Demand Shifts Gears: Retail Steps Back, Institutions Step In

Upway is provided by Up Way China Bullion Limited (hereinafter referred to as "Upway Global"); a company incorporated under the laws of the Hong Kong Special Administrative Region. Its successors or assignees, together with the contracting party of this document (hereinafter referred to as the "Client"), enter into this agreement.:

Upway Global’s Personal Data Privacy Policy is designed to protect the rights of clients under the Personal Data (Privacy) Ordinance. While using client information to provide the best services, Upway Global pays high attention to the handling of client data. Upway Global strives to fully comply with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region and ensures that its employees adhere to strict legal standards of security and confidentiality.

(i) Circumstances Requiring Your Authorization to Collect and Use Your Data

i） i) Assisting You to Become Our User

ii） Upway China is committed to ensuring the website is secure and meets industry standards, and employs additional data protection tools, such as firewalls, authentication systems (passwords and personal identification numbers), and control mechanisms to prevent unauthorized access to and retrieval of data；

iii） Upway Global stores client personal data confidentially to prevent unauthorized use. Upway Global employees respect client privacy and will never disclose any information to unauthorized parties.；

iv） Clients may review and update their personal data held by Upway Global from time to time.；

v） Clients agree that Upway Global may disclose all client information (and other data) to regulatory authorities or other government bodies as required by law or regulations.；

vi） Clients agree that, in accordance with network payment system policies, Upway Global may disclose personal information to relevant institutions when clients deposit or withdraw funds via payment gateways, as proof of identity verification.；

vii） Upway Global may set and access Upway Global cookies on clients’ computers to help analyze and understand the effectiveness of marketing strategies. Upway Global and its employees may use cookies on Upway Global products and services to track client browsing on the Upway Global website. The collected and shared information is anonymized and cannot be individually identified.；

viii） Clients agree that, when Upway Global provides customer services, Upway Global may authorize companies not affiliated with Upway Global to use client personal data. These may include companies contracted to provide services on behalf of Upway Global, such as billing, mailing statements, or maintaining and developing data processing software. These authorized companies must keep client personal data confidential.

II. This Privacy Policy Helps You Understand the Following

1. How We Collect and Use Your Data

We collect and use your personal information for the purposes described in this Privacy Policy:
(1) Situations Requiring Your Consent to Collect and Use Personal Information

i）To help you become our user and provide membership services, certain information such as your phone number is considered sensitive. Collection of such data is required to comply with legal regulations, including online real-name verification. If you do not provide this information, you may be unable to use our services normally. If you only use basic browsing functions, registration and provision of this information are not required. 。
During user registration, providing additional personal information, such as full name, gender, date of birth, residence, avatar, or nickname, allows us to offer personalized services such as birthday privileges. However, not providing this information may limit personalized services but will not affect basic browsing of Upway Global platform services.
When you voluntarily close your account, we will promptly anonymize or delete your personal information in accordance with applicable laws and regulations. 。

ii）Information collected during service use is intended to provide pages and search results better suited to your needs, assess product compatibility, and identify account anomalies. We collect information on your usage of our services and associate these data, which include:
（1）Log Information: When you use Upway China platform services via website or client, we automatically collect detailed usage information for network logging, such as search queries, IP address, browser type, ISP, access date and time, and visited webpages. 。

(2) Device Permission Usage Description

To ensure the normal operation of the application (App) and provide related services, we require access to device permissions, including storage, device information, telephone, camera, photo album, and microphone. Before accessing these permissions, the application will inform you of the purpose and scope of their use. The permission usage is described as follows:

Storage Permission: Used to store files necessary for the normal operation of Upway China, including temporary files, log data, and media files saved during activities such as posting, changing profile pictures, or providing feedback. If you do not enable this permission, it will affect your ability to select images in scenarios such as posting, changing profile pictures, or providing feedback, but it will not affect the use of other services.

Microphone Permission: Used to support voice messaging functions in private messages. If you do not enable this permission, you will be unable to use voice functions, but it will not affect the use of other services.

Dial Telephone Permission: Used to enable direct calls to customer service or receiving callbacks from staff to improve customer service efficiency. If you do not enable this permission, it will affect our ability to promptly address your queries regarding usage, account opening, verification, or transactions via telephone, but it will not affect the use of other services.

MAC Address Permission: Used to remember your identity and analyze your usage of our services to optimize advertising delivery.

Location Permission: You may enable location permissions to view or access services based on your current location. If you do not enable this permission, you will not receive location-based notifications, but it will not affect the use of other services.

Clipboard Access Permission: Used to support data transfer, allowing you to copy or move document content to the clipboard for copying and pasting purposes. We may also access your referrer data via the clipboard to optimize advertising delivery.

