Wintranx Privacy Policy

This Privacy Policy applies to products and services provided by Wintranx (“we”, “us” and “our”).
Wintranx attaches great importance to the privacy and protection of personal information of users (hereinafter referred to as "you"). When you use our products and/or services, we may collect and use your related information based on laws and regulations, or based on your need to use Wintranx services, or in order to provide you with quality services and continuously optimize user experience. Wintranx Privacy Policy (the "Privacy Policy") describes how Wintranx collects, uses, stores and shares such information when you use our products and/or services, and how we provide you with the means to manage and protect such information. This Privacy Policy has the same legal effect as the agreement entered into between you and Wintranx. 
Wintranx is not responsible for the privacy practices of other linked sites. This policy will help you understand the following:

I. Information collection

(I) How to collect information
Your personal information is collected by us either directly (for example, when you use our website, register for our products or services, enter into our promotional events, or when you interact with us by contacting us for enquiries or providing feedback). You are under no obligation to provide the personal information when we seek to directly collect it from you. However, if you do not provide us with necessary personal information, i.e. certain information marked as mandatory or with an asterisk on the relevant forms, we may not be able to process your submission, provide you with our services or respond to your queries.

(2)For what purposes are personal information processed
We may process your personal information in the following situations pursuant to applicable laws, such as:
(a) to create customer profiles, maintain customer records and to communicate with you (including providing you with updates on changes to products and services), fulfill your requests and respond to your queries or feedback, addressing or investigating any complaints, claims or disputes;
(b) to send you important notices or personalized messages in relation to your use of our products and services;
(c) to use your necessary personal information to administer the operation of our website, to allow you to use the services and functions of our website, to process and manage your transactions, to conduct website maintenance, to solve problems, and to continually improve your Website experience and provide you with services and products in accordance with the terms and conditions that govern our relationship with you;
(d) to identify and send you marketing materials, news and information which we think will be of interest to you such as our latest promotional offers and upcoming products and services;
(e) to conduct screening, due diligence checks and verify your identity for the purposes of providing our products or services as may be required under applicable laws, regulations or directives;
(f) to detect, investigate and prevent fraud and other illegal activities;
(g) to use your personal information for purposes associated with our legal or regulatory rights and obligations, including financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes and for the purposes of seeking professional advice, including legal advice; and
(h) to keep internal records, decision making and facilitate internal purposes such as data analysis, and research to improve our products and services, service security and quality, and to maintain opt-in and opt-out lists.

(3) what information we may collect
(a) When you register for Wintranx services, we need to verify your identity in accordance with applicable laws, regulations and regulatory provisions as well as our compliance and risk control requirements. You shall provide us with your basic identity information. Include name, household registration, nationality, sex, occupation, address, date of birth, age, contact number, contact email, type, number, validity period, and photocopy of valid ID, among which basic id information contains your sensitive personal information.If you do not provide the information, you will not be able to use Wintranx's services.
(b)When you use Wintranx's acquiring service, you shall provide us with your transaction information.
(c)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 identifier or other auxiliary information); Order information (basic order information, commodity information, logistics information); ,Contract information (contract/invoice etc.).
(d)In order to ensure the security and stability of the services provided to you and prevent transaction and capital risks, we need to record the information sent to us by your computer, mobile phone or other access devices or applications in accordance with applicable laws, regulations and regulatory provisions as well as our own compliance and risk control requirements. This information includes, but is not limited to, network IP addresses, device information (including device brand, model, name, address, identifier, identifier, and environment and application information of other devices), your browser version information, and geo-location information.
(e) information you provide to us when you contact our support team to help us answer your queries. We also gather information about any suggestions or complaints you make in order to help address your queries and improve the products and services we offer you;
(f)Your email and marketing preferences, including interest and market listing assignments, marketing objections, preferred languages, website and application data;With your authorization and consent, we will send you SMS or email notifications of marketing activities through your mobile phone number and/or email address.If you do not agree with our collection and use of the above information, please send an email to our customer service email (marketing@wintranx.com) to request us not to send marketing activity notification. If you do not agree to collect and use the above information, it will not affect us to continue to provide you with Wintranx services.
(g) We strictly comply with relevant laws and regulations, and will not collect or store your bank card's track information or chip information, verification code, validity period, password and other sensitive information.

