Privacy Policy
Effective date: [Sep] [15], 2020
Coibub Technology Limited (hereinafter referred to as "Webank Microfinance Company SMC LTD" or
"we") fully respect your privacy and will do our utmost to protect the security of your personal
information. In the process of providing you with products or services, we may collect and use your
personal information based on your consent or in accordance with the relevant provisions of applicable
laws and regulations. This Privacy Policy (hereinafter referred to as “Policy”) is aimed at assisting you to
understand how we collect, use, retain, share and transmit your personal information that you provide
to us when you are using Webank Microfinance Company SMC LTD, your rights regarding the personal
information provided to us, and how we safeguard your rights. This Policy applies to Webank
Microfinance Company SMC LTD that display or provide links to this Policy. In consideration of the many
products and services of Webank Microfinance Company SMC LTD, this Policy may not cover all
scenarios of collecting and using personal information. We may supplement it through the privacy policy
of specific products or services or by other means of notification provided during data collection. For
example, depending on the type of Webank Microfinance Company SMC LTD you use and the country
where you are located, the corresponding products or services may differ in how they collect and use
your personal information. If a specific product or service has a separate privacy policy, the separate
privacy policy will be used first and the content of the separate privacy policy will prevail. Any part not
covered by the separate privacy policy of the specific product or service shall be subject to the content
of this Privacy Policy.
Before using our products or services, providing your personal information to us or allowing us to collect
your personal information, please read this Policy carefully to understand our practices regarding your
personal information, and please access it frequently to understand the updates to this Policy. If you
have any questions, please let us know.
How We Collect and Use Your Personal Information
"Personal information" refers to all the data that can directly or indirectly identify or relate to a natural
person by reference to the natural person's identification, attributes, characteristics or other identities,
or through a combination of these identities. You may need to provide personal information when you
use Webank Microfinance Company SMC LTD. You are not required to provide your personal
information to Webank Microfinance Company SMC LTD, but in some cases, if you choose not to do so,
we will not be able to provide you with related products or services, nor will we be able to respond or
resolve the problems you've encountered. We will collect and use your personal information only for
the purposes described in this Policy. The following are some examples of personal information that we
collect about you:
1. Personal information we collect
1.1 Information you provide directly to us
In order to enable you to access our product functionalities and services, we may ask you to provide
necessary information when we provide products or services to you. For example:
(1)Account information. When you register for Webank Microfinance Company SMC LTD, such as
creating an APP account, participating in forum community interactions, etc., depending on the
functionalities of different products or services, you may need to provide: a phone number, name,
nickname, avatar, birthday, nationality, age, the city where you are located and other information; when
you need to log in to the relevant system more conveniently, such as using face recognition or
fingerprint unlocking for quick login, you may need to provide the corresponding facial or fingerprint
biometrics;
(2)Order information. When you purchase our or the third party’s products or services online or offline,
in order to ensure that the products or services can be provided to you in a timely and accurate manner,
we may ask you to provide information such as the recipient's name, phone number, zip code and
address;
(3)After-service information. When you need us to provide after-service or hope that we solve the
problems you encountered in using the products or services, you may need to provide information such
as your name, phone number, device information, residential address, problem descriptions in scenarios
such as filling out the warranty card / electronic warranty card or giving feedback on the problem;
(4)Other information you provide to us. For example, when you participate in our activities such as a
sweepstakes, prize quiz and fan trial research, you may need to provide a personal nickname, avatar,
name, phone number and other information according to the needs of specific scenarios.
1.2 Information we obtain during your use of our products or services
During your use of Webank Microfinance Company SMC LTD, as needed to provide you with products or
services, with your authorization or consent, we will collect the necessary information, including:
(1)Device information. Given that certain services will be for a particular type of device, in the process of
activating a business and using the device, we may collect device-related information such as the device
name, device model, region and language settings, device identification code, device hardware
information and status, user habits, IP address, Mac address, operating system version, PLMN, Android
system version, network operator equipment, etc.