Please note that individual device data or log data cannot identify a specific natural person. If we combine such non-personal data with other data to identify a specific natural person, or use it in conjunction with personal data, such non-personal data will be treated as personal data during the period of combined use. Unless we obtain your explicit consent or as otherwise provided by the Personal Data (Privacy) Ordinance, we will anonymize or de-identify such personal data.

III. How We Protect Personal Data

i) Data Security Technical Measures
We adopt industry-standard security measures, including the establishment of reasonable institutional protocols and advanced security technologies, to prevent unauthorized access, use, or modification of your personal data, and to avoid data damage or loss. In our network services, we employ various encryption technologies, such as Secure Sockets Layer (SSL) technology, to protect your personal data, and utilize data isolation techniques for segregation. During the use of personal data, such as for display or associative computation, we apply data desensitization techniques to enhance data security and implement strict data access controls and multi-factor authentication technologies to prevent unauthorized use of personal data.

ii) Other Security Measures to Protect Personal Data
We have established a data classification and grading system, data security management protocols, and data security development protocols to regulate the storage and use of personal data. We require all personnel with access to personal data to sign confidentiality agreements, and we implement monitoring and auditing mechanisms to ensure comprehensive security management of data, safeguarding the security of personal data.

iii）Upway China will take all reasonable measures to ensure that client personal data is securely stored and accessible only to authorized employees or companies providing services on behalf of Upway China. However, given the open and global nature of the Internet, Upway China cannot guarantee complete protection against third-party interference. Personal data accessed via other websites through Upway China is not covered by Upway China’s privacy policy.

IV. How We Use Personal Data

We will not provide, sell, rent, share, or trade your personal data with any unrelated third party unless we obtain your prior consent, or the third party and this application (including its affiliated companies) provide services to you jointly or individually, and such third parties will be prohibited from accessing personal data they were previously able to access once the service concludes. We may use the personal data collected during the provision of services for the following purposes:

i）i) Providing Services to You For example, we collect your identity data to assist you in completing the user registration process.。。

ii) Ensuring Service Security During service provision, we use your personal data for identity verification, customer service, security protection, archiving, and backup to ensure the security of the products and services we provide to you.

iii) Improving Services

iv) Sending Notifications

五、如何删除、注销个人账户

在您主动删除、注销账号时,可点击我的-更多-更多业务办理-投资者账号注销进行注销账号，在发起注销后会有15天的冻结期，如冻结期间再次登录账号该账号将会撤销本次的申请。

V. How to Delete or Deactivate Your Account

You may proactively delete or deactivate your account by navigating to: “My Page” > “More” > “Additional Services” > “Investor Account Deactivation.” Upon submission of a deactivation request, your account will enter a 15-day freeze period. If you log in to your account during this period, the deactivation request will be automatically canceled.

VII. Authorization Terms

To provide services such as advertising monitoring, our products may integrate third-party Software Development Kits (SDKs) or similar applications. Baidu Analytics SDK: Requires the collection of necessary fields such as your device’s International Mobile Equipment Identity (IMEI), iOS Advertising Identifier (IDFA), and mobile phone number.

Beijing Baidu Netcom Science and Technology Co., Ltd. is our online promotion service provider. To optimize advertising delivery, it collects your device attribute information, including: hardware model, operating system version, device configuration, unique device identifier (CUID), International Mobile Equipment Identity (IMEI), network device hardware address (MAC), advertising identifier (IDFA), and network connection type.。
Privacy Policy Link:： 《Baidu Analytics Privacy Policy》

Tencent Bugly SDK: For crash monitoring and analysis services, it collects your crash information and thread stack, ROM/RAM/SD card capacity, network status, language status, application information (package name, version, process name), and device information (IMEI and other device identifiers).
Privacy Policy Link:《Tencent Bugly User Agreement》

Tencent Bugly SDK: For crash monitoring and analysis services, it collects your crash information and thread stack, ROM/RAM/SD card capacity, network status, language status, application information (package name, version, process name), and device information (IMEI and other device identifiers).
Privacy Policy Link:《Tencent Bugly User Agreement》

To safeguard your information security, we have entered into strict data security confidentiality agreements with third-party SDK service providers, requiring them to strictly comply with our data privacy and security requirements. Unless we obtain your explicit consent, we will not share your other personal data with them.

VIII. Revisions to This Policy

We may revise this Privacy Policy from time to time. In the event of changes to the terms, we will notify you of the updated Privacy Policy through notifications or other means during version updates and specify the effective date. Please carefully review the revised Privacy Policy. Your continued use of our services indicates your agreement to the processing of your personal data in accordance with the revised Privacy Policy.

IX. How to Contact Us

i) If you have any questions, comments, or suggestions regarding this Privacy Policy or matters related to your personal data, please contact us through our online customer service system or by calling our customer service hotline.

ii）ii) Contact Address: 21/F, Tower 2, Nina Tower, 8 Yeung Uk Road, Tsuen Wan, New Territories, Hong Kong

iii）iii) Information Security Contact Phone: (+852) 23557866