Lianlianpay Privacy Policy for
Free Walker App
Release date:
Effective date:
Thank you for choosing Free
Walker App!
The information collected by Free
Walker App is solely for providing you with quality services and to protect the
security of your personal information. This Privacy Policy covers the rules for
handling your personal information in the services provided on the Free Walker App,
so please read the terms and conditions
of this Privacy Policy carefully before using our services and agree to
proceed. This policy only applies to Lianlian Yintong Electronic Payment
Co., Ltd (hereinafter referred to as “Lianlian” or “we” or “us”, of which the registered
address is Floor 11 Building 1 Lianlian tower，No.79 Yueda Lane, Binjiang
District, Hangzhou, Zhejiang Province, China.) for providing payment services
on Free Walker App.
For your convenience, you can
view the complete version of the Privacy Policy by accessing the “Privacy
Policy” section in “My - Settings - Privacy Policy” after logging into Free
Walker App on the new user registration interface.
This policy will help you
understand the following:
How we collect and use your personal information
How we protect your personal information
Your rights
How we handle personal information of minors under the
age of fourteen
How your personal information is transferred globally
How this policy is updated
How to contact us
We are fully aware of the
importance of personal information to you and will do our best to protect your
personal information, and thank you for your trust in us. We are committed to
protecting your personal information in accordance with the industry’s established
security standards, taking appropriate
security measures to protect your personal information, and endeavoring to
interpret for and inform you in easy-to-understand written forms, and we have
highlighted in bold font the provisions in this policy that may have a
significant impact on your legitimate interests to draw your attention. We
strongly recommend that you read and fully understand the entire content of
this Policy before using our services. We will provide you with services
based on your preference. This Policy applies to the collection, use, storage
and provision of your personal information within the People’s Republic of
China (except Hong Kong, Macau and Taiwan for the purposes of this Privacy
Policy).
If you check the box “I have read and agreed” and confirm
to submit, it will be considered that you agree to this policy and authorize us
to process your personal information in accordance with the provisions of this
policy. If we intend to use your personal information for purposes other than
those mentioned in this Privacy Policy, or to use information collected for
other specific purposes, we will promptly inform you in a reasonable manner and
obtain your authorized consent.
I.
How we collect and use your
personal information
1.
What personal information do
we need to collect from you.
1.1
You need to authorize us to
collect and use your personal information in the following circumstance.
When you use the App and the
Service, you understand and agree that we will collect and use specific types
of your personal information as per the following scenarios, for the purposes
of providing you with relevant services, ensuring the security of your account
and funds, and complying with relevant regulatory requirements of national laws
and regulations.
1)
Registration for the App
During the process of
registering on the APP, please provide your
E-mail address, Google ID, or Apple ID. You can choose one of them for the
APP login name. You shall set your own
password for logging into the App that meets security requirements and keep
such password secure. You log in to the APP through your login name and
password. If you do not provide the foregoing information, you may
not be able to register for the APP account.
2)
Apply for the Lianlianpay account
During the process of applying
for the payment account and use the service of our cooperating institutions, please
provide your name, identity document
type, identity document number and validity period, nationality, gender, image
information of identity document, for the purpose of authorizing your
identification. If you do not provide the foregoing information, you may not be
able to apply for a Lianlianpay account and use the payment services.
3)
Password retrieval
To protect the security of
your account and funds, when you need to retrieval your password, please
provide your email address so that
we can send email to you to verify your identity. If you do not agree to our
collection of that information, you may not be able to complete the password
retrieval.
1.2
Information generated in the
course of your use of services
When you use the services we
provide, we may access software
development kits (SDKs) provided by our partners, which you understand and
recognize. We carry out strict security checks on the SDKs from which our
partners collect your information and require them take strict data protection
measures in accordance with this policy and applicable laws and regulations
during the process of handling personal information. Details of the SDKs we have access to are as below, and we suggest that
you read the relevant privacy policies carefully (please note that the privacy
policies of the following partners may be updated from time to time due to
changes in circumstances, so please pay attention to them and check them
promptly):
1)
The J Push SDK
The J Push SDK is provided by
Shenzhen Hexun Huagu
Information Technology Co., Ltd. To facilitate your timely receipt of
transaction notifications through the APP, it will collect your device information, including but not
limited to IMEI/MAC/Android ID/IDFA/OAID/Open UDID/GUID/BSSID/SSID/the IMSI
information of SIM card. If you do not provide the aforementioned information,
you may not be able to use the notification service, but it will not affect
your use of other services we provide.
