PROC Privacy Policy

Overview

Dear PROC user (hereinafter referred to as "You"), Hong Kong PRO C Limited (Address: Room 17, 11/F, Tuen Mun Central Square, 22 Hoi Wing Road, Tuen Mun, New Territories, Hong Kong; hereinafter referred to as "We") values user privacy and recognizes the importance of personal information to you. We will protect your personal information and privacy security in accordance with legal and regulatory provisions. We are committed to maintaining your trust in us, adhering to the following principles to protect your personal information: the principle of balancing rights and responsibilities, the principle of purpose specification, the principle of choice and consent, the principle of minimum necessity, the principle of ensuring security, the principle of subject participation, and the principle of openness and transparency. At the same time, we promise to adopt corresponding security protection measures in line with mature industry standards to protect your personal information.

Please carefully read and understand the "PROC Privacy Policy" before using our products or services.

We will endeavor to explain and inform you using clear and understandable language, and for terms in this policy that may have a significant relationship with your legitimate interests, we will use bold font to draw your attention. We strongly recommend that you carefully read and fully understand all contents of this policy before registering an account or using our services, and make appropriate choices independently. If you do not agree with the content of this policy, we will be unable to provide you with complete products and services, and you should immediately stop using PROC APP products and related services. If you start using our products or services, it will be deemed that you have fully and completely read and understood all contents of this policy, and agree that we collect, use, store, and externally provide your personal information in accordance with the terms of this policy, so that you can enjoy high-quality and convenient services, while better protecting your account and fund security.

You can read the corresponding chapters according to the index below to further understand the specific provisions of this policy:

I. How We Collect and Use Your Personal Information

II. How We Store and Protect Your Personal Information

III. How We Externally Provide Information

IV. How You Access and Manage Your Information

V. How We Protect Minors' Information

VI. How This Policy is Updated

VII. Scope of Application

VIII. How to Contact Us

I. How We Collect and Use Your Personal Information

Personal information refers to information recorded electronically or by other means that can identify a specific natural person alone or in combination with other information, or reflect the activities of a specific natural person, including **name, date of birth, identity document number, personal biometric information, address, communication contact details, communication records and content, account passwords, property information, credit information, travel trajectories, accommodation information, health and physiological information, transaction information, etc. Personal sensitive information refers to personal information that, if leaked, illegally provided, or misused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment, etc., including identity document numbers, personal biometric information, bank account numbers, communication records and content, property information, credit information, travel trajectories, accommodation information, health and physiological information, transaction information, personal information of minors under 14 years old (inclusive), etc. In the process of you using PROC APP and related services, we need to collect some of your information to provide you with services, improve our service quality, safeguard your account and fund security, and comply with national laws, regulations, and regulatory requirements.

(I) What Personal Information We Collect from You

1. Situations Where You Need to Authorize Us to Collect and Use Your Personal Information

(1) To Fulfill Anti-Money Laundering Obligations and Conduct Real-Name System Management in Accordance with Laws, Regulations, and Regulatory Provisions

When you register a PROC account, you need to provide your mobile phone number and verification code. During registration, we also need to obtain your location permission to ensure the compliance and security of your subsequent use of payment collection services. When using PROC services, you need to provide your mobile phone number as the account login name. If you do not provide the aforementioned information, you may not be able to complete registration or use PROC services normally. According to relevant laws and regulations, PROC will conduct multiple cross-verifications of your basic identity information. To protect your interests and enhance account security, we recommend that you complete real-name verification (bank card verification, document verification),

1) If you are a small or micro merchant, you need to provide your name, ID card number, front and back photos of your ID card, and bank card number;

2) If you are an enterprise merchant, you need to provide the enterprise name, unified social credit code, name of the enterprise's legal representative, ID card number and front/back photos of the ID card, enterprise bank account name, account number, and bank of deposit.

If you do not provide the aforementioned information, you may not be able to use some services that require multiple cross-verifications as per regulatory requirements, but this will not affect your use of other services we provide. At the same time, to verify the accuracy and completeness of the information you provide, we will cross-check with state organs, financial institutions, and enterprises and institutions that legally retain your aforementioned information.

