PRIVACY NOTICE TO USERS OF ALIPAY SERVICES

Updated as of February, 2017

This notice applies to use of Alipay Services in connection with your online transactions on e-commerce platforms and other online merchants (“merchant sites”), as provided by Alipay Singapore E-Commerce Private Limited (“Alipay SG”).

Alipay SG and their affiliates are collectively referred to as “Alipay”, “we”, “our” or “us”. This notice sets out how we may collect, use, disclose or otherwise process your “personal data”, “personally identifiable information” or other personal information (collectively, “Personal Data”) on behalf of the entities operating the merchant sites. If you do not provide such Personal Data, we may not be able to provide you with Alipay Services. The word “including” shall not be limiting.

By agreeing to the terms of the Alipay Services and completing the registration as a user of the Alipay Service, you will be deemed to have agreed to the terms of this notice concerning the collection, use, storage, transfer and disclosure of your Personal Data as set out in this notice.

A. COLLECTION OF PERSONAL DATA

We may obtain your Personal Data from various sources, including:

  1. We may obtain information when you register as a user of Alipay Services on the payment portal of the relevant merchant site, including your name, date of birth, address, telephone number and e-mail address (“Registration Information”).
  2. We may obtain directly or indirectly details of your bank account numbers, billing and delivery information, credit/debit card numbers and expiration dates and information from checks or money orders (“Account Information”).
  3. We may also obtain your Personal Data from third parties and from publically available sources.

We have taken steps to ensure that we do not collect more Personal Data from you than is necessary for us to provide you with Alipay Services, to protect your account, comply with our legal obligations, protect our legal rights, and operate our business.

B. USE OF PERSONAL DATA

We may use the Personal Data that we obtain about you for the following purposes:

  1. Verifying your identity, including during account creation and password reset processes;
  2. Verifying your eligibility to register as a user of Alipay Services (including any anti-money laundering and counter-terrorist financing verification);
  3. Processing your registration as a user, providing you with a log-in ID and maintaining and managing your registration;
  4. Providing you with Alipay Services and related user services, including facilitating the settlement of purchase price for goods and services, shipping and related services for purchases, charge-backs, sending notices about transactions, and responding to User queries, feedback, claims or disputes;
  5. Managing risk, performing creditworthiness and solvency checks, or assessing, detecting, investigating, preventing or remediating fraud or other potentially prohibited or illegal activities and otherwise protecting the integrity of our payments platform;
  6. Detecting, investigating, preventing or remediating violations of your agreements with us or the merchant site or any applicable policy, industry standards, guidelines, laws and regulations and our policies;
  7. Making such disclosures as may be required by any law or regulation, government official or other third party, including any card association or other payment network. Disclosures may also be made pursuant to any subpoena, court order or other legal process or requirement applicable to us or our affiliate (including anti-money laundering and counter-terrorist financing reporting requirements);
  8. Making any disclosure to prevent any harm or financial loss, to report suspected illegal activity or to deal with any claim or potential claim brought against us or our affiliates;
  9. improving and optimizing the Alipay Services for all Users;
  10. any other legitimate business purposes, such as protecting Users, to protect lives, to maintain the security of our products, and to protect our rights or property.

We also may use your Personal Data in other ways for which we provide specific notice at the time of collection.

C. DISCLOSURE OF PERSONAL DATA

Your Personal Data processed by Alipay will be kept confidential but Alipay may provide such information to the following parties (whether within or outside your country of residence) for the purposes set out in B.1 to B.10 above:

  1. Alipay’s group companies;
  2. Any agent, contractor or third party service provider that we work with in providing Alipay Services, including for fraud prevention, bill collection, data entry, database management, promotions, marketing, customer service, technology services, products and services alerts and payment extension services;
  3. Entities with whom Alipay maintain commercial arrangements, including merchant sites, third parties and entities belonging to the Alibaba Group;
  4. Merchants and other organizations, such as card associations, payment networks or financial institutions, to whom or through which payments are made using Alipay Services, or such other entities to enable your use of Alipay Services;
  5. Third party financial institutions, banks, collection agents and credit agencies;
  6. Third party marketing service providers;
  7. Professional advisers, law enforcement agencies, insurers, government and regulatory authorities or any other organizations to which Alipay is under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement, including arrangements with any card association or payment network; and
  8. Entities involved in any merger, acquisition or financing transaction with us.

D. SECURITY MEASURES

We take steps, including technical, administrative and physical safeguards to help protect your Personal Data that we process from loss, misuse and unauthorised access, disclosure, alteration and destruction.

For registered users of Alipay Services, your Registration Information and Account Information (if any) can be viewed and edited through your account, which is protected by a password. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer.

We will store your Personal Data only for as long as it is necessary for the fulfillment of the purpose for which the data was collected, unless otherwise required or authorized by applicable law.

E. INTERNATIONAL DATA PROCESSING

Your Personal Data may be processed outside your country of residence (including outside the European Economic Area), wherever Alipay, Alibaba Group, and the other third parties to whom we may disclose Personal Data to under C.1 operate. The countries where your Personal Data may be processed may not have the same data protection laws as the laws of your country of residence (including in the European Economic Area).

F. CHILDREN

Alipay Services is not directed towards children under 13 years of age nor does Alipay knowingly collect information from children under 13. If you are under 13, please do not use Alipay Services or submit any Personal Data to us.

G. THIRD PARTY SERVICES AND SITES

The Alipay Services and websites may provide links to other websites and services (including other online merchant sites) for your convenience and information. These services and websites may operate independently from us. Linked services and websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for these websites’ or services content, any use of these services or websites by you, or the privacy practices of these services or websites.

H. CHANGES TO THIS NOTICE

Alipay reserves the exclusive right to change, amend or revise this notice from time to time.

I. FURTHER INFORMATION

If you have any privacy queries, please do so by contacting the Data Protection Office at privacy@alipay.com. You may also contact us at our business address: Legal Department, 1 Raffles Place #59-00 One Raffles Place Tower One Singapore 048616, the department that we have designated for purposes of ensuring that the Personal Data Protection Act 2012 (No. 26 of 2012) is complied with.