(2)Log information. When you use our products or services, we may collect certain information and
store it in log files. For example, service access time, access frequencies, usage time, temporary
historical messages, standard system logs, event information (errors, crashes, restarts, upgrades), etc.
(3)Location information. When you need to use certain location-based services, such as using navigation
software, viewing the weather conditions in a geographic location, retrieving your phone's location,
sharing your geographic location with others, etc., with your consent, we may collect and process
approximate or precise information about the actual location of the equipment you use. For example:
latitude and longitude information, country or area code, city code, community identifier, navigation
route, operator identifier, etc. Surely, unless you provide consent or in order to comply with a legal
requirement by the relevant country or region, we will not continue to collect your location information
to identify your whereabouts. You have the right to turn off location service permissions for related apps
directly on your mobile device.
(4)cookie information. Our websites, interactive applications, products and advertisements may use
technologies such as cookies, pixel tags and web beacons to collect and store your relevant personal
information.
(5)Other personal information. Different types of products or services may obtain different types of
personal information about you. For example: transactional SMS information collection. Due to the large
number of products or services we provide to you, we cannot list all the scenarios where your personal
information is used. For personal information not covered by this Privacy Policy, the relevant product or
service will inform you of your personal information that may be collected through the specific privacy
policy of said product or service or by notification or other means, and will obtain your consent prior to
its collection.
1.3 Information obtained from third parties
Where permitted by law, we may obtain your personal information from public channels or other third
parties. For example: when you use third-party social networking services or pre-installed third-party
applications, we may also obtain your personal information from these services or applications. In
addition, we will explain it to you at the time of collection and obtain your consent.
Webank Microfinance Company SMC LTD may also use other methods to collect other information
about you, your device or the use of services, which will be explained to you at the time of collection or
we will obtain your consent.
1.4 Collection and use of non-personal information
Non-personal information refers to information that cannot be used to determine the identity of a
natural person, such as website visits, application downloads, product sales and various statistical
summary information. The purpose of our collection is to understand how users use our products and
services, and we use this as a basis to continuously improve our services and better meet user needs.
Since this type of information is not personal information, we may collect, use, disclose and transfer
non-personal information at our discretion as permitted by law; when this type of information is
combined with personal information, it will be treated as personal information. We will process such
information in accordance with the requirements of relevant laws and regulations on personal privacy
data protection.
It needs to be emphasized and stated again that, due to the large number of our products and services,
the content and scenarios of personal information collected by Webank Microfinance Company SMC
LTD as listed herein cannot cover all of our business scenarios. For any part that is not included in this
Policy, we will supplement it by specifying in the privacy policy of specific products or services, or by
notification or other means when collecting data in specific business scenarios.
2. Purpose of our use of personal information
When we need to fulfill our obligations to you under the user agreement and/or service contract, or
when we have assessed it is necessary for protecting the legitimate interests pursued by us or a third
party, with your consent, we may process your personal information for the purposes described in this
Privacy Policy. We may also process your personal data for compliance with and enforcement of
applicable legal obligations. We will strictly abide by the content of this Privacy Policy and its updates
when using your personal information.
2.1To provide you with registration services and account management services. We will use the basic
information you filled out during registration to provide you with the corresponding registration services
and subsequent account management services;
2.2To provide customer support and related services for your purchase and post-purchase activities. For
example: your provision of necessary information may be involved when we offer financial services,
warranty services, technical support, or via feedback of error reports to quickly locate and fix existing
abnormal issues, etc.
2.3To provide you with information services for your needs or interests. For example: we may use your
personal information, analyze your usage habits and behavior preferences, and provide you with
notification or content push services based on your consent.
