Wenfubang - Personal Information Protection Guidelines

Personal Information Protection Guidelines

Effective Date: July 8, 2024

Release Date: July 8, 2024

Introduction

Dear Wenfubang users, as the operator of the platform, we deeply understand the importance of your personal information and appreciate your trust in us. We will protect the security of your personal information in accordance with laws and regulations. When you use the services of our Wenfubang mobile client (APP), we will inform you how we collect, store, protect, use and provide your information externally in accordance with the Wenfubang "Personal Information Protection Guidelines" (hereinafter referred to as the "Personal Information Protection Guidelines" or "this Guidelines"). In order to ensure the legal, legitimate and necessary collection and use of your personal information, and to store and transmit it in a safe and controllable manner, please carefully read the content of the Personal Information Protection Guidelines before officially using the services through this platform. If you have any questions during the reading process, you can contact our customer service (contact phone number: 13810488871) for consultation.

This Guidelines is closely related to your use of our services. We recommend that you carefully read and understand all the content of the Personal Information Protection Guidelines. The terms and important content related to your personal information rights and interests have been highlighted in bold for your key reference.

You can scroll down the page to view the corresponding chapters according to the following table of contents to further understand the relevant terms of the Personal Information Protection Guidelines.

I. How We Collect Your Personal Information

II. How We Use OAuth Authentication and Authorization Technology

III. How We Store and Protect Personal Information

IV. How We Use Personal Information

V. How We Provide Information Externally

VI. Your Rights

VII. How We Protect Minors' Information

VIII. Updates to This Guidelines and How to Contact Us

IX. Law Application and Dispute Resolution

I. How We Collect Your Personal Information

1.1 Relevant Definitions and Explanations

1.1.1 Definitions

"Wenfu Information" or "We": Refers to Beijing Wenfu Information Technology Co., Ltd., with the registered address: Room 1250, 2nd Floor, Building 55, No. 5 Yard, Yujing East Road, Tongzhou District, Beijing; the contact address: Room 162, 4th Floor, Building B, Shimao Tower, No. A92, Jianguo Road, Chaoyang District, Beijing.

"Wenfubang APP" or "This Platform": Refers to the mobile intelligent terminal application software developed and operated by Wenfu Information.

"Wenfubang Website": Refers to the official website: https://wefullbund.com/

"Personal Information": Personal information refers to various information recorded in electronic or other forms related to an identified or identifiable natural person, excluding information after anonymization.

1.1.2 Explanations

(a) In this Guidelines, unless otherwise explicitly provided, the following terms shall be interpreted as follows:

(i) "Day", "Month" and "Year" refer to the days, months and years of the Gregorian calendar;

(ii) "Include" means including but not limited to;

(iii) Unless otherwise stated, time shall be interpreted as Beijing time.

(b) The titles are for convenience only and shall not affect the interpretation.

1.2 Application Scenarios Requiring Collection for Business Function Realization

When you use our products and/or services, we need to collect your personal information to provide services to you, improve our service level, ensure the security of your account and comply with national laws, regulations and regulatory requirements.

Here, you understand and agree that:

I. We are committed to providing personalized and differentiated services to meet your needs. Facing the various services we provide, users can make autonomous choices. Since the specific service scopes selected and used by different users vary, correspondingly, the types and scopes of personal information we collect and use will also be different. Please refer to the specific service functions.

II. In order to continuously improve your service experience, we are constantly striving to improve our technology. As a result, we may launch new or optimized functions from time to time, which may require collecting and using new personal information or changing the purpose or method of using personal information. In this regard, we will separately inform you of the collection purpose, scope and use method of the corresponding information through updating the Personal Information Protection Guidelines, pop - up windows, page prompts, etc., and provide you with a way to autonomously choose to agree. We will collect and use the information after obtaining your explicit consent. During this process, if you have any questions, opinions or suggestions, you can contact us through various contact methods provided by this platform, and we will answer you as soon as possible.

III. In order for you to use our services normally, we will collect your relevant personal information in the following situations and business scenarios, and may also collect your personal information from third - parties who legally store your relevant information.

1.2.1 Non - registered Users

If you have not registered our account, it will not prevent you from using the platform's functions. Unless we have obtained your explicit authorization in advance, we will not obtain any permissions of your mobile device and will not collect any of your information.

1.2.2 Account Registration and Login

(a) Mobile Phone Number Registration and Login

When you register as a Wenfubang user, you need to provide us with a real - name mobile phone number under your name. We will verify the validity of your identity by sending a SMS verification code. After the verification is passed, a Wenfubang account UID will be created. You can also register through a third - party account (see below). After successfully registering a Wenfubang account, you can upload your user avatar (the avatar must be a picture that does not contain illegal content) and modify your nickname.

