Privacy Policy

Release date of this version: January 1, 2021

Effective date: January 1, 2021

Overview

This policy will help you understand the following:

  1. 1. How we collect personal information
  2. 2. How we use Cookie, Beacon, Proxy and other technologies
  3. 3. How we store and protect personal information
  4. 4. How we use personal information
  5. 5. How we provide personal information to external parties
  6. 6. How do you access your personal information?
  7. 7. Statement on Third Party Responsibilities
  8. 8. Special agreement on privacy rights of minors
  9. 9. Application and update of this policy
  10. 10. Description of keywords in this policy

AirPay Financial Technologies Pty Ltd (AirPayFinTech) (Address: Level 11, 333 Collins Street, Melbourne, VIC 3000) and its AirPass product (hereinafter referred to as "we") respect and protect your privacy. When you use our services, we will collect, store, use and provide your personal information in accordance with the AirPass Privacy Policy (hereinafter referred to as "this policy"). At the same time, we will explain to you through this policy how we provide you with services to access, update, manage and protect your information. This policy is closely related to your use of our services. We recommend that you carefully read and understand the entire content of this policy and make the choices you deem appropriate. We strive to express it in easy-to-understand, concise words, and mark the provisions in this policy that have a significant bearing on your rights and interests in bold to draw your attention.

In order to comply with national laws, regulations and regulatory requirements (for example: conducting real-name management, performing anti-money laundering duties, taking risk prevention measures), and also to provide you with services and improve service quality (for example: supporting us in developing new products or improving existing product functions) , to provide you with and recommend more high-quality or suitable services), we need to collect, store, use and provide your information to the outside world. You agree that we will process your information in accordance with this policy so that you can enjoy high-quality, convenient and personalized services while better protecting the security of your account and funds.

How we collect personal information

When you use AirPass products and services, we need to collect some of your information in the following situations to provide you with services, improve our service quality, protect the security of your account and funds, and comply with national laws, regulations and regulatory requirements. :

  1. 1. Fulfill anti-money laundering obligations and conduct real-name management in accordance with laws, regulations and regulatory provisions
    1. (1) When you register an AirPass account or use AirPass products and services, you need to provide your valid ID information, contact information, and address. If you do not provide the above information, you may not be able to register an AirPass product account or use AirPass product services. According to relevant laws and regulations, you must pass multiple cross-verifications of basic identity information before you can use our services;
    2. (2) We need to prompt you to provide a color photocopy or photo of your valid ID in a timely manner for us to check and retain in accordance with the "Anti-Money Laundering and Anti-Terrorist Financing Management Measures for Payment Institutions" and other anti-money laundering laws, regulations and regulatory requirements; if you If you do not provide the aforementioned color photocopies or photos, you may not be able to use some AirPass product services.
  2. 2. Payment
    1. (1) In order for you to use bank card-based consumption, transfer, red envelope and other functions, you need to provide your bank card number, name, ID number, and bank-reserved mobile phone number. If you do not provide the above information, you may not be able to use some AirPass products and services;
    2. (2) When you pay a merchant, in accordance with laws, regulations and regulatory provisions, we need to manage the merchant (for example, identify and prevent cash out or fraud). At the same time, in order to provide you with bill query management functions, we need to provide you with bill query management functions. Collect information related to your transaction (for example: payment amount, payment object, product name, delivery information). If you do not agree to provide the aforementioned information, you may not be able to complete the transaction; (3) In order to protect the security of your account and funds, we need to verify your identity when you need to retrieve your password, for which you need to provide us with some available information. Proof of your identity. You can upload your proof of identity according to the prompts on the relevant page.
  3. 3. Risk prevention In order to improve the security of your use of our services and prevent your funds and personal information from being obtained by criminals, we need to record the AirPass product service category, method and related operation information you use, such as: device model, IP address, device software version Information, device identification code, device identifier, location, network usage habits, and other log information related to AirPass product services. If you do not agree to provide the aforementioned information, you may not be able to complete the risk control verification.
  4. 4. According to relevant laws, regulations and national standards, in the following situations, we may collect and use your personal information in accordance with the law without obtaining your consent:
    1. (1) Directly related to national security and national defense security;
    2. (2) Directly related to public security, public health, and major public interests;
    3. (3) Directly related to criminal investigation, prosecution, trial and judgment execution;
    4. (4) To protect your or others’ life, property and other major legitimate rights and interests but it is difficult to obtain your consent;
    5. (5) The personal information collected is disclosed to the public by you yourself;
    6. (6) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
    7. (7) Necessary to sign and perform a contract according to your requirements;
    8. (8) Necessary to maintain the safe and stable operation of the services provided, such as: discovering and handling product or service failures;
    9. (9) Other situations stipulated by laws and regulations.
  5. 5. Others When we provide you with other business functions, we will separately explain to you the scope and purpose of information collection, and obtain your consent before collecting your information necessary to provide the corresponding services. We will use, store, provide and protect your information in accordance with this policy and the corresponding user agreement; if you choose not to provide the aforementioned information, it will not affect your use of payment services.

