Privacy Policy
Dear Users,
BenPay (the “Platform”, “we”, “us”, or “our”) respects and protects
the privacy of users (“you”, “your” or “Users”). The Platform will
collect, use, disclose and process your personal information, in
accordance with this privacy policy (the “Policy”) when you:
(a) access or use our website and mobile applications (the
“Applications”) and services;
(b) provide us with your personal information, regardless of the
medium through which such personal information is provided.
The Platform recommends that you shall carefully read and understand
the entire Policy before using the Applications. Significant
information including the disclaimers is in bold herein. Definitions
shall have the same meanings as ascribed to them by the BenPay Terms
of Use. In the event of any inconsistent definitions or terminologies
in the BenPay Terms of Use and the Policy, the Policy shall prevail.
By providing us with your personal information, you are deemed to have
consented to our collection, use, disclosure (including transfer) and
processing of your personal information in accordance with the Policy.
Please DO NOT provide any personal information to us if you do not
accept the Policy. The Platform reserves the right to update the
Policy online from time to time, without notice to you, and the
revised Policy will come into effect and supersede the older versions
once posted on our Applications. The revised Policy will apply, with
immediate effect, to the personal information that you had provided to
us previously. In particular, if you do not accept the revised Policy,
please immediately stop your use of the Applications. Your continued
use of our Applications will be regarded as your acceptance of the
revised policy.
1.
Information We Collect
When you access or use the Platform or the Applications and related
services, we will collect, process and use the following
information:
We will collect your personal information, including but not limited
to your mobile device information, operation records, transaction
records and wallet addresses.
In order to satisfy your needs or requests for specific services, we
may also collect the personal information including but not limited to
your social media account, mobile phone number, e-mail address
etc.
You understand that your wallet password, private key on the
Applications are not stored or synchronized on the Platform’ servers.
The Platform does not offer the service to recover your wallet
password, private key.
We may also request you to provide us with additional personal
information to enable your use of specific functions of the
Applications. Your refusal to provide us with such requested personal
information will be considered as your choice not to use the
particular function of the Applications.
We allow the integration of other services and applications with the
services provided by the Platform. If you use the integrated
third-party service, we may receive and process data from that third
party (and share certain data with that third party, including the
data mentioned above) to provide the integrated service.
The Policy does not apply to third parties’ processing of information
resulting from your use of any third-party integrated services through
our services. When using integrated applications and services on the
Platform, please review the relevant third parties’ legal documents,
including but not limited to their service agreements and privacy
policies.
To the extent permitted by applicable laws and regulations, the
Platform may collect and use the personal information under the
following circumstances without your prior consent or
authorization:
(1) information related to national security and national
defence;
(2) information related to public security, public health, or
significant public interests;
(3) information related to criminal investigation, prosecution, trial
and enforcement;
(4) personal Information in the public domain;
(5) personal information collected from legally and publicly
disclosed information, such as legitimate news reports, and government
information disclosure;
(6) personal Information necessary to maintain the security and
compliance of the services, such as to detect or to fix the
malfunction of products and services; and/or
(7) other circumstances permitted by laws and regulations.
We collect information in the following manners:
(1) when you provide us with your personal information for whatever
reasons;
(2) when you authorize us to obtain your personal information from a
third party;
(3) when you register for a user account on our Applications;
(4) when you contact us or interact with our employees through
various communication channels, e.g., through social media platforms,
messenger platforms, face-to-face meetings, telephone calls, e-mails,
fax and letters;
(5) when you transact with us, contact us or request that we contact
you;
(6) when you request to be included in an e-mail or our mailing list;
and/or
(7) when we copy all or part of your transaction records on the
blockchain. However, you should refer to the blockchain system for
your latest transaction records.
Our Applications may contain certain technologies that collect
personal information in the manners described in the Policy or the
applicable terms and conditions.
Your provision of personal information to us is voluntary and you may
withdraw your consent at any time. However, if you choose not to
provide us with the personal information we require, it may not be
possible for you to use the Applications or for us to contact you, or
provide products or services which you need from us.
In certain circumstances, you may also provide us with the personal
information of persons other than yourself. If you do so, you warrant
and represent to us that you have obtained his/her consent to our
collection of his/her personal information and to your disclosure of
his/her personal information to us. You agree to indemnify and hold us
harmless from and against any and all claims by such individuals
relating to our collection, use and disclosure of such personal
information in accordance with the terms of the Policy.
You shall ensure that all personal information you provide to us is
true, accurate and complete. In the event of any changes to your
personal information, you shall inform us of such changes as soon as
practicable.