(b) Third - party Account Registration and Login

For your convenience, we allow you to register and log in to your Wenfubang account through your WeChat account. We will obtain relevant information of this WeChat account according to the authorization. After successfully registering a Wenfubang account, your nickname and avatar will be displayed on the Wenfubang platform. For this purpose, we need to obtain and verify your WeChat account information from WeChat (including your nickname and avatar on WeChat, as well as the information provided to us by WeChat according to its authorization rules). Except for the above situation, we will not actively obtain your personal information from third - parties without your explicit authorization.

This platform uses third - party registration and login services which need to be embedded in the third - party SDK (WeChat Open Platform) to complete.

Third - party SDK: WeChat Open Platform

Company Name: Tencent Technology (Shenzhen) Co., Ltd.

Involved Personal Information: IMEI, MAC

Purpose of Use: WeChat Login

Usage Scenario: Login

Collection Method: The SDK collects it by itself

1.2.3 Helper Function

The helper function aims to provide you with a new user zone, selected special topics and a gold consultant function. At present, we do not collect relevant information from users for this function. In subsequent versions, we may collect your access records, access times, nickname and avatar information.

(a) New User Zone

You can visit the official website of Wenfubang (jump to the official website https://wefullbund.com/).

(b) Selected Special Topics

You can browse the graphic information published in our selected special topics.

You can browse the introduction information of our gold consultants published in the selected special topics.

1.2.4 Wealth Function

Under the wealth function, you can enter your corresponding information according to the relevant composition details set by the platform. This information is required for the analysis function provided by this platform. Failure to enter it will affect your use of the analysis function and service experience.

(a) Assets and Liabilities

You can enter the category information corresponding to assets, liabilities and insurance under the "Assets and Liabilities" item. We will collect your cash assets (including cash/current accounts, money market funds, etc.), investment assets (including public funds, private securities funds, etc.), fixed assets (including real estate, cars, etc.) and insurance asset information under the assets item.

(b) Cash Flow

You can enter the category information corresponding to income and expenditure under the "Cash Flow" item. We will collect your income (including salary, bonus, etc.) and expenditure (including living expenses, loans, etc.) information under the cash flow item.

1.2.5 Planning Function

(a) Home Purchase Planning

You can enter the corresponding category information under the "Home Purchase" item. We will collect your information such as the total price of the property, loan amount and taxes under the home purchase item.

(b) Retirement Planning

You can enter the corresponding category information under the "Retirement" item. We will collect your expected retirement time, estimated retirement income, estimated retirement expenditure, social security pension and other information under the retirement item.

You can enter the corresponding category information under the "One - Time Money" item. We will collect your information such as the name of the money use, target amount and money use date under the one - time money item.

1.2.6 Information Required for Secure Operation

To ensure the safe and stable operation of this Application, we may collect necessary basic device information, network status information, and log information for troubleshooting, security protection, and service stability assurance. This Application will not independently collect your device MAC address, software installation list, or running application process information. If you use payment services within this Application, the relevant payment SDKs may collect necessary device and application information during the payment process for payment security purposes. For details, please refer to the "Third-Party SDK Description" in this Guideline.

1.2.7 Payment Services

When you use the payment function within this App, we will integrate third-party payment SDKs to help you complete payments and ensure transaction security.

(1) WeChat Pay SDK

Third-party Name: Tenpay Payment Technology Co., Ltd.

SDK Name: WeChat Pay SDK

Purpose of Use: To help users complete payments, ensure transaction security, conduct risk control, and prevent fraudulent transactions

Types of Information Collected: Device MAC address, software installation list, device hardware model, unique device identifier, operating system version

Collection Method: Automatically collected by the SDK when the user initiates a payment

Usage Scenarios: Invoked only during the payment process

Information Flow Description: The above information is collected by the WeChat Pay SDK and transmitted to its servers for payment verification and security risk control. This App will not upload the above information to its own servers nor store such information on its own servers.

Sharing Object: Tenpay Payment Technology Co., Ltd.

Privacy Policy Link: https://www.tenpay.com/v3/helpcenter/low/privacy.shtml

(2) Alipay SDK

Third-party Name: Alipay (Hangzhou) Information Technology Co., Ltd.

