable laws and regulations. Whenever possible, we provide third parties with account-related identifiers so that the transaction and/or service can be facilitated without using other personal information such as your name or WeChat nickname.

· 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.

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

6. Data Retention

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. Different retention periods may apply to different types of personal information collected and held by us in accordance with applicable laws, regulations, and our internal policies.

7. Your Rights

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

8. Service-related Notifications

We may from time to time send you service-related notifications when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related notifications). You may not opt out of these service-related notifications, which are not promotional in nature.

9. Direct Marketing

You may opt out of receiving direct marketing by following the instructions in the direct marketing message or email, or by contacting us at wechatpayhk_privacy@wechat.com.

10. Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to wechatpayhk_privacy@wechat.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at wechatpayhk_privacy@wechat.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 the data protection authority where you think we have infringed data protection laws.

11. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

12. Language of this Privacy Policy

In the event of any discrepancy or inconsistency between the English version and Chinese version of this Privacy Policy, the English version shall prevail.