How we use Cookie, Beacon, Proxy and other technologies

In order to provide you with an easier access experience, when you visit the AirPass website or use the services provided by AirPass, we may identify you through small data files. This can help you save the need to repeatedly enter registration information, or help you Determine the security status of your account. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (hereinafter referred to as "Cookies"). Please understand that some of our services can only be achieved through the use of Cookies. If your browser or browser add-on services allow, you can modify your acceptance of cookies or reject AirPass cookies. The "Help" section of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have your browser notify you when you receive a new cookie, or how to turn off cookies entirely. In addition, you can turn off or delete similar data used by browser add-ons (e.g. Flash Cookies) by changing the settings of the browser add-on or by visiting the provider's web page. However, this move may affect your safe access to the AirPass website and use of services provided by AirPass under certain circumstances.

Our website may also contain some electronic images (hereinafter referred to as "single-pixel GIF files" or "network Beacon"). The use of network Beacon can help the website count users browsing the web or access certain cookies. We will collect your browsing history through the network Beacon. Information about web activity, such as the address of the page you visited, the location of the referring page you previously visited, your browsing environment and display settings. If you use services provided by third parties other than AirPass through our website or APP, we cannot guarantee that these third parties will take protective measures in accordance with our requirements. We will try our best to ensure the security of your account and make you safer. To provide a better access experience, we may use dedicated network protocols and proxy technologies (hereinafter referred to as "dedicated network channels" or "network agents"). Using a dedicated network channel can help you identify high-risk sites that we know and reduce the resulting risks such as phishing and account leakage. At the same time, it is more conducive to protecting the common rights and interests of you and third parties and preventing criminals from tampering with you and yours. Normal service content between third parties you wish to access, such as advertising injection, illegal content tampering, etc. caused by insecure routers, illegal base stations, etc. During this process, we may also obtain and save relevant information about your computer, such as IP address and hardware ID.

How we store and protect personal information

  1. 1. For products involving cross-border business, if we need to transfer relevant personal information collected domestically to overseas institutions, we will implement it in accordance with laws, regulations and relevant regulatory authorities, and require effective measures such as signing agreements and on-site inspections to require overseas The organization maintains the confidentiality of your personal information obtained. We will only store your personal information for the period necessary for the purposes stated in this policy and within the time limits stipulated by laws, regulations and supervision.
  2. 2. We promise that we will make information security protection reach the industry-leading security level. To ensure the security of your information, we are committed to using various security technologies and supporting management systems to minimize the risk of your information being leaked, damaged, misused, unauthorized accessed, disclosed and altered. For example: encrypted transmission through network security layer software (SSL), encrypted information storage, strictly restricting access to data centers, using dedicated network channels and network proxies. At the same time, we have established a personal information protection department, established relevant internal control systems, and adopted the principle of minimum authorization for staff who may have access to your information; we systematically monitor the staff's behavior in handling your information, and constantly monitor the staff's behavior. We provide training on relevant laws and regulations, privacy and security guidelines, and strengthen security awareness, and organize all staff to take security exams every year. In addition, we hire an external independent third party to evaluate our information security management system every year.
  3. 3. We have formulated an emergency plan for personal information security incidents and regularly organize relevant internal personnel to conduct emergency response training and emergency drills so that they can master their job responsibilities and emergency response strategies and procedures. After an unfortunate personal information security incident occurs, 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 steps you can take to prevent and reduce risks on your own. Suggestions, remedies for you, etc. We will promptly notify you of the incident-related information through APP push notifications, sending emails/short messages, etc. When it is difficult to inform the personal information subjects one by one, we will issue announcements in a reasonable and effective manner. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities. If your legitimate rights and interests are damaged, we will bear the corresponding legal liability.
  4. 4. Please be sure to keep your AirPass product login name and other identity factors properly. When you use AirPass products and services, we will identify you through your login name and other identity factors. Once you leak the aforementioned information, you may suffer losses and may have adverse legal consequences against you. If you find that your AirPass product login name and/or other identity elements may or have been leaked, please contact us immediately so that we can take appropriate measures in a timely manner to avoid or reduce related losses.
  5. 5. After you terminate your use of AirPass products and services, we will stop collecting and using your information, unless otherwise provided by laws, regulations or regulatory authorities. If we cease operations, we will promptly stop collecting your personal information, notify you of the cessation of operations in the form of one-by-one delivery or announcements, and delete or anonymize the personal information we hold.