SDK Name: Alipay SDK

Purpose of Use: To help users complete payments, ensure transaction security, conduct risk control, and prevent fraudulent transactions

Types of Information Collected: Device MAC address, software installation list, device hardware model, unique device identifier, operating system version

Collection Method: Automatically collected by the SDK when the user initiates a payment

Usage Scenarios: Invoked only during the payment process

Information Flow Description: The above information is collected by the Alipay SDK and transmitted to its servers for payment verification and security risk control. This App will not upload the above information to its own servers nor store such information on its own servers.

Sharing Object: Alipay (Hangzhou) Information Technology Co., Ltd.

Privacy Policy Link: https://opendocs.alipay.com/common/02kiq3

Special Note:

The types of information collected, processing methods, and scope of third-party payment SDKs may change due to SDK version updates or changes to third-party rules. Please refer to the privacy policy or service description officially published by the third party for the most accurate information.

1.2.8 Clipboard Information

To facilitate quick pasting and filling of information when you use this App and enhance service experience, we may read the content in your device's clipboard in specific functional scenarios.

Usage Scenarios include: When you actively enter a page that requires pasting content, or actively perform operations such as pasting or input recognition, we may read the clipboard information to identify the content you have copied and assist in completing filling, jumping, or business processing.

Type of Information Processed: Text information in the clipboard.

Purpose of Processing: To improve input efficiency, conveniently identify content actively copied by users, and optimize functional experience.

Processing Method: Temporarily read only in relevant functional scenarios.

Information Storage and Usage Scope: Except as necessary to implement the current function, we will not collect, store, or upload irrelevant clipboard content to this App's servers.

If you do not agree to our reading of clipboard information in relevant scenarios, it may affect the convenience of corresponding functions, but will not affect your use of other basic functions of this App.

1.3 Optional Authorized Permissions for Business Function Realization

When you use our products and/or services, in order to realize the functions of providing our products and/or services to you, we will apply to the system for the following device permissions. We will seek your consent before the application, and you can choose to "Allow" or "Prohibit" the permission application. After obtaining your authorization, we will enable the relevant permissions, and you can cancel the authorization in the system at any time. If you refuse to provide or cancel the authorization, it will not affect your use of the basic services on this platform, but you may not be able to obtain the user experience brought by the following services. This platform is currently only applicable to mobile devices with the IOS system.

1.3.1 Network

Purpose of Use: To enable the Internet access function (by connecting to a Wi - Fi network or enabling mobile data) to achieve the reading, updating and normal use of Wenfubang content;

1.3.2 Device Information/Phone Status:

Purpose of Use: To ensure safe operation and complete risk control verification, it is necessary to obtain device information such as IMEI, IMSI and the running status, as well as the mobile phone number;

1.3.3 Storage

Purpose of Use: To facilitate users to save picture information when using the financial analysis function;

1.3.4 Application Program Installation List

Purpose of Use: To confirm whether you have installed the software of our cooperative third - party platforms by obtaining your application program list;

1.4 Exceptional Situations for Obtaining Authorization Consent

According to relevant laws, regulations and national standards, in the following situations, we may legally collect and use your personal information without obtaining your consent:

(a) It is necessary for fulfilling statutory duties or obligations.

(b) It is necessary for responding to a sudden public health event or protecting the life, health and property safety of natural persons in an emergency.

(c) It is for the public interest, such as news reporting and public opinion supervision, and personal information is processed within a reasonable scope.

(d) Personal information that has been publicly disclosed by the individual himself or has been legally disclosed by others is processed within a reasonable scope in accordance with the "Personal Information Protection Law".

(e) Other situations stipulated by laws and administrative regulations.

1.5 Special Reminder

Please understand that since our products and services are constantly developing and improving, we may add new functions or adjust existing functions from time to time. If we provide you with other business functions and services, we will separately inform you of the scope and purpose of information collection and collect the information you need to provide the corresponding services after obtaining your consent. We will strictly abide by the provisions of laws and regulations and the agreements in this Guidelines, take necessary measures in accordance with the law, continuously protect your personal information and fully respect your right to manage your personal information.

II. How We Use OAuth Authentication and Authorization Technology

Our application program uses OAuth authentication and authorization mechanism to protect your personal information. OAuth is an open standard that allows you to securely authorize our application program to access your account information on other service providers without sharing your account credentials.

When you use our application program, you may be required to log in with your account on other service providers. This is to simplify your login process and ensure the protection of your personal information. We will not store or use your account credentials in any way.

Please note that when you authorize our application program to access your account information, we can only access the information you authorize and can only use this information within the authorized scope. We will make every effort to protect your personal information and strictly comply with applicable personal information protection laws and regulations.