To ensure the authenticity of your identity, you may need to provide color photocopies or photos of your valid identity documents as well as your real-time facial recognition photos/data/video/audio for our verification and retention. If you do not provide the aforementioned color photocopies, photos and your real-time facial recognition photos/data/video/audio or do not agree to our retention, you may not be able to use some services related to regulatory requirements, but this will not affect your use of other services we provide.

When you perform facial recognition in our APP/client to verify your identity, we will collect your facial information, encrypt and store it in the system backend database, for retention during the business process, and to assist in identifying and verifying customer identity. For certain local biometric authentication functions of some phone brands or models, such as facial recognition, the information is processed by the phone terminal provider, and we do not retain information related to your use of the phone terminal's functions. Matters not covered regarding facial recognition shall be handled in accordance with the relevant provisions of the "Facial Recognition Service Agreement" and this Privacy Policy.

(2) Merchant Service Activation

To ensure your normal use of the payment services provided by PROC, we need to obtain your GPS location information, mobile phone camera usage permission, and external storage read/write permission during the process of activating merchant services for you; as well as collect your:

1) Personal information, including mobile phone number, name, ID card number, front and back photos of ID card, facial liveness detection photo, email (optional)

2) Bank account information for payment collection, including bank of deposit, account name, account number;

3) Store operation information, including store name, store address, storefront photo or business premises photo (optional). The specific information to be collected will be implemented according to your merchant type, legal and regulatory provisions, regulatory agency requirements, and PROC's relevant policies.

(3) Card Payment Collection

When you use our card payment collection service, to ensure transaction security and compliance, we need to obtain your GPS location information, IP address, device identification information, and mobile phone storage permission.

(4) Bill Inquiry

To provide you with daily transaction and fund management services, and facilitate your real-time query of transaction information, we record and display your transaction-related information (including transaction amount, handling fee, transaction type, transaction time).

(5) Credit Card Authentication

To ensure transaction security and verify your identity, you need to provide your credit card number, name, and ID card number during credit card authentication. We will verify the aforementioned information with the issuing bank. If you do not provide the aforementioned information, you may not be able to use the current service, but this will not affect your use of other services we provide.

(6) Password Retrieval

To protect your account and fund security, when you need to retrieve your password, you need to provide your registered mobile phone number, name, and dynamic verification code to verify your identity.

1) To retrieve the login password, you need to provide your registered mobile phone number and dynamic verification code.

2) To reset the login password, you need to provide your registered mobile phone number and dynamic verification code.

3) To reset the payment password, you need to provide your registered mobile phone number and dynamic verification code.

(7) Security Management

To ensure the safe and stable operation of the services provided to you and prevent transaction and fund risks, we need to record the categories and methods of PROC services you use, as well as device model, IP address, device software version information, device identification code, region, and other log information related to PROC services. If you do not agree to our recording the aforementioned information, you may not be able to complete risk control verification.

The information collected and used by various product functions is listed item by item as follows:

(1) Registration

Collection Frequency : Collected only when triggered by business need

Personal Information Type : Basic Personal Information

Personal Information Fields : Mobile phone number, location information

Purpose/Scenario Description : To register a user on the PROC homepage

(2) Account Password Login

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Basic Personal Information, Common Device Information

Personal Information Fields: Mobile phone number

Purpose/Scenario Description: To verify account and password for login on the PROC login homepage

(3) Real-Name Authentication

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Basic Personal Information, Identity Information

Personal Information Fields: Name, ID card number, front/back photos of ID card, facial recognition photo, bank card number, mobile phone number

Purpose/Scenario Description: Precondition for users to activate VCC cards and conduct transactions, requires personal identity verification and risk control

(4) Set/Modify/Forgot Login Password

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Basic Personal Information, Identity Information

Personal Information Fields: Mobile phone number, dynamic verification code

Purpose/Scenario Description: To set/modify personal login password after verifying relevant user information

(5) Set/Modify/Forgot Payment Password

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Basic Personal Information, Identity Information

Personal Information Fields: Mobile phone number, dynamic verification code, name, ID card number