2.4To continue to provide you with better products and services, we may invite you to participate in our
product improvement and user experience related programs or interactive activities. After you join our
programs or activities, we may collect your necessary personal information such as mobile phone
numbers (mainly used for research and return visits), device information, operation behavior data,
location information and log information for statistical analysis, so as to continuously improve and
optimize products and provide a better user experience;
2.5For commercial promotion activities. If you enter into a sweepstake, contest, or similar promotion,
we may use the information you provide to administer those programs;
2.6We may conduct macro customer surveys to analyze market share. We may collect information such
as website visits, application downloads and product sales to analyze market share and provide a
reference for business development.
2.7Other purposes that you consent to. When we want to use your personal information for other
purposes, if the purpose is not stated in this Policy, we will use the privacy policy or notice of the specific
product or service or other means that are accessible to you to obtain your consent in advance.
How We Use Cookies and Similar Technologies
Cookies are small files transmitted by our websites, applications or services and stored on your device.
We use cookies and other similar technologies to distinguish you from other users of our websites. Our
websites, online services, interactive applications, email and other information services may use cookies
and other similar technologies such as pixel tags and web beacons. We generally treat information
collected by cookies and similar technologies as non-personal information. However, to the extent that
Internet Protocol (IP) addresses or similar identifiers are considered personal information by the laws of
the countries concerned, we will also follow the laws of the countries concerned.
We and our partners use cookies or similar tracking technologies to better understand the use of mobile
software on your device, to understand how often you use the app, events that occur within the app,
cumulative usage, performance data, and where the app is downloaded from; we and our partners use
cookies or similar tracking technologies to analyze trends, administer the site, track user behavior on the
site, and collect demographic information about our user base as a whole. For example: we may
cooperate with third parties to display ads on our websites or to manage our ads on other websites. Our
third-party partners may use cookies or similar tracking technologies to serve you ads based on your
browsing history and interests. If you want to opt out of interest-based ads, you can choose
"clearing/disabling cookies" to manage cookies and cookie preferences. If Do Not Track is enabled in
your browser, all of our websites will respect your settings.
You can clear all cookies stored in websites and applications, but if you do so, you will need to change
the settings every time you visit our websites or applications. Most browsers have a function to block
cookies. If you want to manage cookies through a browser, you can refer to the browser developer’s
introduction or search on the Internet. Please note that if cookies are blocked, certain website features
and functionalities may not function properly or may even stop functioning completely.
How We Store and Protect Your Personal Information
The personal information collected based on your consent will be stored in accordance with the laws
and regulations on personal privacy data protection of the countries concerned. To the extent not
prohibited by local laws and regulations, we may also store the collected personal information in
countries or regions outside the country where the business is located.
Whether we store personal information in the country where the business is located, or in other
countries or regions to the extent that doing so does not violate laws and regulations, we will retain it in
accordance with the relevant laws and regulations on data storage. At the same time, we will consider
the characteristics, scope and purpose of personal information processing, the risks that may be
encountered in the processing, and the serious consequences caused by the damage, etc., and
implement the necessary security measures. For example: we will use encryption and de-identification
methods to store the collected personal information. We will also keep the information for the shortest
storage period specified by law. For those not specified by law, we will retain the information according
to the shortest storage period required for business. For data that exceeds the storage period, or data
that you request us to delete, we will delete said data accordingly or take other appropriate measures
without violating the relevant laws and regulations. In addition, we will take other necessary measures
to protect the security of your personal information and prevent data from being misused, unauthorized
access, and unauthorized modification, disclosure or destruction, etc.
Nevertheless, we need to remind you that no matter how perfect the measures are, there is no absolute
guarantee of avoiding the occurrence of data storage security incidents. If a security breach occurs, we
will report it to the corresponding regulatory authorities as required by the relevant laws and
regulations, and provide the type of personal data involved in the breach, the number of data subjects,
the possible consequences of the breach, and the remedial measures we intend to take according to the
requirements of the regulatory authorities. We will take the best possible measures to remedy or
mitigate the damage and consequences of data leakage. When permitted or required by laws and
regulations, we will inform you of the possible consequences or significant damage to you in a timely
manner, so that you can take appropriate measures promptly to protect your rights as much as possible.