III. How We Store and Protect Personal Information

3.1 How We Store Your Personal Information

We hereby declare that the personal information collected and generated within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. We will only retain your personal information for the time necessary to achieve the purpose.

3.2 Protecting Your Personal Information with Technical Means

3.2.1 We have used security protection measures in line with industry standards to protect the personal information you provide, preventing the data from being accessed, publicly disclosed, used, modified, damaged or lost without authorization. We are committed to using various security technologies and supporting management systems to minimize the risks of your information being leaked, damaged, misused, accessed without authorization, disclosed without authorization and changed.

3.2.2 We adopt a combination of end - cloud and data isolation to enhance our data security capabilities. Technically, we take the following measures:

(a) Data encryption: Encrypt and store and transmit users' personal information.

(b) Access control: Implement strict data access permission management.

(d) Vulnerability management: Discover and fix security vulnerabilities in a timely manner.

(e) Data backup: Regularly back up important data to ensure data recoverability.

3.3 Protecting Your Personal Information with Management Means

We have set up a personal information protection commissioner position to conduct a personal information security impact assessment on the collection, use and sharing of personal information, ensuring that only authorized personnel can access personal information. At the same time, we have established relevant internal control systems, adopting the principle of minimum necessary authorization for the staff who may come into contact with your information; systematically monitoring the behavior of the staff in handling your information, and continuously training the staff on relevant laws and regulations, privacy and security guidelines and strengthening the publicity of security awareness.

3.4 Emergency Response to Personal Information Security Incidents

3.4.1 We have formulated an emergency response plan for personal information security incidents and regularly organize internal relevant personnel for training and emergency drills to enable them to master their job responsibilities and emergency response strategies and procedures.

3.4.2 In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the measures we have taken or will take, the suggestions for you to independently prevent and reduce risks, and the remedial measures for you. We will promptly inform you of the relevant situation of the incident by means of email, phone, SMS, APP push notifications, etc. When it is difficult to inform individual information subjects one by one, we will adopt reasonable and effective methods to issue announcements. At the same time, we will also actively report the handling situation of the personal information security incident to the regulatory authorities as required.

3.4.3 The Internet is not an absolutely secure environment. You must properly keep your account and other identity elements. When you use the platform and services, we will identify your identity through your account and other identity elements. Once you leak the above information, you may suffer losses and may have adverse legal consequences. If you find that your account or/and other identity elements may have been or have been leaked, please contact us immediately so that we can take corresponding measures in a timely manner to avoid or reduce relevant losses.

IV. How We Use Personal Information

4.1 Situations of Using Personal Information

In order to comply with national laws, regulations and regulatory requirements, as well as to provide services to you and improve service quality, or to ensure the security of your account, we will use your information in the following situations:

4.1.1 Realization of Existing Product and Service Functions

To achieve the purposes described in "How We Collect Your Personal Information" in this Guidelines

4.1.2 User Profiling

After collecting your personal information, we will de - identify the data through technical means, and some of the data will be statistically analyzed internally to form feature tags.

4.2 Others

4.2.1 When we add new functions or adjust existing functions on the basis of existing services and functions, or when we want to use personal information for other purposes not specified in this Guidelines, we will, in accordance with the requirements of laws, regulations and national standards, seek your consent again in the form of agreement confirmation, copywriting confirmation actions in specific scenarios, etc.

4.2.2 All personal information provided when using our products or services will continue to be authorized for us to use during your use of our products or services, unless you delete it or refuse our collection through system settings. When you cancel your account, we will stop using and delete your personal information or anonymize your personal information.

V. How We Provide Information Externally

5.1 Sharing

5.1.1 Except as otherwise provided by laws, regulations and regulatory authorities, we promise to keep your information strictly confidential.

5.1.2 We will not share your personal information with any company, organization or individual, except in the following situations:

(a) We have obtained your explicit consent or authorization in advance.

(b) Based on legal situations: As required by judicial organs or government agencies in accordance with the law for the settlement of disputes such as legal proceedings.

5.2 Transfer

We will not transfer your personal information to any company, organization or individual, except in the following situations:

5.2.1 Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

5.2.2 In case of merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this personal information protection policy. Otherwise, we will require the company or organization to seek your authorization and consent again.

5.3 Public Disclosure

We will only publicly disclose your personal information in the following situations:

5.3.1 After obtaining your explicit consent;

5.3.2 Disclosure based on the law: In case of legal requirements, legal procedures, litigation or mandatory requirements of government authorities, we may publicly disclose your personal information.