2)
The Gaode
location SDK
The Gaode
location SDK is provided by Gaode Software Co., Ltd.
To make efforts to protect the security of your account and provide you with a
more convenient experience, when you enable device location services and use
our location-based services, it collects your geographic location information, device information (including IMEI,
IDFA, Android ID, MEID, MAC address, OAID, IMSI, hardware serial number). If
you do not provide the aforementioned information, you may not be able to use
the location-based services.
3)
Lianlian Information QR Code
Payment SDK
Lianlian Information QR Code Payment SDK is provided by Lianlian
(Hangzhou) Information Technology Co., Ltd. When you use the QR Code payment
service, it will collect your location
information, device information (including IMEI, IDFA, Android ID, MEID, MAC
address, OAID, IMSI, Hardware Serial Number); the device type (IOS, android, or
other), Imei number, Sim number, machine
code, IOS machine code; latitude and longitude, IP address, cellular device and
phone model; Resolution, model, phone model, SDK version number, release
version, carrier (optional), networking method, whether IOS is jailbroken,
Android swiped. If you do not provide the
aforementioned information, you may not be able to use the QR Code payment
service, but it will not affect your use of other services we provide.
1.3
You can choose whether to
authorize us to collect and use your personal information in the following
circumstances.
1)
To help you to use QR code payment services, you can authorize us to
access your camera device when you
use it for the first time. If you do not provide this personal information, you
may not be able to use the aforementioned services, but it will not affect your
use of other services we provide.
2)
To facilitate your timely receipt of transaction notifications, you can
authorize us to enable notification
permissions when installing the App. If you do not provide this personal
information, you may not be able to use the aforementioned services, but it
will not affect your use of other services we provide.
3)
To prevent you from using the APP properly after we upgrade it, we need to
obtain authorization from your mobile
device regarding the use of the media and files. Otherwise, your APP will not
be upgraded automatically, which will affect your normal use of it.
4)
To help you to find the addresses of the exchange net for using the
service, we need to obtain authorization from your mobile device regarding the use of the location
information. If you do not provide this personal information, you may not
be able to use the aforementioned services, but it will not affect your use of
other services we provide.
1.4
You fully understand that,
according to relevant laws and regulations, in the following circumstances, we
may collect and use your personal information in accordance with the law
without obtaining your authorization and consent:
1)
Information directly related to national security and defense security;
2)
Information directly related to public security, public health, and
significant public interests;
3)
Information directly related to criminal investigations, prosecutions,
trials, and execution of judgments;
4)
Information necessary for the protection of your or others’ vital
interests, such as life, property, etc., but it is difficult to obtain your
consent;
5)
The personal information involved has been publicly disclosed by you
yourself;
6)
Information necessary for the signing and performance of contracts at your
request;
7)
Information collected from legally publicly disclosed sources, such as
legitimate news reports, government information disclosure, etc.;
8)
Information necessary to maintain the safety and stable operation of the
products or services provided, such as discovering and handling failures of products
or services.
2.
Rules for the use of your
personal information
1)
We will use the personal information collected in accordance with the
provisions of this Privacy Policy and to fulfill the functions of our products
and/or services.
2)
To ensure the stability and security of our services, we may use your
information for identity verification, security measures, fraud monitoring,
prevention or prohibition of illegal activities, risk reduction, archiving, and
backup purposes.
3)
We may report to relevant authorities in accordance with laws,
regulations, or regulatory requirements.
4)
After collecting your personal information, we will use technical means to
de-identify and anonymize the data. The de-identified information will not be
valuable for identifying individuals.
5)
Please note that all personal information you provide when using our
products and/or services will continue to be authorized for us to use unless
you delete it or refuse our collection of it through the system settings.
6)
We may conduct statistical analysis of the usage of our products and/or
services and may share the statistical information with the public or third
parties to showcase the overall usage trends of our products and/or services.
However, the statistical information will not include any personally
identifiable information about you.
7)
When we use your personal
information for purposes not specified in this policy or when information
collected for specific purposes is used for other purposes, we will obtain your
consent again in accordance with the requirements of laws, regulations, and
national standards.
3.
How we share, transfer, and
publicly disclose your personal information
3.1
Share.
We will not share your
personal information with any company, organization or individual outside of Lianlian
unless we have your explicit consent.