(4) exceptions with your authorization and consent
In accordance with the laws and regulations and regulatory requirements of the jurisdiction and other relevant countries, regions and areas, the collection of your personal information does not require your authorization and consent under the following circumstances:
(a) Related to the national security and national defense security of relevant countries, regions and fields;
(b) Related to the performance of statutory duties or obligations prescribed by applicable laws and regulations and regulatory authorities;
(c)Those related to public security, public health or major public interests;
(d) those related to criminal investigation, prosecution, trial and execution of judgment;
(e)For the purpose of safeguarding the life, health, property safety and other important legal rights and interests of the subject of personal information or other individuals, but it is difficult to obtain the consent of the individual;
(f)The collected personal information is disclosed to the public by you;
(g) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
(h)Necessary for signing and performing the contract according to your requirements;
(i)Necessary for maintaining the safe and stable operation of the provided products or services, such as discovering and disposing of faults of the products or services, identifying and disposing of fraud or theft in the products or services;
(j)Necessary for the public interest and legitimate news reporting;
(k) Other circumstances stipulated by applicable laws and regulations.

2.How do we use cookies and similar technologies
If you visit our website through computers or mobile devices, we may identify you through small data files, such as cookies or Flash cookies, in order to ensure the normal operation of the website and make it easier for you to access the website. Or other local storage (collectively, "cookies") provided by a browser (or associated application) that typically contains identifiers, site names, and some numbers, characters, or data.Cookies enable us to remember your actions and preferences (such as login, language, font size, and other display preferences) for a period of time, so you don't have to re-log in when you go from page to page and return to the site.You may modify your cookie acceptance level or refuse our cookies if your browser or browser add-ons allow it.However, if you do so, it may affect your safe access to our Site and use of the services we provide under certain circumstances and may require you to change user Settings each time you visit our site.
In addition to cookies, we also use web beacons, pixel tags, ETag and other similar technologies on our websites.For example, we may send you an email that contains an address link to content on our website. If you click on this link, we will track this click to help us understand your product or service preferences so that we can proactively improve our customer service experience.

3.How do we store or protect information
(1)We have taken reasonable and feasible security measures in line with industry standards to protect your personal information and prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information.For example, data (such as bank card information) exchanged between your browser and server is encrypted by the Secure Socket Layer (SSL) protocol.We will use encryption technology to improve the security of personal information;We will use trusted protection mechanisms to protect personal information from malicious attacks;We will deploy access control mechanisms to ensure that only authorised personnel have access to personal information;And we will conduct security and privacy protection training courses to enhance staff's 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 have obtained the certification qualification of PCI DSS international data security standard.
(3)We have formulated emergency plans for personal information security, and regularly organized relevant internal personnel to conduct emergency response training and drills, for the purpose of mastering their job responsibilities as well as emergency handling strategies and procedures. When unfortunately a personal information security incident occurs, we will pursuant to the applicable laws, timely inform you of the basic situation of the security incident and the possible impact, the disposal measures we have taken or will take, the action we recommend you to take independently to prevent and reduce the risk, and remedial measures for you, etc. We will timely inform you of the latest status of the incident in the form of in-site letters, and emails/messages, etc. If it is impractical to inform the subject of personal information one by one, we will take a reasonable and effective way to make announcement. Meanwhile, we will also take the initiative to report the disposal of personal information security incidents in accordance with the requirements of regulatory authorities. 

4.Retention period of information
We retain your personal information only for a period of time necessary and reasonable for the purpose of providing our services to you or as long as required by laws, regulations and regulations.
When you stop using our services, we will immediately stop collecting and using your information, unless otherwise stipulated by laws, regulations or regulatory authorities.

5.How do we use information
In order to comply with national laws, regulations and regulatory requirements, as well as to provide and improve the quality of our services to you, or to protect the security of your account and funds, we will use your information under the following circumstances:
(1)To achieve the purposes described in the "Information Collection" section of this Privacy Policy;
(2) in order to ensure the stability and service security, to protect your account and capital security, the performance of anti-money laundering and other legal obligations 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 authorities according to applicable laws and regulations or regulatory requirements;
(4) invite you to participate in our service related customer, product research;
(5) we will take desensitization, delabeling and other ways to conduct comprehensive statistics, analysis and processing of your information, so as to provide you with more accurate, personalized, smooth and convenient services, or help us evaluate, improve or design services and operation activities;

