Alipay Privacy Policy for Merchant Services
1 WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
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your basic personal details, including first and last name, date of birth, social security number and copies of your personal ID documents (e.g., passport); -
contact information, including your address, phone number, email, or other information that permits us to contact you; -
account information, such as details of the payment card used to complete a transaction with a merchant; -
company registration details, such as the basic personal details of the ultimate beneficiar(y)(ies) and account authentication details to complete “know your business” or “know your client” checks as required by local law; -
financial information and tax identification information; -
transaction details, such as the merchants you deal with, the amounts paid and the details of the products and/or services purchased; -
details of any marketing preferences you have given us (such as requests to receive or not receive certain types of marketing communication); -
copies of communications with or about you; and -
the following usage, device, and technical information:
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information about the device you use to interact with us, and -
information from your visits to our websites or mobile applications, collected automatically through tracking tools described in section 2 below. This information includes browser history, product engagement, length of visit/usage, page views, IP address or other unique identifiers, browser/platform type and version, internet service provider, operating system, referral source/exit pages, device operations, and other information regarding your interaction with our websites and our advertisements) session information, device ID, user agent, and IP address. We also embed tracking tools within the emails and other communications we send to you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on content within the message.
2 HOW WE OBTAIN YOUR PERSONAL INFORMATION
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merchants and other third parties who support the ability to make payments and conduct transactions through Alipay Services or otherwise; -
Alipay Affiliates; -
suppliers providing services on our behalf (such as vendors that provide hosting services, assist in sending emails, provide technical assistance and security, perform research and analysis for us, or provide marketing and advertising services); -
banks and other payment institutions that we cooperate with to provide you with the Alipay Services; and -
publicly available sources, such as public registers and social media.
3 HOW WE USE YOUR PERSONAL INFORMATION
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verifying your identity, including during account creation and payment password reset processes; -
verifying your eligibility as a User of Alipay Services; -
processing, maintaining and managing your registration as a User; -
providing you with Alipay Services and related User services, including enabling and conducting transactions, customizing your user experience, enabling the receipt of balance top-ups, financing proceeds and third-party payments, facilitating the settlement of payment for goods and services and providing other fund settlement services, handling foreign exchange conversions, charge-backs, sending notices about transactions, and responding to your queries, feedback, claims or disputes; -
contacting you in relation to our provision of Alipay Services, contacting you in connection with any communication preferences or requests you have expressed, asking you for feedback about Alipay Services or other related products and services, collecting feedback from you and your staff about our products and services and using such feedback to improve our business and/or customize products and services; -
serving you advertising and sending you information about products and services, including for promotional and marketing purposes; -
assessing, detecting, investigating, preventing or remediating fraud, data breaches or other potentially prohibited or illegal activities and otherwise protecting the integrity of our platform and safety and security of our staff and that of our suppliers and counterparties; -
managing our risk, performing creditworthiness and solvency checks on Users, or detecting, investigating, preventing or remediating violations of your agreements with us or any of our applicable policies, industry standards, guidelines, laws and regulations; -
making disclosures as may be required by any rules, law or regulation, regulatory authorities, government officials, card association or other payment network. Such disclosures may also be made pursuant to any subpoena, court order or other legal process or requirement applicable to us or any Affiliates (including “know your customer” , anti-money laundering, counter-terrorist financing reporting, tax requirements or other commercial disputes); -
making disclosures to competent regulators to prevent any harm or financial loss, to report suspected illegal activity or to establish, exercise, or defend claims or potential claims on behalf of ourselves or our Affiliates; -
improving and optimizing the Alipay Services; -
managing our business including to protect Users, prevent harm, fraud or theft to ourselves or others, maintain the security of our products, and protect our rights or property and those of others; -
to comply with law, regulation, codes of conduct and other good practice and conduct requirements; and -
in any other ways for which we provide notice at the time of collection.
4 WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
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our Affiliates; -
merchants that provide you with products, services and other offerings on or through Alipay Services; -
any agent, contractor, vendor, or service provider acting as subcontractor on behalf and upon our instruction to help us in providing Alipay Services. We set out a list of such agents, contractors, vendors, and service providers here . We engage the foregoing to help us with fraud prevention, anti-money laundering checks, credit checking, bill collection, data entry, database management, promotions, marketing, customer service, technology services, products and services alerts and payment extension services or to provide trade financing services; -
banks, card associations, payment networks or acquiring institutions; -
organisations involved in processing of payments and conducting transactions through Alipay Services; -
law enforcement agencies, insurers, government and regulatory authorities or any other organizations to which we, or any of our Affiliates or service providers, is under an obligation to make disclosure under the requirements of any applicable law, regulation, code of conduct or good practice or conduct requirement or commercial arrangement; -
individuals and entities involved in any merger, acquisition, corporate reorganization, financing, or similar transaction with us, including in the event of the sale of all or part of our assets; and -
our own and others’ professional advisors (e.g., lawyers, accountants, auditors, and trustees).
5 HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?
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the various regulatory requirements that we are subject to; -
whether a legal claim could be brought against us for which your personal information may be relevant; -
the necessity of your personal information to provide the Alipay Services, -
the type, nature, and sensitivity of your personal information being processed; and -
the legal basis for processing your personal information – e.g., consent or legitimate interests or otherwise.