Purpose/Scenario Description: To set/modify personal payment password after verifying relevant user information

(6) Add Bank Card

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Basic Personal Information, Identity Information

Personal Information Fields: Name, bank card number, card expiration date

Purpose/Scenario Description: To bind user's personal bank card after verifying relevant user information

(7) Account Balance

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Basic Personal Information, Personal Property Information

Personal Information Fields: Account balance

Purpose/Scenario Description: To view account balance

(8) Bill Inquiry

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Personal Property Information

Personal Information Fields: Transaction amount, handling fee, transaction type, transaction time, transaction result, transaction location information

Purpose/Scenario Description: To view user's bill details

(9) Card Transaction

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Basic Personal Information, Identity Information

Personal Information Fields: Device identifier, location information, transaction amount, transaction card number, transaction card CVV, user handwritten signature

Purpose/Scenario Description: For user card transactions

(10) Account Details

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Basic Personal Information

Personal Information Fields: Personal avatar, nickname, mobile phone number, name, ID card number

Purpose/Scenario Description: To maintain user's basic information

(11) Card Wallet

Collection Frequency: Collected only when triggered by business need

Personal Information Type: Basic Personal Information

Personal Information Fields: Bank card number, bank name, card type

Purpose/Scenario Description: To display cards bound by the user on the homepage

2. Information Generated During Your Use of Services

When you use the services we provide, our system may automatically collect the following information through SDKs or other means:

(1) Log Information

To provide you with a more relaxed access experience, technical information that may be automatically collected by the system when you use our services, including: Device or software information, such as your hardware device model, software version information you use, your operating system and version, your IP address, your location, mobile network information, device manufacturer, device model, IMEI information, MAC address, list of installed software, running applications;

(2) Location Information

To protect your account security as much as possible, provide you with a more secure access experience, and, in accordance with regulatory requirements, to prevent transaction and fund risks, when you enable the device location function and use our location-based services, we collect information about your location, such as when you use our services through a mobile device with positioning capabilities, we collect your geographic location information through GPS or WiFi/4G and other network types. Each time you use PROC APP, we will collect the aforementioned information. You can stop our collection of your geographic location information at any time by turning off the location function. If you do not provide location information, you may not be able to use the current service, but this will not affect your use of other services we provide.

(3) Device Information

To ensure the normal operation of basic functional services and the stability and security of the system when you use our services, and to prevent your personal information from being obtained illegally, we need to collect your device information (device model, device Mac address, operating system and software version, device status, network status, advertising identifier IDFA information, IDFV information, UUID, AndroidID, IMSI), log information, IP address, and location information to assess your account risk. We also collect your device information for analyzing PROC system issues, statistical traffic, and investigating potential risks, and to address issues when you choose to send us exception information. If you do not provide the aforementioned information, we will not be able to protect your service and account security during your use of PROC services.

The relevant situation of SDKs involved in user information usage by PROC APP is listed item by item as follows:

(1) Tencent Document Recognition SDK

SDK Type: Tool

SDK Description: Used for identifying front/back of ID cards, bank cards, passports, automatically scanning identity information on documents

SDK Usage Business Scenario: Real-name authentication, personal information verification

SDK Required User Information Fields: Device model, IMEI number, system version, phone model

Purpose/Reason for Use: Provides automatic ID card recognition function, security verification during real-name authentication

SDK Provider Information: Tencent Cloud Computing (Beijing) Co., Ltd. 95716

(2) Tencent Facial Recognition SDK

SDK Type: Tool

SDK Description: Collects user facial images/videos to determine if it is a live human, verifies the authenticity of user identity

SDK Usage Business Scenario: Real-name authentication

SDK Required User Information Fields: Device model, IMEI number, system version, phone model

Purpose/Reason for Use: Provides facial recognition as a security authentication method or means

SDK Provider Information: Tencent Cloud Computing (Beijing) Co., Ltd. 95716

(3) WeChat Open Platform

SDK Type: Social, Transaction

SDK Description: WeChat sharing, payment, and other functions

SDK Usage Business Scenario: WeChat sharing, WeChat payment

SDK Required User Information Fields: Device model, IMEI number, system version, phone model