There is no absolutely safe website, Internet transmission, computer system and wireless connections.
Except the necessary protective measures we have taken, users have to strengthen the awareness of
privacy security risks. For example, when you jump from our services to third-party websites, links,
products or services, for the security of any data collected by those websites, links, products or services,
please read through the terms and conditions of those third parties carefully. We do not assume any
legal responsibility for data security issues caused by such third parties. If you find that certain contents,
advertisements or functions in our websites, products or services may be provided by a third party and
may possibly endanger your privacy and security, please contact us promptly, as we will handle it with
priority in accordance with laws and regulations.
How We Share, Transfer and Disclose Your Personal Information and Data
In sharing, transferring, and disclosing your personal information, we uphold the principles and
requirements of minimization, necessity, and legality. Under normal circumstances, we do not share,
transfer or disclose your personal information externally. However, to the extent permitted by
applicable laws and regulations, we may share, transfer and disclose your personal information in the
following situations:
In order to provide you with timely services, your personal information may be shared with Webank
Microfinance Company SMC LTD's affiliated companies. We will only share your information within
Webank Microfinance Company SMC LTD’s affiliated companies for legitimate and explicit purposes, and
only share the information necessary to provide the services, and are bound by the purposes stated in
this Privacy Policy. If a purpose concerned is not included in this Policy, we will state it in the
corresponding privacy policy or notice of the specific product or service.
We may share the necessary personal information with authorized third-party partners (including
logistics service providers, data storage service providers, financial service providers, marketing
promotion service providers, etc.) for the performance of certain functions or to provide you with better
service and a better user experience. For example: when you purchase financial products, Webank
Microfinance Company SMC LTD may need to provide your relevant personal information to the
financial service provider to arrange financial loan; when providing you with after-service, we may need
to provide your relevant personal information to the after-service provider in order to offer better
service and support. We uphold the principles of minimization, necessity, and legality to carry out such
sharing. Before sharing information, we will sign strict confidentiality agreements with authorized
partners and require them to take relevant confidentiality and security measures to process personal
information in accordance with this Policy and applicable laws in your jurisdiction.
In order to provide evaluation, analysis or other business services, we may also share your non-personal
information with third parties, for example: we may use aggregated data to help partners (such as
advertising service providers) understand the effectiveness, feedback and usage trends of their services.
In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related
transaction, if a personal information transfer is involved, we will require the new company or
organization holding your personal information to continue to be bound by this Privacy Policy through
an agreement or other appropriate measures, and we will require such subject to take confidentiality
and security measures of a degree no less than the requirements of this Policy to process personal
information.
We will only publicly disclose your personal information in the following circumstances: with your
explicit consent; or to enforce or assist in the enforcement of a mandatory disclosure requirement by
law.
How Your Personal Information is Transferred Across Borders
As a globally operating company, we have resources or servers in different countries or regions
worldwide to support our products and services. In order to better provide services to you, to the extent
permitted by local laws and regulations and with your authorized consent, we may transfer your
personal information to a third country or region for storage or processing, or your data may be
accessed by a third country or region. The privacy protection laws of these countries or regions may be
different. We will follow the legal requirements of the country or region where the personal information
is located to carry out the corresponding cross-border transfer and other processing of personal
information.
Your Rights to Your Personal Information
As a data subject, you have a series of rights to your personal information, including the right to confirm,
access, correct, delete, withdraw consent, and lodge complaints. We fully understand and respect your
rights. We will also take active steps to ensure that your rights are effectively protected. However,
please understand and note that for security reasons, we may need to verify your identity before
processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but
we will charge a certain fee for repeated requests that exceed the reasonable limit where applicable.
We may reject requests that are unreasonably repetitive, require excessive technical means (for
example, to develop new systems or fundamentally change existing practices), pose risks to the legal
rights of others or are very unrealistic, or violate the mandatory provisions by law.