We will only share your personal information for lawful, legitimate, necessary,
specific and clear purposes, and will only share personal information that is
necessary for our services. Our partners are not authorized to use the shared
personal information for any other purpose. We will sign strict confidentiality
agreements with companies, organizations and individuals with whom we share
such personal information, requiring them to handle personal information in
accordance with our instructions, this Privacy Policy, and any other relevant
confidentiality and security measures, and we will require our partners to
provide data security capabilities and information security qualifications (
such as evaluation for multi-level protection, information security management
system, etc.). We require third parties to use data masking and encryption
techniques to protect user data when using sensitive personal data. If you have
any objections to the use of your personal information by third parties or find
that the applications developed by these third parties are risky, we suggest
that you terminate the relevant operations to protect your legitimate rights
and interests, and you can also negotiate with the corresponding third parties
to solve the problem, and we will provide assistance
as much as possible. If Lianlian violates the laws and regulations in the
process and causes losses to you, we will bear the corresponding
responsibilities arising therefrom. Currently, we ask for your authorization
and consent for sharing your personal information in the following
circumstances:
We may share your personal
information externally in accordance with laws and regulations or the mandatory
requirements of governmental authorities. If Lianlian violates the laws and
regulations in the process and causes losses to you, we will bear the
corresponding responsibilities arising therefrom.
3.2
Transfer
We will not transfer your
personal information to any company, organization or individual, except in the
following cases:
1)
Transfer with explicit consent: We will transfer your personal information
to other parties after obtaining your explicit consent;
2)
Such information is provided in accordance with applicable laws and
regulations, the requirements of legal proceedings, and as necessary for
mandatory administrative or judicial requirements;
3)
In case of mergers, acquisitions, asset transfers, or similar transactions
that involve the transfer of personal information, we will require the other
company or organization that holds your personal information to be bound by
this Privacy Policy as well, or we will require the company or organization to
seek authorization and consent from you again.
3.3
Public disclosure
We will not publicly disclose
your personal information except under certain circumstances. When disclosure
is necessary, we will inform you of the purpose of public disclosure, the type
of personal information to be disclosed, the type of sensitive personal
information involved, and will disclose your personal information only after
obtaining your explicit consent with industry-standard security measures
adopted. If we violate the laws and regulations in the process and causes
losses to you, we will bear the corresponding responsibilities arising
therefrom.
3.4
Disclosure without consent
In accordance with relevant
laws and regulations and national standards, we may share, transfer, and
publicly disclose your personal information without your consent in the following
cases in accordance with the law:
1)
Information directly related to national security and defense security;
2)
Information directly related to public security, public health, and
significant public interests;
3)
Information directly related to criminal investigations, prosecutions,
trials, and execution of judgments;
4)
Information necessary for the protection of your or others’ vital
interests, such as life, property, etc., but it is difficult to obtain your
consent;
5)
Personal information publicly disclosed by you yourself;
6)
Personal information collected from legally publicly disclosed sources,
such as legitimate news reports, government information disclosure, etc.
II.
How we protect your personal
information
1.
In accordance with relevant laws and regulations, we will store your
personal information collected and generated during our operations in the
People’s Republic of China. We will retain your personal information only for
the period necessary for the purpose of providing you with the service and
within the time limit prescribed by laws, regulations and regulatory
requirements.
2.
We have obtained the following certifications: our core business system
has passed Level 4 certification of Multi-level Information System Protection
of the People’s Republic of China, and our core online payment system has
passed Level 3 certification of Multi-level Information System Protection of
the People’s Republic of China.
3.
If we cease to operate this App or the service, we will promptly cease
activities to collect your personal information, notify you of the cessation of
operations by individual delivery or announcement, and delete or anonymize your
personal information in our possession.
4.
We have adopted various protection methods such as internal management
system and technical measures to protect your personal information,
specifically including but not limited to:
4.1
Internal management system
1)
We have adopted a classification and grading system based on the extent
and type of sensitivity of personal information, and based on the results of
the classification and grading, we have imposed restrictions on user
privileges, use scenario privileges, use authorization privileges, and graded
approval mechanisms, among other things.
2)
Through regular security audits, we will conduct comprehensive
verification and control of the effectiveness of privacy policies and related
regulations as well as data security.
3)
As for supporting mechanisms, we have set up a personal information
protection team to carry out impact assessments for the collection, use,
provision and entrusted processing of personal information to protect personal
information, trained internal staff on relevant laws and regulations and
guidelines for personal information security and security awareness, and
annually organized all staff to take a compliance test.