Purpose/Reason for Use: To share interface to WeChat client via WeChat, complete payments via WeChat channel

SDK Provider Information: Tencent Technology (Shenzhen) Co., Ltd. +86-755-86013388

(4) Alipay Open Platform

SDK Type: Transaction

SDK Description: Payment function

SDK Usage Business Scenario: Alipay payment

SDK Required User Information Fields: Device model, IMEI number, system version, phone model

Purpose/Reason for Use: To complete payments via Alipay channel using Alipay

SDK Provider Information: Alipay (China) Network Technology Co., Ltd. 4007585858

(5) Image_picker/Image_cropper/Flutter_image_compress

SDK Type: Tool

SDK Description: Image selection

SDK Usage Business Scenario: Loading/cropping/compressing images

SDK Required User Information Fields: Device model

Purpose/Reason for Use: To display/crop/compress images selected/loaded by user from album

(6) Dio

SDK Type: Tool

SDK Description: Lightweight network framework

SDK Usage Business Scenario: Network requests

SDK Required User Information Fields: Used for network requests

Purpose/Reason for Use: For handling network requests

(7) talker_flutter

SDK Type: Logging Tool

SDK Description: Open-source logging tool class

SDK Usage Business Scenario: Local log code output during development

SDK Required User Information Fields: Device type, system version, log information

Purpose/Reason for Use: For saving local log output

(8) Hive/shared_preferences

SDK Type: Database Tool

SDK Description: Local data persistence

SDK Usage Business Scenario: Basic business data storage

SDK Required User Information Fields: Device type

Purpose/Reason for Use: Local log data storage

(9) UUID

SDK Type: Tool Library

SDK Description: Used to generate a unique device identifier

SDK Usage Business Scenario: To record some related information about the device

SDK Required User Information Fields: AndroidID, DEVICEID, IMEI, IMSI

Purpose/Reason for Use: To generate a unique identifier for each device

(10) device_info_plus

SDK Type: Tool Library

SDK Description: Obtains device-related information

SDK Usage Business Scenario: To record some related information about the device

SDK Required User Information Fields: AndroidID, DEVICEID, DeviceType, OSVersion

Purpose/Reason for Use: To obtain device information needed for other scenarios in one go, preventing repeated/multiple acquisitions of device information

(11) geolocator/geocoding

SDK Type: Tool Library

SDK Description: Latitude/Longitude acquisition, reverse geocoding

SDK Usage Business Scenario: To obtain user location information during registration and transactions

SDK Required User Information Fields: Latitude/longitude information, location information

Purpose/Reason for Use: To obtain user location information during registration and transactions for risk control

If you do not agree to the aforementioned third-party service providers collecting the aforementioned information, you may not be able to obtain the corresponding service, but this will not affect your normal use of other functions or services. If you agree to the aforementioned related third-party service providers collecting the aforementioned information and an information leak occurs, the relevant third-party service provider shall bear corresponding legal responsibility.

3. Situations Where You Can Choose Whether to Authorize Us to Collect and Use Your Personal Information

(1) To make your payment collection transactions more secure, you can authorize us to access your location information when using location for the first time. We will assess your location based on the location information to ensure the security of your payment collection transactions. If you do not provide this personal information, you may not be able to use the aforementioned services, but this will not affect your use of other services we provide.

(2) To enable you to conveniently use card scanning and facial recognition services, you can authorize us to access your camera device when using the camera for the first time. If you do not provide this personal information, you may not be able to use the aforementioned services, but this will not affect your use of other services we provide.

(3) To enable you to conveniently upload card photos, you can authorize us to access your mobile phone album when using the album for the first time. If you do not provide this personal information, you may not be able to use the aforementioned services, but this will not affect your use of other services we provide.

(4) To enable you to timely receive your message notifications, you can authorize us to allow notification permissions when installing PROC. If you do not provide this personal information, you may not be able to use the aforementioned services, but this will not affect your use of other services we provide.