6. How we provide your information externally

(1) Sharing
1. We will keep your information strictly confidential according to the provisions of this Privacy Policy.Except as otherwise stipulated by applicable laws, regulations and regulatory authorities, we share your information with third parties only in the following circumstances:
(a) For the purpose of enabling you to complete the transaction, provide your counterparty with transaction identification information and relevant payment information, and your counterparty may view part of your registration information during the payment process or after the payment is successful;
(b) With your express prior consent or authorization, we will share your information with relevant Wintranx partner to the extent permitted by applicable laws and regulations and in accordance with your authorization;
(c) in accordance with applicable laws and regulations, the requirements of legal procedures, mandatory administrative or judicial requirements;
(d) To the extent permitted by laws and regulations, it is necessary to protect Wintranx or Wintranx affiliates or Wintranx partner, you or other Wintranx users or the public interest, property or safety from damage;
(e) Certain products or services may be provided by third parties in cooperation with Wintranx or jointly provided by us and third parties in cooperation with Wintranx. Therefore, only by sharing your information can we realize the core functions of our products and/or services or provide products or services you require;
(f) If you choose to participate in marketing and promotion activities jointly carried out by us and relevant third parties in cooperation with Wintranx, we may share the information generated in the process of such activities and necessary to complete the activities so that the third party in cooperation with Wintranx can provide you with services, rights and benefits in a timely manner. 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;
(g) Handle disputes or disputes between you and others as required;
(h) in accordance with relevant agreements signed with you or as required by other legal documents;
(i) Use based on academic research;
(j) Use based on social and public interests that comply with applicable laws and regulations.

2. In accordance with the foregoing provisions of this Article, we may provide your personal information to:
(a)Our affiliated companies;
(b) Service providers and partners we engage in order to provide our products and services to you, such as payment processing companies, acquirers, bank partners, payment system operators to process your transactions;
(c) Our Service providers and partners to carry out due diligence identity verification, transactions monitoring, fraud-screening and for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues, protecting against harm to the rights, property or safety of our users or the public, or as necessary to serve our legitimate business interests;
(d)Our advertising and analytics providers and with related service providers, in order to improve our business services;
(e)Any subsidiaries, joint ventures, or other companies under common control;
(f) Any other third party you authorized;

3. For companies, organizations and individuals with whom we share personal Information, we will evaluate the legality, legitimacy and necessity of collecting information from such third parties, and require them to strictly abide by relevant laws, regulations and regulatory requirements by signing agreements with them, and take measures to protect your personal information.
(2) Entrusted handling.In order to improve the efficiency of information processing, reduce the cost of information processing, or improve the accuracy of information processing, we may entrust competent Wintranx affiliates or other professional organizations to process information on our behalf.We will sign a written agreement with the entrusted enterprise or institution, requiring the entrusted company to abide by strict confidentiality obligations and take effective protection measures to prohibit them from using this information for purposes not authorized by you.
(3) Transfer.We will not transfer your personal information to any company, organization or individual except for the following circumstances:
(a) Obtain your explicit written consent or authorization in advance;
(b)In accordance with applicable laws and regulations, requirements of legal procedures, mandatory administrative or judicial requirements;
(c) Provided in accordance with relevant agreements or other legal documents signed with you;
(d)When it comes to merger, acquisition, asset transfer or similar transaction, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy; otherwise, we will require the company or organization to seek your authorization and consent again.

(4) 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:
(a) According to your requirements, disclose your designated personal information in a manner that you have expressly agreed to;
(b) If it is necessary to provide your personal information as required by applicable laws and regulations, compulsory administrative law enforcement or judicial requirements, we may publicly disclose your personal information based on the type and disclosure method of personal information required.Subject to applicable laws and regulations, when we receive such disclosure requests, we will require such authorities or departments to issue corresponding legal documents, such as subpoenas or letters of investigation.We firmly believe that we should be as transparent as the law allows about the information we are asked to provide.We carefully review requests for public disclosure to ensure that they are based on legal basis and are limited to data that law enforcement authorities are legally entitled to obtain for specific investigative purposes.To the extent permitted by applicable laws and regulations, the documents we disclose are protected by encryption keys.
(5) According to relevant laws and regulations, we may share, transfer or publicly disclose your personal Information in accordance with the law without your consent under the following circumstances:
(a)Related to the performance of obligations stipulated by laws and regulations and regulatory authorities;
(b)Those directly related to national security and national defense security;
(c)Those directly related to public security, public health or major public interests;
(d) those directly related to criminal investigation, prosecution, trial and execution of judgment;
(e)For the protection of your or other personal life, property and other important legal rights and interests, but it is difficult to get your consent;
(f)Personal information disclosed to the public by yourself;
(g)Personal information collected from lawfully publicly disclosed information.