4)
After you correct or delete your personal information or cancel your
account, your personal information will be handled by the backup system in
accordance with regulatory requirements.
4.2
Technical support measures
In terms of technical support
measures, we have adopted irreversible encrypted storage and segregated storage
of sensitive personal information for storage, de-identification for
information display and download, and technical measures such as private line transmission,
encrypted transmission, and segregated transmission of keys and data media for
transmission, to ensure the security of your personal information.
1)
We have formulated relevant emergency response plans for information
security incidents and regularly organized emergency response training and
emergency drills for relevant internal personnel to ensure that they are aware
of their job responsibilities and emergency handling strategies and procedures.
2)
After the occurrence of a personal information security incident (if any),
we will, in accordance with the requirements of laws and regulations, promptly
inform you of the following: the basic situation of the security incident and
its potential impact, the measures we have taken or will take to deal with the
incident, the suggestions for you to independently make to prevent and reduce
the risk, and the remedial measures for you. We will promptly inform you of the
related situation by App notifications. When it is impossible to inform the
owners of personal information one by one, we will take a reasonable and
effective way to make a public announcement. At the same time, we will also
take the initiative to report the disposition of personal information security
incidents in accordance with the provisions of laws and regulations and the
requirements of regulatory authorities. If your legitimate rights and interests
are damaged, we will assume the corresponding legal responsibility.
3)
Security tips: Although we have taken the
above security measures and actively implement the standards required by laws
and regulations, please understand that due to technical constraints and the
possible occurrence of a variety of malicious behaviors from outside, we cannot
guarantee that the information is completely safe, but we will do our best in
this regard. Please be aware and
understand that the systems and communication networks used for your access to
our services may have security problems beyond our control, so we strongly recommend that you take
active measures to protect the security of your personal information, including
but not limited to using more complex passwords, not disclosing personal
account passwords and sensitive personal information to others, etc.
4)
The Internet environment is not 100% safe, we will try our best to ensure
the security of any information you send to us. After the occurrence of a
personal information security incident (if any), we will, in accordance with
the requirements of laws and regulations, promptly inform you of the following:
the basic situation of the security incident and its potential impact, the
measures we have taken or will take to deal with the incident, the suggestions
for you to independently make to prevent and reduce the risk, and the remedial
measures for you. We will promptly inform you of the related situation by App
notifications. When it is impossible to inform the owners of personal
information one by one, we will take a reasonable and effective way to make a
public announcement. At the same time, we will also take the initiative to
report the disposition of personal information security incidents in accordance
with the requirements of regulatory authorities. If your legitimate rights and
interests are damaged, we will assume the corresponding legal responsibility.
5)
Please be sure to keep your
App login name and other identity factors properly. When you use the service, we
will identify you by your login name and other identity factors. Once you have
disclosed the aforementioned information, you may suffer losses and may be
subject unfavorable legal consequences. If you find that your App login name
and/or other identity factors may or have been leaked, please contact us
immediately (send an e-mail to our customer service email address: service@lianlianpay.com)
so that we can take appropriate measures in a timely manner to avoid or reduce
related losses.
III.
Your rights
According to the relevant
Chinese laws, regulations and standards, as well as the common practice in
other countries and regions, we protect your rights to your personal
information in the form of the following:
1.
Access to your personal information.
You have the right to access
your personal information, except for the exceptions stipulated by laws and
regulations. You can log in to your App account through this App and access and
check your personal information through the following channels:
Check the transaction and
consumption records (transaction amount, transaction type, merchant name) in “mine→
Record of changes in balance”;
2.
Deletion of your personal information.
2.1
In the following circumstances, you can request us to delete your personal
information by sending an e-mail to us:
1)
If our processing of personal information violates laws and regulations;
2)
If we collect and use your personal information without obtaining your
consent;
3)
If our processing of personal information violates the agreement with you;
4)
If you no longer use our products or services, or if you cancel your
account;
5)
If we terminate our services and operations.
2.2
If we decide to respond to your deletion request, we will also notify the
entities that have obtained your personal information from us and request them
to delete it in a timely manner unless otherwise required by laws and
regulations, or unless these entities have obtained your authorization
separate. After you delete information from our services, we may not
immediately delete the corresponding information from our backup systems, but
we will delete it when the backups are updated.
3.