The access permissions to your device that may be enabled by various related business functions are listed item by item as follows:

(1) Read/Write Mobile Phone Storage Permission

Application Scenario: Business involving reading/writing file system, e.g., application information data file caching, reading

Usage Frequency: Obtained when related business is triggered

(2) Access Location Information Permission

Application Scenario: User registration, transactions

Usage Frequency: Obtained when related business is triggered

(3) Access Mobile Phone Album Permission

Application Scenario: Modifying avatar, uploading ID documents, uploading bank card

Usage Frequency: Obtained when related business is triggered

(4) Use Camera Device Permission

Application Scenario: Facial recognition, uploading ID photos for real-name authentication, binding bank card recognition

Usage Frequency: Obtained when related business is triggered

(5) Read NFC Permission

Application Scenario: Transaction

Usage Frequency: Obtained when related business is triggered

(6) Microphone Permission

Application Scenario: Third-party SDK, when using IM chat

Usage Frequency: Obtained when related business is triggered

(7) Read Phone State and Identity Information

Application Scenario: Recording login device, completing security risk control verification

Usage Frequency: Obtained when related business is triggered

(8) Location Permission

Application Scenario: Used for registration, transactions, and other functions requiring location information to ensure transaction security

Usage Frequency: Obtained when related business is triggered

4. You are fully aware that, in accordance with relevant laws and regulations, under the following circumstances, we may legally collect and use your personal information without obtaining your prior consent:

(1) Related to fulfilling obligations stipulated by national laws and regulations and relevant provisions of industry regulatory authorities;

(2) Directly related to national security and national defense security;

(3) Directly related to public security, public health, and significant public interests;

(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments, etc.;

(5) For the purpose of safeguarding the life, property, and other significant legitimate rights and interests of you or other individuals, but where it is difficult to obtain the consent of the person;

(6) Where the personal information involved is disclosed to the public by you on your own initiative;

(7) Necessary for the conclusion and performance of a contract according to your requirements;

(8) Collected from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels;

(9) Necessary for maintaining the safe and stable operation of the provided products or services, such as discovering and handling faults of the products or services;

(10) Other circumstances stipulated by laws and regulations.

5. Others

Please understand that the services we provide to you are constantly updated and developed. If you choose to use other services not covered in the aforementioned description, and we need to collect your information based on that service, we will separately explain to you the scope and purpose of information collection through page prompts, interactive processes, or agreement terms, and obtain your consent. We will use, store, externally provide, and protect your information in accordance with this policy and the corresponding user agreement terms; if you choose not to provide the aforementioned information, you may not be able to use a certain service or part of a service, but this will not affect your use of other services we provide.

(II) Rules for Using Your Personal Information

1. We will use the collected personal information in accordance with the terms of this Privacy Policy and to realize the functions of our products and/or services;

2. To ensure service stability and security, we will use your information for identity verification, security protection, fraud monitoring, preventing or prohibiting illegal activities, risk reduction, archiving, and backup purposes;

3. To report to relevant departments according to legal, regulatory, or supervisory requirements;

4. After collecting your personal information, we will process the data through technical means such as desensitization and de-identification. De-identified information cannot identify the subject. Please understand and agree that under such circumstances, we may conduct comprehensive statistics, analysis, and processing of your information in order to provide you with more accurate, personalized, smooth, and convenient services, or to help us evaluate, improve, or design services and operational activities;

5. Please note that all personal information you provide while using our products and/or services will be continuously authorized for our use during your use of our products and/or services, unless you delete it or refuse our collection through system settings. When you cancel your account, we will stop using and delete your personal information;

6. We may conduct statistics on the usage of our products and/or services and may share these statistical information with the public or third parties to demonstrate the overall usage trends of our products and/or services. However, this statistical information does not contain any of your identity identification information;

7. When we intend to use your personal information for purposes not specified in this policy, or use information collected for a specific purpose for other purposes, we will seek your consent again in accordance with the requirements of laws, regulations, and national standards, in the form of confirmation agreements, confirmation actions in specific scenarios, etc.

We may obtain and store your device's IP address, hardware ID, and the page locations you access.