7. Your Rights

(1)Query your personal information
You can query your personal information or contact us by sending us an email to marketing@wintranx.com,  except for the exceptions stipulated by laws and regulations..

(2) Correct your personal information
When you find that there is an error in the personal information we process about you, you have the right to request that we make a correction. You may request correction of personal information to us by sending an email to marketing@wintranx.com.

(3) Delete your personal information
You may send an e-mail to marketing@wintranx.com to request us to delete your personal information in the following circumstances, unless otherwise provided by laws and regulations:
(a) If we process personal information without your consent or in violation of our agreement with you;
(b) If we process personal information in violation of laws and regulations;
(c) If you no longer use our services, you cancel your account, or the retention period of your personal information has expired;
(d) The purposes for which we process your personal information have been achieved, cannot be achieved or are no longer necessary to achieve the purposes for which we processed;
(e) You withdraw your authorized consent to us.

(4) Withdraw all or part of your consent
(a) You can cancel your account and withdraw all of our authorization to continue collecting your personal information.
(b) You may request to change the scope of authorized consent by sending an email to marketing@wintranx.com.
(c) Please understand that each business function requires certain necessary personal information to be completed. Once you withdraw your consent or authorization to relevant necessary personal information, we cannot continue to provide you with the services corresponding to the consent or authorization to be withdrawn, and will no longer process your relevant personal information. However, your decision to withdraw your consent or authorization will not affect the prior processing of personal information based on your authorization.

(5) Respond to your request
If you have any questions, suggestions, comments or complaints, please contact us by sending email to marketing@wintranx.com.In order to ensure security, we will process the information after the necessary authentication is approved. Normally, we will give a reply within 15 working days.
Under the following circumstances, we will not be able to respond to your request in accordance with the laws, regulations and/or regulatory requirements of our jurisdiction and other relevant countries, regions and areas:
(a)Those directly related to the security and national defense security of relevant countries, regions and fields;
(b) Those directly related to public security, public health or major public interests;
(c) those directly related to criminal investigation, prosecution, trial and execution of judgment;
(d)There is sufficient evidence that you have subjective malice or abuse of rights;
(e)Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
(f) involving commercial secrets.

8.Protection of children's personal information
Our products, websites and services are intended for adults.We strictly comply with relevant laws and regulations of relevant countries, and only collect and process the personal information of children (" children "in this Privacy Policy refers to minors under the age of 14) on the basis of obtaining authorization and consent from parents or other guardians.If we find that we have collected personal information about children without first obtaining verifiable parental or other guardian consent, we will try to remove the data as soon as possible.In the case of personal information collected by a child with the consent of a parent or guardian, we will only use or publicly disclose such information when permitted by law, with the express consent of a parent or other guardian, or when it is necessary to protect the child.

9. How your personal information is transferred globally
In view of the fact that we provide Wintranx services to you worldwide, to the extent permitted by relevant laws and regulations, your personal information may need to be transmitted to Wintranx affiliates or third parties cooperating with Wintranx on the basis of obtaining your authorization and consent.On the premise of meeting relevant provisions and requirements of laws and regulations, we will use our commercially reasonable best efforts to ensure that your information transfer and disclosure is in accordance with the requirements of local laws and regulations. At the same time, We will 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.), ensure that your personal information is handled securely and comply with the protection convention of this privacy policy.

10.Policy updates
Our Privacy Policy is subject to changes in product updates as well as legal and regulatory requirements. When there is a significant change to this Policy, we will timely notify you by pop-up reminder, message push, email notification or announcement on our official website. The circumstances that constitute significant changes include but are not limited to:
(a) Significant changes occur in the scope and mode of services we provide;
(b) Significant changes occur in our operating entities, organizational structure, ownership structure and other aspects;
(c) The main object for which your personal information is provided, transferred or publicly disclosed changes;
(d) Your rights to participate in personal information processing and the way in which you exercise them change significantly;
(e) Our responsible department responsible for personal information security and its contact information, complaint channels have changed;
(f) Other changes that may materially affect your personal information rights and interests.
You may find this Policy by clicking Privacy Policy on our official website . If you have any questions, comments or suggestions regarding this Privacy Policy or your personal information, please contact us by sending an email to marketing@wintranx.com. 

11.Your Consent
Your use of Wintranx means that you accept this Privacy Policy. You agree that the personal information given by you and collected by us from time to time may be used and disclosed for the foregoing purposes, and to such persons as may be appropriate in accordance with this Privacy Policy.