2 How We Use Your Information
We collect, use or disclose your personal information for one or more
of the following purposes:
(1) to provide you with the products and/or services that you request
for;
(2) to manage your relationship with us;
(3) to facilitate your use of our Applications;
(4) to associate you with your wallet by the unique serial number of
your mobile device;
(5) to push important notifications to you, such as Applications
update, changes to Terms of Use and the Policy;
(6) to assist with your enquiries, feedback, complaints and requests
by using the wallet address and the mobile device information provided
by you;
(7) to notify you of our products, services, programmes and
events;
(8) to resolve any disputes, investigate any complaint, claim or
dispute or any actual or suspected illegal or unlawful conduct;
(9) to conduct our internal audit, data analysis and research;
(10) to conduct user behaviour tracking by tracking the Users’ use of
the Applications;
(11) to comply with our obligations in accordance with laws and
regulations and to cooperate with regulatory authorities;
(12) to comply with international laws and regulations for securities
and to counter money-laundering or financing of terrorism;
(13) to perform our obligations and comply with contractual terms and
conditions;
(14) any other reasonable purposes related to the aforesaid.
With your consent, we will use your personal information from time to
time for other purposes, such as to inform you of the latest events,
offers and promotions from our strategic partners or affiliates.
3 How You Control Your Own Information
You have the following control over your personal information in the
Applications:
You may import your other wallets into the Applications through
synchronization of wallets and you may export your wallets from the
Applications to other tokens management wallets. The Applications will
display the information of the imported wallets.
You understand that you may change types of tokens, transfer and
receive tokens using the “Assets” column.
You understand that you may freely perform the following operations
in the “Profile” column in the Applications:
(1) in the “Settings” column, you may choose not to switch on certain
functions;
(2) in the “Feedback” column, you may submit any questions or
suggestions to us at any time. We will be glad to communicate with you
to improve our services.
You understand that you may choose not to switch on “Payment without
Password”, which means you refuse to call your biological
identification and authentication when conducting transactions.
You understand that due to the open source nature of blockchain, your
transaction records are public and transparent in the whole
blockchain.
Our Applications may contain links to other websites, applications or
smart contracts that are not owned, operated, developed or maintained
by us. These links are provided for your convenience only. The Policy
only applies to our Applications. When using third-party services, you
understand that the BenPay Terms of Use and BenPay Privacy Policy will
no longer apply. You are recommended to carefully review the privacy
policies and terms of service of such third parties.
You are entitled to ask us to update, revise, and delete your
personal information and/or withdraw any consent provided to us. If
you wish to withdraw any consent you have given us at any time, or to
update, revise, delete or access to your personal information held by
us, or if you do not accept any amendment to the Policy, please
contact us at: support@benfen.org
We may charge you a fee for responding to your request for access to
your personal information held by us, or for information about the
manners in which we have (or may have) used your personal information
in the one-year period preceding your request. If a fee is to be
charged, we will inform you of the amount in advance and respond to
your request after payment is received. We will endeavour to respond
to your request within thirty (30) days, and if that is not possible,
we will inform you of the time by which we will respond to you.
We need your personal information under various circumstances to
provide you with the products or services that you require. If you do
not provide us with the required personal information, or if you
withdraw your consent to our use and/or disclosure of your personal
information for these purposes, it may not be possible for us to
continue providing you with the products and services that you
require.
4 Information We may Share or Transfer
We will keep your personal information for business and legal
purposes.
We do not sell, trade or otherwise transfer your personal information
to third parties without your consent.
If you have consented to our disclosure of your personal information
to our strategic business partners and associates, we may disclose
your personal information to them. They will use your personal
information only for the purposes you have consented to.
You agree that we may disclose or share your personal information
with third parties such as:
(1) service providers and data processors working on our behalf and
providing services to us, such as conducting know-your-clients checks,
accounting, data processing or management services, website hosting,
maintenance and operation services, e-mail message services, analysis
services, handling of payment transactions, marketing etc;
(2) our consultants and professional advisors (such as accountants,
lawyers, and auditors).
If we need to transmit your personal information to any country for
the purposes set out above, we shall obtain your prior consent and
ensure that the recipient of the personal information protects your
personal information to the same level as we have committed to
protecting your personal information. Where these countries or
territories do not have personal data protection laws that are
comparable to the laws applicable to our relationship with you, we
will enter into legally enforceable agreements with the
recipients.