II. How We Store and Protect Your Personal Information

1. To ensure your information security, after collecting your information, we will take various reasonably necessary measures to protect your information. For example, in the technology development environment, we only use de-identified information for statistical analysis; when providing external research reports, we will de-identify the information contained in the reports. We store de-identified information separately from information that can be used to re-identify individuals, ensuring that individuals are not re-identified in subsequent processing of the de-identified information.

2. We promise that our information security protection will reach leading industry security levels. To protect your information security, we are committed to using various security technologies and supporting management systems to minimize the risk of your information being leaked, damaged, misused, accessed without authorization, disclosed without authorization, or altered. For example: encrypted transmission through Secure Sockets Layer (SSL) software, encrypted storage of information, strictly restricted access to data centers. When transmitting and storing personal sensitive information (including personal biometric information), we will adopt security measures such as encryption, access control, and de-identification.

3. We have established a personal information protection responsibility department to conduct personal information security impact assessments regarding the collection, use, sharing, and entrusted processing of personal information. At the same time, we have established relevant internal control systems, adopting the principle of minimum necessary authorization for staff who may have access to your information; systematically monitoring staff's handling of your information, and continuously training staff on relevant laws, regulations, privacy and security standards, and strengthening awareness of security.

4. We have formulated a personal information security incident emergency response plan. In the unfortunate event of a personal information security incident, we will inform you in a timely manner in accordance with legal and regulatory requirements: the basic situation of the security incident and its possible impact, the measures we have taken or will take, suggestions for you to prevent and reduce risks independently, remedies for you, etc. We will promptly notify you of the incident-related situation through APP push notifications, emails/text messages, etc. When it is difficult to inform each individual information subject, 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 to regulatory authorities as required. If your legitimate rights and interests are damaged, we will bear corresponding legal responsibility.

5. Please be sure to keep your PROC account name, password, and other identity elements safe. When you use PROC APP, we identify your identity through your account name and password. Once you disclose the aforementioned information, you may suffer losses, which may have adverse consequences for you. If you find that your PROC account name and password may have been or have been disclosed for any reason, please contact us immediately so that we can take timely measures to avoid or reduce related losses. However, before we become aware of such situation and take action, we shall not be held responsible for this.

6. If you have any questions about our personal information protection, you can contact us through the contact methods specified in this policy.

7. After you terminate using the services we provide, we will stop collecting and using your information, unless otherwise stipulated by laws, regulations, or regulatory authorities.

III. How We Externally Provide Information

(I) Sharing

1. Business Sharing

We promise to keep your information strictly confidential. Unless otherwise stipulated by laws, regulations, and regulatory authorities, we will only share your information with third parties under the following circumstances. Third parties include our affiliated companies, cooperative financial institutions, and other partners. If sharing your information with a third party is necessary to provide services to you, we will assess the legality, legitimacy, and necessity of the third party's information collection. We will require the third party to take protective measures for your information and strictly comply with relevant laws, regulations, and supervisory requirements. Additionally, we will obtain your consent in accordance with the requirements of laws, regulations, and national standards, in the form of confirmation agreements, confirmation in specific scenarios, pop-up prompts, etc., or confirm that the third party has obtained your consent. With your prior explicit consent, we will share your information with third parties within the scope permitted by laws and regulations and not contrary to public order and good morals, in accordance with your authorization scope.

2. Other Cooperative Sharing

We may share your name, mobile phone number, ID card number, device model with partners and third parties to ensure the smooth completion of services provided to you. However, we will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and will only share the personal information necessary to provide the services. When sharing your privacy information with recipients, we will adopt security protection measures in line with industry standards, and our partners are not allowed to use the shared personal information for any other purposes. Our partners include the following types:

1. Suppliers providing technology and consulting services. We may share your name, mobile phone number, ID card number with third parties supporting our service provision. These entities include those providing us with infrastructure technical services, data processing services, telecommunications services, audit services, legal services, etc. However, we require these service providers to use your information only for the purpose of providing services to us and not for their own interests.