6.1 Right to confirm and access: We inform you how we collect and process personal information
through this Privacy Policy or in the form of a privacy policy or notice of the specific product or service.
You have the right to confirm or reject such collection and processing via a check box or other methods.
However, after you reject, some functions that require your explicit authorization and consent to use
may no longer be available. You can directly access the personal information you have provided to us in
the interface of our products or services. For those that you are unable to access, you can send an email
to takenow.ug@gmail.com. We will handle it promptly after receiving your email.
6.2 Right to correct and delete:When your personal information is changed, or when you find that your
personal information collected and processed by us is inaccurate or incomplete, you have the right to
ask us to make corrections or additions. You can directly correct or modify some of your personal
information on the relevant product/service function pages. When your personal information collected
by us has fulfilled the purpose of collection or is no longer required, or when you find that our collection
and processing of your personal information violates the provisions of laws and regulations or this
Privacy Policy, you have the right to ask us to delete the relevant personal information. For personal
information that we have not provided you with a channel for correction or deletion, you can request
that it be corrected or deleted by contacting takenow.ug@gmail.com.
6.3 Right to withdraw consent:To achieve respective features of our various products or services, we
require necessary personal information as a prerequisite. This is described in the "How We Collect and
Use Your Personal Information" part in this Privacy Policy. You can revoke your consent previously
granted to us for a specific purpose by deleting information, turning off device features, and requesting
to withdraw consent, including the collection, use and/or disclosure of your personal information that
we manage or control. If the method of request to withdraw consent is clearly stated in the privacy
policy or notice of the specific product or service, please follow it accordingly. If not specified, you can
send the relevant request to takenow.ug@gmail.com.
6.4 Right to complain:You have the right to lodge a complaint by sending us an email at
takenow.ug@gmail.com. We will respond promptly after receiving your complaint. If you are unsatisfied
with our response, especially if our processing of personal information damages your legitimate rights
and interests, you may refer your complaint or report to your local statutory personal data protection
department, or file a lawsuit with a competent court.
Third-Party Service Providers and Services
When you use Webank Microfinance Company SMC LTD, you may receive links to third-party websites
or content and services provided by third parties other than us. You can choose whether to visit or
accept the third-party websites, products, and services based on your own judgment. Our Privacy Policy
does not apply to products and services provided by any third party. Since we are not able to
substantially control a third party, we cannot be responsible for the third party’s collection and
processing of your personal information. Therefore, when you submit any information to a third party,
please carefully understand the third party’s privacy policy and be aware when protecting your own
personal information.
Supplement and Update of the Policy
This Policy mainly explains how we collect, process, store and transmit your personal information when
you use Webank Microfinance Company SMC LTD. However, it needs to be emphasized and stated again
that, due to the large number of our products and services, the methods of information collection, types
of collection, use and processing methods, and disclosures described in this Policy may not be fully listed
herein. We may inform you through a privacy policy or notice or by other means for the specific product
or service.
As our business develops and the products or services we provide change, we reserve the right to
update or modify this Policy from time to time. If this Policy is modified, we will notify you of the latest
Policy via notification of Webank Microfinance Company SMC LTD. Please pay attention to our
notifications promptly to keep abreast of the updates to this Privacy Policy. Although this Privacy Policy
may be adjusted, without your explicit consent, we will not weaken your rights pursuant to this Privacy
Policy.
The content of Webank Microfinance Company SMC LTD described herein may vary according to the
type of product you use, system version, or requirements of local laws and regulations.
How to Contact Us
If you have any questions or concerns about our Privacy Policy or practices on personal information
protection, please contact us via:
Email: takenow.ug@gmail.com (Note: This mailbox is only used to receive messages related to our
Privacy Policy or our protection of personal information)
Address: PRISM BUILDING 4tm FLOOR KAMPALA ROAD