How we use personal information

  1. 1. In order to comply with national laws, regulations and regulatory requirements, provide you with services and improve service quality, or protect the security of your account and funds, we will use your information in the following situations:
    1. (1) To achieve the purposes stated in "How We Collect Personal Information" in this policy;
    2. (2) In order to let you know the status of using AirPass product services, we will send you service reminders. You can unsubscribe from messages on the "Service Reminder" page and→set up→Message Management" resubscribe.
    3. (3) In order to ensure the stability and security of the service, we will use your information for identity verification, security prevention, fraud monitoring, prevention or prohibition of illegal activities, risk reduction, archiving and backup purposes;
    4. (4) Report to relevant departments in accordance with laws, regulations or regulatory requirements; (5) Invite you to participate in customer research related to our products or services; (6) We will conduct comprehensive statistics, analysis and processing of your information in order to provide you with More accurate, personalized, smooth and convenient services, or help us evaluate, improve or design products, services and operational activities, etc.
  2. 2. When we want to use the information for other purposes not specified in this policy, we will seek your consent again in the form of confirmation agreements, copywriting confirmation actions in specific scenarios, etc. in accordance with the requirements of laws, regulations and national standards.

How we provide personal information to external parties

  1. 1. Share
    1. (1) Business sharing
    2. We are committed to keeping your information confidential. Unless otherwise provided by laws, regulations and regulatory authorities, we will only share your information with third parties under the following circumstances. Third parties include our affiliates, cooperative financial institutions and other partners. Before providing information to a third party, we will use commercially reasonable efforts to evaluate the legality, legitimacy, and necessity of the information collected by the third party. We will sign relevant legal documents with third parties and require third parties to abide by laws and regulations when processing your personal information, and try our best to require third parties to take protective measures for your information.

      1. (1) In order for you to complete the transaction and achieve the purpose of the transaction, we need to provide your transaction counterparty with the transaction number and related payment information. At the same time, your transaction counterparty can view some of your registration information during the payment process or after the payment is successful. ;
      2. (2) Some products or services may be provided by third parties or jointly provided by us and third parties. Therefore, only by sharing your information can the products or services you need be provided;
      3. (3) If you choose to participate in draws, contests or similar promotional activities jointly carried out by us and a third party, we may share with them the information generated during the activity and necessary to complete the activity so that the third party can issue prizes to you in a timely manner or To provide you with services, we will clearly inform you on the activity rules page or through other channels what kind of personal information needs to be provided to third parties in accordance with the requirements of laws, regulations or national standards;
      4. (4) With your explicit consent in advance, We will share your information with third parties based on your authorization to the extent permitted by laws and regulations and not contrary to public order and good morals.
    3. (2) Complaint handling
    4. When you complain or are complained by others, in order to protect your legitimate rights and interests and those of others and maintain a green trading environment, we may provide your name, valid ID number, contact information, and complaint-related content to the consumer rights protection department and Supervisory authorities in order to promptly resolve complaints and disputes, except where provision is expressly prohibited by laws and regulations.

  2. 2. Transfer
  3. We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

    1. (1) Obtain your explicit consent in advance;
    2. (2) According to laws, regulations or mandatory administrative or judicial requirements;
    3. (3) When involving asset transfer, acquisition, merger, reorganization or bankruptcy liquidation, if personal information transfer is involved, we will inform you of the relevant situation and require new companies and organizations that hold your personal information to continue to be bound by this policy. constraints. If the purpose of using personal information is changed, we will require the company or organization to obtain your explicit consent again.
  4. 3. Public disclosure
  5. In principle, we will not disclose your information to the public except for displaying the winner's mobile phone number or AirPass login name in a desensitized manner when announcing the list of winners. If public disclosure is necessary, we will inform you of the purpose of public disclosure, the type of information disclosed and the sensitive information that may be involved, and obtain your explicit consent.

  6. 4. Entrusted processing
  7. In order to improve information processing efficiency, reduce information processing costs, or improve information processing accuracy, we may entrust capable affiliates or other professional organizations to process user information on our behalf, but we will do so through written agreements, on-site audits, etc. The method requires the entrusted company to abide by strict confidentiality obligations and take effective confidentiality measures, and prohibits it from using this information for purposes without your authorization. When the entrustment relationship is terminated, the entrusted company will no longer store personal information. We are committed to being responsible.