The situations in which we share your personal information with partners and third parties are listed item by item as follows:

(1) Real-Name Authentication

Type of User Information Shared: Personal Identity Information

User Information Fields Shared: Name, ID card number

Sharing Frequency: During initial real-name authentication

Name of Third-Party Cooperative Institution/Subsidiary Sharing Information: Compliant institutions accessed via interface mode, such as Tencent Cloud, etc.

Purpose/Use of Sharing Information: For personal identity verification and risk control judgment

(2) Bank Card Authentication

Type of User Information Shared: Personal Identity Information

User Information Fields Shared: Name, bank card number

Sharing Frequency: Shared once each time a bank card is bound

Name of Third-Party Cooperative Institution/Subsidiary Sharing Information: Compliant institutions accessed via interface mode, such as Tencent Cloud, etc.

Purpose/Use of Sharing Information: For personal identity verification and risk control judgment

(3) Facial Recognition

Type of User Information Shared: Basic Personal Information, Personal Identity Information

User Information Fields Shared: Name, ID card number, facial recognition photo

Sharing Frequency: During initial real-name authentication

Name of Third-Party Cooperative Institution/Subsidiary Sharing Information: Tencent Cloud, etc.

Purpose/Use of Sharing Information: For identity verification and risk control judgment

3. For companies, organizations, and individuals with whom we share personal information, we sign strict confidentiality agreements with them, requiring them to handle personal information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures. Regarding the use of personal sensitive data, we require third parties to adopt data desensitization and encryption technologies to better protect user data. It is recommended that you contact third parties to obtain detailed information about their privacy policies. If you find risks in web pages created by these third parties, applications developed by third parties, or products or services provided by them, it is recommended that you terminate related operations to protect your legitimate rights and interests.

4. To comply with laws, enforce or apply our terms of use and other agreements, or to protect the rights, property, or safety of us, you, or our other customers, such as to prevent illegal activities like fraud and reduce credit risks, we may exchange your personal information, service information, and activity information with regulatory agencies or organizations such as UnionPay and the People's Bank of China after obtaining your consent. However, this does not mean we will violate the commitments made in this policy to sell, rent, share, or otherwise disclose personal information for profit.

5. Complaint Handling

(I) When you complain about others or are complained about by others, to protect your and others' legitimate rights and interests, we may provide your name and valid ID number, contact information, and complaint-related content to consumer rights protection departments and regulatory authorities to promptly resolve complaint disputes, unless expressly prohibited by laws and regulations.

(II) Transfer We will not transfer your personal information to any company, organization, or individual, except in the following cases:

1. With your prior explicit consent or authorization;

2. As required by laws and regulations, legal procedures, or mandatory administrative or judicial requirements;

3. As provided in agreements signed with you (including electronically signed agreements and corresponding platform rules) or other legal documents;

4. In cases 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 the new holder of your personal information to continue to be bound by this policy. If the purpose of personal information use changes, we will require that company or organization to obtain your explicit consent again.

(III) Public Disclosure We will only publicly disclose your personal information under the following circumstances and while taking security protection measures in line with industry standards. Apart from this, in principle, we will not publicly disclose your information. If public disclosure is indeed necessary, we will inform you of the purpose of disclosure, the type of information to be disclosed, and any sensitive information that may be involved, and obtain your explicit consent.

1. According to your needs, disclose the personal information you specify in the disclosure method you explicitly agree to;

2. Under circumstances where it is necessary to provide your personal information as required by laws, regulations, mandatory administrative law enforcement, or judicial requirements, we may publicly disclose your personal information according to the required type of personal information and disclosure method.

(IV) Entrusted Processing To improve information processing efficiency, reduce information processing costs, or improve information processing accuracy, we may entrust capable affiliated parties or other professional institutions to process information on our behalf. We require entrusted companies to comply with strict confidentiality obligations and adopt effective confidentiality measures through written agreements, on-site audits, etc., prohibiting them from using this information for purposes not authorized by you. When the entrustment relationship is terminated, the entrusted company no longer retains personal information.