Cancellation of your account
After you cancel your account
and return your funds in your payment account that Lianlian set up for you, we
will stop providing you with payment services and, at your request, delete your
personal information, unless otherwise provided by laws or regulations.
4.
Acquisition of a copy of your personal information
5.
You have the right to acquire a copy of your personal information. If you
need to obtain a copy of the personal information we have collected about you,
you can do so by sending an e-mail to our customer service email address: service@lianlianpay.com.
The customer service representative will verify your personal information to
confirm your identity. Once confirmed, they will submit a copy of your personal
information to you. Upon your request, and where permitted and technically
feasible under relevant laws and regulations, we will provide you with a copy
of your personal information.
6.
Response to your requests above
You can send an e-mail to our
customer service email address: service@lianlianpay.com to submit any
questions, suggestions, opinions, or complaints. To ensure security, we will
process your inquiries after necessary identity verification, and respond
within a maximum of fifteen days or within the timeframe required by applicable
laws and regulations. We generally do not charge any fees for your reasonable
requests. However, according to relevant laws, regulations, and national
standards, there may be situations where we are unable to respond to your
requests.
1)
Information directly related to national security and defense security;
2)
Information related to public security, public health, and significant
public interests;
3)
Information related to criminal investigations, prosecutions, trials, and
execution of judgments;
4)
There is sufficient evidence to suggest that you have subjective malice or
abuse your rights;
5)
Information necessary for the protection of your or others’ vital
interests, such as life, property, etc., but it is difficult to obtain your
consent;
6)
Responding to your request would seriously harm the legitimate rights and
interests of other individuals, organizations, or owners of personal
information;
7)
Information involving trade secrets.
IV.
How we handle personal
information of minors under the age of fourteen
1.
Our payment services are primarily for adults. Minors are not permitted to
create their own user accounts without the consent of parents or guardians. In
cases where we collect personal information of minors under the age of fourteen
with the consent of their parents, we will only use or disclose such
information when permitted by law, with explicit consent from their parents or
guardians, or when necessary to protect these minors under the age of fourteen.
2.
Although the definition of minors may vary according to local laws and
customs, we consider anyone under the age of fourteen as a minor.
3.
If we discover that we have collected personal information of a minor
under the age of fourteen without verifiable consent from his/her parents, we
will take steps to promptly delete the relevant data.
4.
If you are the parent or
guardian of a minor and have concerns about the handling of personal
information regarding the minor under the age of fourteen you are responsible
for, please contact us through the contact methods mentioned above.
V.
How your personal information
is transferred globally
In principle, the Service in the
APP are only intended for use within the territory of the People’s Republic of
China. And the personal information we collect and generate during our
operations within the territory of the People’s Republic of China is stored
within China.
VI.
How this policy is updated
1.
Our Privacy Policy is subject to change. Without your explicit consent, we
will not diminish the rights you are entitled to under the current effective
policy. When there are significant changes to this Policy, we will notify you
in a timely manner through methods such as pop-up alerts, message
notifications. Significant changes may include, but are not limited to:
1)
There are significant changes in the scope and mode of services we
provide, such as changes in the purposes of collecting and using personal
information, types of personal information processed, or methods of using
personal information;
2)
There are significant changes in our operating entity, organizational
structure, ownership structure, such as changes in ownership resulting from
business adjustments, mergers, acquisitions, or reorganizations;
3)
There are significant changes in your rights and means of exercising them
in relation to the processing of personal information;
4)
There are changes in the methods, primary recipients, or other aspects of
personal information sharing, transfer, or public disclosure;
5)
The personal information risk assessment report indicates a high risk;
6)
There are changes in the department responsible for the security of
personal information, their contact information, or the complaint channels;
7)
Other changes that may have a significant impact on your rights and
interests concerning personal information. To ensure you receive timely
notifications, we recommend that you inform us promptly when your contact
information changes. If you continue to use the services after the updated
policy comes into effect, it means that you have read, understood, and accepted
the updated policy and are willing to be bound by it.
You can view this Policy in
the App by going to “Mine -> Settings -> Privacy Policy”. We encourage
you to review our privacy policy every time you use the App.
VII.
How to contact us
If you have any questions,
opinions or suggestions regarding this Privacy Policy or your personal
information, please contact us through various methods such as sending an e-mail to our customer service
email address: service@lianlianpay.com.
We have designated a Data
Protection Officer, and you can contact him/her via email at privacy@lianlianpay.com.