6 WHAT IS OUR LEGAL BASIS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION?
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when the processing is necessary for the performance of the Agreement(s) or other contracts to which you are a party or to take pre-contractual steps at your request to receive the Alipay Services. -
w hen the processing is necessary to comply with our obligations under law and regulation . -
w hen the processing is necessary for the following legitimate interests:
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to operate, market and improve our business and minimise any disruption to the Alipay Services that we may offer to you; -
to ensure the security of the Alipay Services and to protect us, our staff and other Users from fraud or other criminal or similar conduct; -
to comply with codes of conduct, codes of practice and similar good conduct principles which do not have the force of law in the countries in which we operate, but are prudent for Alipay Group to apply; -
to make our communications with you more relevant and personalised to you, and to make your experience of our products and services efficient and effective; -
as the Alipay Group has infrastructures outside of the European Economic Area (including ( in China, Singapore and the United States), and the Alipay Services potentially involve Alipay providing services in any jurisdiction where you make purchases, to comply with our obligations under the laws and regulations from countries outside the European Union or to reply to any official request from public or judicial authorities in such countries, at all times in compliance with both the laws and regulations of the European Union or the European Union Member States (as applicable) and the legal requirements under local law.
However, in cases in which we wish to use your personal information for our legitimate interests, we carefully consider the position and do not proceed if we think your interests or fundamental rights and freedoms relating to your personal information would be prejudiced. Examples of matters we consider include how we use your personal information responsibly (for instance, security measures we put in place to protect it, such as access controls).
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Because you have given your consent. At times we may ask for your consent to allow us to use your personal information for one or more purposes. See the section Your rights with respect to your personal information for information about the rights that you have if we process your information on the basis of your consent.
7 INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
8 YOUR CHOICES AND PRIVACY RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION
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You can control cookies and tracking tools. You can disable or block non-essential cookies on your computer or mobile device. In some jurisdictions, we also provide specific tools on our websites and apps to help do that. Where that is not the case, please consult your browser’s documentation instructions for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, certain aspects of our websites and the Alipay Services may not function properly or as intended. Since these selections are specific to the browser and device you are using, please note that you will need to make these selections for each device and each browser you use to access our website and the Alipay Services. -
You can opt-out of email marketing and certain other communications. You may manage your receipt of marketing communications by clicking on the "Unsubscribe" link located on the bottom of any Alipay marketing email and/or following the instructions found on any page to which the link may take you. Please note that you cannot opt out of receiving administrative, support, or transactional emails.
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ask us about the processing of your personal information and access it, including by asking us to provide you with a copy of your personal information . -
request the correction and/or updating of your personal information; -
request the deletion of your personal information; -
request the restriction of the processing of your personal information, or object to that processing; -
withdraw your consent to the processing of your personal information (where we process your personal information based on your consent); -
request receipt or transmission to another organisation, in a machine-readable form, of the personal information that you have provided to us where we are using your personal information based on consent or performance of a contract; and -
complain to the relevant supervisory authority.
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Access/Right to Know: You may ask for: (i) a portable copy of the specific pieces of your personal information that we have collected; (ii) a list of categories of personal information (and sensitive personal information) we have collected about you; (iii) a list of categories of sources from which such information was collected; (iv) a list of categories of information that we sold or disclosed for a business purpose about you; (v) a list of categories of third parties to whom the information was sold or disclosed for a business purpose; and/or (vi) the business or commercial purpose for collecting and selling your information. -
Deletion: You may request that we delete the personal information we have collected about you, subject to certain exceptions. -
Do not Sell or Share my Personal Information for Behavioral Advertising: We do not “sell” or “share” your personal information as defined under applicable law. -
Correct or Update Your Personal Information: You have the right to request that we correct, update, or modify the personal information we maintain about you. -
Limit the Use and Sharing of Your Sensitive Personal Information: In relation to any sensitive personal information identified in section 1 above, you can request that we limit our use and sharing of such information to those uses which are necessary to perform the Alipay Services or as otherwise allowed by relevant data protection laws.
9 ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES
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Depending on our interactions with you, we may collect, use, and disclose for our business and commercial purposes the following categories of personal information set forth in the CCPA and CPRA: identifiers; payment and customer records information; commercial information; internet or other electronic network activity information; and sensitive personal information. See section 1 above for more details. -
We collect and use the above categories of personal information for the business and commercial purposes described in section 3 of this Privacy Notice. -
We collect these categories of personal information from the sources described in section 2 of this Privacy Notice. -
We may disclose each of these categories of personal information to the categories of third parties as described in section 4 of this Privacy Notice. -
We do not “sell” or “share” your personal information .
10 HOW DO WE PROCESS PERSONAL INFORMATION ABOUT CHILDREN?
11 THIRD PARTY SERVICES AND SITES
12 CHANGES TO THIS PRIVACY NOTICE
13 CONTACT US
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the European Economic Area or Switzerland: Alipay (Europe) Limited S.A., Privacy Office, 11-13, 9, rue du Laboratoire, L-1911 Luxembourg ; or -
the United States: AUS Merchant Services, Inc., Privacy Office, 525 Almanor Avenue, Suite 100, Sunnyvale, CA 94085. -
any other part of the world: Alipay Singapore E-Commerce Private Limited, Privacy Office, 51 Bras Basah Road, #04-08 Lazada One, Singapore 189554 .