(V) In accordance with relevant laws, regulations, and national standards, under the following circumstances, we may legally share, transfer, or publicly disclose your personal information without obtaining your consent:

1. To fulfill obligations stipulated by laws and regulations or required by regulatory authorities;

2. Directly related to national security and national defense security;

3. Directly related to public security, public health, and significant public interests;

4. Directly related to criminal investigation, prosecution, trial, and execution of judgments, etc.;

5. For the purpose of safeguarding the life, property, and other significant legitimate rights and interests of you or other individuals, but where it is difficult to obtain your consent;

6. Personal information disclosed by you to the public on your own initiative;

7. Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure, and other channels.

IV. How You Access and Manage Your Information

We attach great importance to your attention to personal information and will do our utmost to protect your rights to access, correct, delete, and withdraw consent regarding your personal information, so that you have sufficient ability to protect your privacy and security. Your rights include:

(I) Accessing and Correcting Your Personal Information Unless otherwise stipulated by laws and regulations, you have the right to access the following your personal information at any time and correct part of the information at any time, specifically including:

(1) In "Me → Click on letter avatar" to enter "Settings - Nickname/Personal Information Details" to access/correct nickname, login mobile phone number;

(2) In "Me → Click on letter avatar" to enter "App Settings" to access/correct account login password, payment password;

(3) In "Card Details Page" to access bill information, including order type, order status, order time, transaction records (transaction amount, handling fee);

(II) Cancelling Your Account

You can apply to cancel your PROC account through "Settings → Account → Account Cancellation".

V. How We Protect Minors' Information

1. Our products and services are primarily provided to natural persons, legal persons, or other organizations with full capacity for civil rights and civil conduct, who can independently bear civil liability. Without the consent of parents or guardians, minors may not create their own user accounts. If you are a minor, you should read this policy under the guidance of your parent or guardian. Before submitting personal information, you should seek the consent and guidance of your parent or guardian. You and your parent or guardian must give your autonomous, specific, clear, and unambiguous consent for us to collect your personal information based on full knowledge. If the aforementioned conditions are not met, please immediately stop using our services and notify us to delete your personal information. For information collected with the consent of parents or guardians, we will only use or publicly disclose this information to the extent permitted by law, with the explicit consent of the parent or guardian, or as necessary to protect your rights. If your guardian does not agree for you to use our services or provide information to us in accordance with this policy, please immediately stop using our services and notify us promptly so that we can take corresponding measures.

2. If we discover that we have collected a minor's personal information without prior verifiable parental consent, we will try to delete the relevant data as soon as possible.

3. If you are a parent or guardian of a minor, when you have questions about the processing of the minor's information under your guardianship, please contact us.

VI. How This Policy is Updated

In order to provide you with better services and as our business develops, this policy will also be updated accordingly. However, without your explicit consent, we will not reduce the rights you are entitled to under this policy. When this policy undergoes major changes, we will notify you in a timely manner through pop-up reminders, message pushes, email notifications, etc. Major changes include but are not limited to:

(1) Changes in our basic situation, such as changes in ownership due to merger, acquisition, or reorganization;

(2) Changes in the scope, purpose, or rules for collecting, storing, or using personal information;

(3) Changes in the objects, scope, or purpose of externally providing personal information;

(4) Changes in the way you access and manage personal information;

(5) Changes in data security capabilities or information security risks;

(6) Changes in user inquiry and complaint channels and mechanisms, as well as external dispute resolution institutions and contact methods;

(7) Other changes that may have a significant impact on your personal information rights.

VII. Scope of Application

1. All services of PROC APP are subject to this policy, unless the relevant service has an independent privacy policy or there are special provisions in the corresponding user service agreement.

2. If you also use third-party products or services during your use of PROC APP services, as third-party products or services are not bound by this policy, we will strive to require these entities to take protective measures for your personal information. It is recommended that you contact them to obtain detailed information about their privacy policies, and carefully review and discern to make choices you deem appropriate. If you discover risks during your use of third-party products or services, please stop using them in a timely manner to safeguard your legitimate rights and interests.

VIII. How to Contact Us

If you have any questions about this policy, or any complaints or opinions regarding the processing of your personal information, please contact our person in charge of personal information protection at: 634430688@qq.com.After receiving your question, we will process the issue you reported after verifying your identity and reply to you within fifteen working days.