  8. 5. According to relevant laws, regulations and national standards, in the following situations, we may share, transfer, and publicly disclose your personal information in accordance with the law without your consent:
    1. (1) Directly related to national security and national defense security;
    2. (2) Directly related to public security, public health, and major public interests;
    3. (3) Directly related to criminal investigation, prosecution, trial and judgment execution;
    4. (4) To protect your or other individuals’ life, property and other major legitimate rights and interests but it is difficult to obtain your consent;
    5. (5) Personal information that you disclose to the public on your own;
    6. (6) Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

How you access your personal information

During your use of AirPass product services, in order for you to access your personal information more conveniently, we have provided you with corresponding operation settings in the product design. You can refer to the following guidelines for operation.

  1. 1. Manage your personal information
  2. You can log in to your account from the AirPass product backend system to query transaction management, reconciliation management, daily settlement, system management and other information.

  3. 2. If you find that our collection and use of your personal information violates laws and regulations or violates our agreement with you, you can contact us to request that the corresponding information be deleted.
  4. 3. Despite the above agreement, in accordance with relevant laws, regulations and national standards, we may not be able to respond to your request in the following circumstances:
    1. (1) Directly related to national security and national defense security;
    2. (2) Directly related to public security, public health, and major public interests;
    3. (3) Directly related to criminal investigation, prosecution, trial and execution of judgments;
    4. (4) There is sufficient evidence to show that you have subjective malice or abused your rights;
    5. (5) Responding to your request will cause serious damage to the legitimate rights and interests of other individuals and organizations;
    6. (6) Involving business secrets.
  5. 4. If you have any questions about this policy, or have any complaints or comments about the processing of your personal information, please contact us in time. To ensure the security of your information, we need to verify your identity and credentials first. We have established a customer complaint management mechanism, including a follow-up process. Generally speaking, we will complete the processing within three working days after the verification is passed. In special circumstances, we will respond within no more than thirty days or within the period specified by laws and regulations. If you are not satisfied with our response, you can also complain to the consumer rights protection department or file a lawsuit with a court of competent jurisdiction.

Statement on third party liability

Please note that your transaction counterparties, third-party website operators you visit, third-party services accessed through us and third parties that receive your personal information through AirPass may have their own privacy protection policies; when you When viewing web pages created by third parties or using applications developed by third parties, these third parties may place their own cookies or pixel tags. These cookies or pixel tags are not under our control, and their use is not covered by this policy. constraint. We will make commercially reasonable efforts to require these entities to take protective measures for your personal information, but we cannot guarantee that these entities will take protective measures in accordance with our requirements. Please contact them directly to obtain information about their privacy rights. Details of the policy. If you find that these web pages created by third parties or applications developed by third parties are risky, it is recommended that you terminate the relevant operations to protect your legitimate rights and interests.

Special Agreement on Privacy Rights of Minors

  1. 1. We expect parents or guardians to guide minors in using our services. We will protect the confidentiality and security of minors' personal information in accordance with relevant national laws and regulations.
  2. 2. If you are a minor, it is recommended that your parents or guardians read this policy and use our services or provide us with your information with the consent of your parents or guardians. For situations where we collect your information with the consent of your parents or guardians, we will only use or publicly disclose this information as permitted by law, with the explicit consent of your parents or guardians, or as necessary to protect your rights and interests. If your guardian does not agree with you using our services or providing information to us in accordance with this policy, please terminate your use of our services immediately and notify us in time so that we can take appropriate measures.
  3. 3. If you are the parent or guardian of a minor, if you have any questions about the processing of the personal information of the minor under your custody, please contact us in time.

Application and update of this policy

This policy applies to all AirPass products and services. We will update this policy in a timely manner when the following major changes occur:

  1. (1) Changes in our basic situation, such as changes in owners caused by mergers, acquisitions, and reorganizations;
  2. (2) Changes in the scope, purpose, and rules of collecting, storing, and using personal information;
  3. (3) The objects, scope, and purpose of providing personal information to external parties change;
  4. (4) Changes in the way you access and manage personal information;
  5. (5) Changes in data security capabilities and information security risks;
  6. (6) Changes in the channels and mechanisms for user inquiries and complaints, as well as external dispute resolution agencies and contact information;
  7. (7) Other changes that may have a significant impact on your personal information rights.

Since there are many users of AirPass products, if this policy is updated, we will notify you through APP push notifications, sending emails/short messages, or publishing announcements on the official AirPass website. In order for you to receive timely notifications, it is recommended that you notify us in time when your contact information is updated. If you continue to use the AirPass service after this policy update comes into effect, it means that you have fully read and understooduntie.