PRIVACY POLICY

The Company places paramount importance on the protection of user privacy and will make every effort to ensure the security of personal data for customers and prepaid cardholders ("Cardholders") while maintaining and treating such data confidentially.

1. Collection of Personal Data from Cardholders.

In order to provide services and/or products to Cardholders, the Company will collect personal data of Cardholders, including (but not limited to):

a. Name;

b. Gender;

c. Age;

d. Date of Birth;

e. Nationality;

f. Personal identification documents (including ID card/passport/driving license number and copies);

g. Photographs;

h. Videos and imagery;

i.Bank account information (including bank name, account holder's name, and bank account number);

j. Contact information (including telephone number, email address, residential address, and location address).

The Company may need to verify the originals of personal data, collect copies of personal data, and provide information from the Cardholders for the following matters:

a. Applying for or purchasing products and/or services provided by or through the Company;

b. Establishing, utilizing, or maintaining products and/or services provided by or through the Company.

Cardholders can choose whether to disclose to the Company; failure to provide the relevant information may result in the Cardholders being unable to establish, use, or maintain the services and/or products provided by the Company. The Company will be unable to establish, maintain, or provide products and services to the Cardholder.

When Cardholders conduct transactions through the Company, the Company will also collect the Cardholders' information.

2. Use of Cardholder Information

The primary purposes of personal data (but not limited to) are:

a. To approve or process the Cardholder's application for products and services;

b. To regulate or manage the services or products that the Cardholder has purchased or applied for;

c. To establish, provide, continue, manage, and optimize products and services;

d. To investigate complaints and transactions;

e. To communicate with the Cardholder, providing updates or important news;

f. Market research;

g. Research analysis and statistics;

h. Promotion of products or services;

i. Risk assessment and management;

j. For identity verification in crime prevention, investigation, and prosecution, screening for government sanctions, and due diligence in any jurisdiction;

k. To comply with the Company's internal policies or procedures, any local or overseas applicable laws, regulations, self-regulatory guidelines, judgments or court orders, guidance from regulatory or law enforcement agencies, best practices, and reporting obligations under regulations;

l. To seek legal advice.

For the purposes mentioned above, the Cardholder's data may be provided to the Company, its contractors and agents, third-party data processors or service providers, regulatory bodies authorized or required by law, law enforcement agencies, courts, arbitration tribunals, or adjudicative bodies to achieve the above objectives.

Such data may be transferred, disclosed, processed, and stored in Hong Kong and/or outside Hong Kong to fulfill the purposes listed above. If a need arises to transfer such data, the Company will adopt appropriate protective measures.

For the privacy policy on direct marketing, please refer to Section 3 of this Privacy Policy.

3. Use of Cardholder Data for Direct Marketing Purposes

The Company intends to use the personal data of the Cardholder for direct marketing, but such usage requires the consent of the Cardholder (including an indication of no objection). Please note:

a. Without the consent of the Cardholder, the Company will not transfer or disclose the Cardholder's personal data to any third party for direct marketing purposes;

b. The Company may occasionally transfer or disclose the Cardholder's name, contact information, product and service portfolio data, statistical data, transaction patterns, and behavior to the Company's offices in Hong Kong and/or overseas for direct marketing of services and/or products related to the Company;

c. Services and/or products for direct marketing include but are not limited to: the latest information, events, and promotional offers concerning the Company's existing and/or upcoming prepaid card and other digital currency services and/or products;

d. For the said direct marketing, the Company may commission third-party data processors or service providers (including but not limited to data companies, telecommunications companies, and information technology companies) to execute on its behalf;

Should the Cardholder explicitly decline, the Company will not send promotional materials to the Cardholder. If at any time the Cardholder does not wish for the Company to use their personal data for the above direct marketing purposes, or if they have any inquiries about the Company's use of their personal data, they may contact the Company at any time (by sending an email to: info@ucash.com.hk). When making such requests or inquiries, the Cardholder should provide clear details of their personal data. Generally, the Company can respond or complete the relevant opt-out procedures for promotional messages within 14 working days after receiving the Cardholder's notification.

4. Retention of Cardholder's Personal Data and Data Security Measures

The personal data of the cardholder will only be retained for the period specified by relevant laws or the company's internal guidelines.

The company is committed to keeping the personal data provided by cardholders confidential to protect the interests of cardholders. Only authorized personnel or third-party data processors or service providers commissioned by the company can access or process such data.

When the company stores, uses, and/or transmits cardholder's personal data, sufficient protective measures are in place to prevent unauthorized and/or accidental access, disclosure, alteration, and/or destruction. While the company adopts all reasonable and feasible procedures and security measures to protect the cardholder's personal data, there is no absolutely secure method for transmitting and storing data online. Cardholders should be aware that the internet is not a secure means of communication. Sending and receiving information via the internet carries risks, including risks of intrusion and interference. If the cardholder's personal data is transmitted over the internet, the company does not assume responsibility for its confidentiality, security, and integrity. The company cannot guarantee the security of any personal data provided by cardholders online. Unless it can be proven that the company was indeed negligent, it will not assume any responsibility or obligation.

Regarding data security measures, cardholders must cooperate with the company and rigorously implement:

a. Cardholders should ensure that UCASH account information (including login accounts, expiration dates, security codes, login passwords, transaction passwords, and security questions/answers) is not leaked. Cardholders should ensure that they do not intentionally or unintentionally share, provide, or allow unauthorized individuals to access or use this information. Do not let others know the UCASH details and do not allow others to access or use such information;

b. Cardholders should maintain strict confidentiality to protect UCASH account information. Do not write down such information;

c. When cardholders choose a password, they should not use easily guessable combinations, such as birthdates, phone numbers, or any easily guessable sequence;

d. If cardholders believe that UCASH information has been disclosed to a third party, lost, or stolen, they have the responsibility to notify the company immediately.

5. Access and Correction of Personal Data

Cardholders can contact the company's customer service department or log in to the company's website (www.uash.com.hk) to access the personal information held by our company for him/her. The company reserves the right to charge the cardholder a reasonable fee for processing any request to access or provide relevant data.

To ensure the accuracy of the personal data held by the company, if there are any changes to the cardholder's personal data, please notify the company as soon as possible.

6. Amendments to This Privacy Policy

The company regularly reviews and updates this privacy policy. Any revisions, updates, or corrections to this privacy policy will be published on the company's website and will take effect immediately. Cardholders should periodically pay attention to any revisions or updates to this privacy policy sent by the company. This privacy policy was last updated on September 30, 2023.

7. Other matters

The company's website may from time to time contain links to other websites. This privacy policy applies only to this website. If you access other websites through these links, you should read the privacy policies of those websites.

This privacy policy statement does not affect the rights and obligations under the terms of any product or service provided by the company.