The Platform will not share with or transmit your personal
information to any third party without your prior consent, except for
the following circumstances:
(1) the collected personal information is publicized by
yourself;
(2) the personal information is collected from public information
which was legally disclosed, such as legitimate news reports,
government information disclosure;
(3) to disclose or implement the Policy in accordance with the
applicable laws, regulations, legal proceedings, or requirements by
administrative or judiciary authorities to protect our or others’
rights, property or safety;
(4) in the case of mergers and acquisitions, if transfer of personal
information is involved, the Platform may require the recipients of
the personal information to be continuously bound by the Policy.
5 Automatic Data Collection Technologies
We use automatic data collection technologies on our Applications.
Examples of such technologies include:
(1) Cookies (or browser cookies). Cookies are small text files which
are set by a website or application operator so that your browser or
device may be recognised. We may use cookies on our Applications to
store and track information such as the number of users and their
frequency of use, profiles of users and their online preferences.
Cookies do not capture information which would identify you, but the
information collected may be used to assist us in analysing the use of
our Applications and to improve your online experience with us. You
can disable the cookies by changing the setting on your browser.
However, this may affect the functionality of the Applications.
(2) Web analytics. Web analytics is the term given to a method for
collecting and assessing the behaviour of visitors to websites and
mobile applications. This includes the analysis of traffic patterns,
e.g., determining the frequency of visits to certain parts of a
website or mobile application, or identifying the information and
services which the visitors are most interested in. The web analytics
services on our Applications are provided by third-party service
providers.
6 How We Protect Your Information
If the Platform ceases operation, the Platform will stop collecting
your personal information and take steps to delete or anonymize your
personal information held by us within a reasonable period.
To protect your personal information, the Platform may adopt data
security techniques, improve internal compliance levels, increase
security training for our staff, and set security authority for access
to relevant data to protect your personal information.
We will send you messages about information security in the
“Notifications” column and update materials concerning the use of
wallets and information protection in the “Support” column on our
Applications for your reference.
2.
Data Retention
We will only retain your personal information for as long as is
necessary for the purposes described in the Policy, unless a longer
retention period is required (such as to comply with legal obligations
or requirements, or to establish, exercise or defend legal claims, or
for legitimate business purposes, or as required by law).
8 Protection for the Minors
The following special provisions apply to minors who are under the
age of 18 years:
Minors shall not use services by the Platform without the guidance
from their parents or guardians.
Parents and guardians of the minors shall provide guidance to the
minors on using the Applications after they read the Policy, BenPay
Terms of Use and our other relevant rules.
The Platform will ensure the confidentiality and security of minors’
personal information in accordance with the applicable laws and
regulations.
9 Disclaimer
You acknowledge that after you use third-party services, the Policy
will no longer apply to the collection, use, disclosure and
transmission of your personal information by these third parties. The
Platform is unable to guarantee that these third parties will
implement reasonable security measures to protect your personal
information.
You are solely responsible for your use of third-party services and
agree that you will not hold the Platform liable for any damages or
injuries incurred as a result of the collection, use, disclosure and
transmission of your personal information by these third
parties.
You acknowledge and accept that, to the maximum extent permitted by
applicable laws, the Platform will adopt measures as reasonable as
possible to protect your personal information under current techniques
on an “as is”, “as available” and “with all faults” basis, to avoid
the disclosure, tampering or damage of information. Since the Platform
transmits data wirelessly, the Platform makes no guarantee on the
privacy and security of wireless internet data transmission.
Despite implementation of the technical and security measures
described in the Policy, the Platform is unable to guarantee the
absolute security of data transmission on the Internet. Therefore, the
Platform does not provide any guarantee on the security of personal
information provided by Users to the Platform, and the Platform does
not assume any liability for incidents that occur due to unauthorized
access to Users' personal information.
10 Miscellaneous
The Policy shall become effective on January 1, 2022. The Platform
reserves the right to amend the Policy from time to time and at any
time. The Platform notifies the Users of the changes to the Policy by
updating and publishing the effective date of the new version. You
understand that sometimes the Platform will issue a notice to inform
you of the revisions to the Policy, but this is not an obligation of
the Platform. You should regularly check the Policy and pay attention
to its revisions. If you do not agree with the revised content, you
should stop accessing the Platform immediately. When the updated
version of the Policy is released, your continued access to the
Platform shows and indicates that you consent to the updated content
of the Policy and you agree to abide by the updated version of the
Policy.
In relation to any issues not covered in the Policy, you shall comply
with the announcements and relevant rules as updated by the Platform
from time to time.