VI. Your Rights

During your use of this application and services, in order to enable you to more conveniently access and manage your personal information and ensure your right to cancel your account, we have provided corresponding operation settings to ensure the exercise of your rights over your personal information.

6.1 Accessing and Correcting Your Personal Information

6.1.1 Accessing Basic Information such as Avatar and Nickname

Query and access through [Me - Personal Information - Profile Information].

6.1.2 Accessing Mobile Phone Number

Query and access through [Me - Personal Information - Profile Information].

6.2 Deleting Your Personal Information

6.2.1 You can directly clear or delete information such as message records and cache records through [Me - Personal Information - Profile Information].

6.2.2 In the following situations, you can request us to delete your personal information:

(a) If our handling of personal information violates laws and regulations;

(b) If we collect and use your personal information without your consent;

(d) If you no longer use our products or services, or you cancel your account;

(e) If we no longer provide products or services to you.

6.3 Changing the Scope of Your Authorization Consent or Withdrawing Your Authorization

6.3.1 Each business function requires some basic personal information to be completed. You can modify the authorization scope by deleting information, turning off device functions, and making privacy settings on the platform and in the following ways:

Modify permissions through [Me - Support - Permissions and Privacy - Permissions];

6.3.2 You can also withdraw all authorizations for us to continue collecting your personal information by canceling your account; when you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw consent will not affect the previous personal information processing based on your authorization.

6.4 Canceling Your Account

6.4.1 You can cancel your previously registered account at any time. You can operate it by yourself through [Me - Personal Information - Profile Information].

6.4.2 Generally speaking, we will complete your request within a maximum of 15 working days after verification. When you cancel your account, we will stop providing products and services to you. At that time, all information in your account will be cleared, and we will no longer collect, use or provide externally the personal information related to this account, except as otherwise provided by laws and regulations.

6.5 Responding to Your Requests

If you cannot access, correct or delete your personal information through the above methods, or you need to access, correct or delete other personal information generated when using our products or services, or you think that this platform violates any laws and regulations or the agreement with you regarding the collection or use of personal information, you can contact us through the customer service phone number in the Personal Information Protection Guidelines. For security reasons, we may require you to provide a written request or prove your identity in other ways. Generally speaking, we will reply to your request within 15 working days after verification.

In the following situations, in accordance with the requirements of laws and regulations, we will not be able to respond to your request:

(a) It is directly related to national security and national defense security;

(b) It is directly related to public security, public health and major public interests;

(d) There is sufficient evidence to show that you have subjective malice or abuse your rights;

(e) Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations.

(f) It involves trade secrets.

VII. How We Protect Minors' Information

7.1 Restrictions on Minors' Use

Our products, platforms and services are mainly targeted at adults. Minors are not allowed to create their own accounts without the consent of their guardians. For the situation where the personal information of minors is collected with the consent of their guardians, we will only use or disclose this information when permitted by law, with the explicit consent of the guardians or when it is necessary to protect minors.

7.2 Protection Measures

If your parents or guardians do not agree to your use of the services or provision of information in accordance with this Guidelines, please immediately stop using the services and notify us in time so that we can take corresponding measures.

If we find that we have collected the personal information of minors without prior verifiable consent from their guardians, we will try to delete the relevant data as soon as possible.

If you are the guardian of a minor and have questions about the handling of the minor's information, please contact us.

VIII. Updates to This Guidelines and How to Contact Us

8.1 Updates to This Guidelines

Our Personal Information Protection Guidelines may be changed. Without your explicit consent, we will not reduce the rights you should enjoy in accordance with this Personal Information Protection Guidelines.

8.1.1 Situations for Updating This Guidelines

According to user needs, business rules and legal requirements, and when the following major changes occur, we may adjust this Guidelines in a timely manner:

(a) There are major changes in our service model. Such as the purpose of processing personal information, the types of personal information processed, the way of using personal information, etc.;

(b) There are major changes in our organizational structure, ownership structure, etc. For example, business adjustments, mergers, acquisitions, reorganizations that cause changes in the owner, etc.;

(d) The objects, scope and purpose of providing personal information externally change;

(e) The way you access and manage personal information changes;

(f) The data security capabilities and information security risks change;

(g) The responsible position, contact method and complaint channel for handling personal information security change;

(h) Other changes that may have a major impact on your personal information rights and interests.

We will also archive the old versions of this Guidelines for your reference

8.1.2 Notification Methods for Updates to This Guidelines

(a) A pop - up window will remind you when you log in to the Wenfubang APP client software;

(b) Short message notifications will be pushed to you when you use our products and/or services;

(d) An announcement will be made on the official website of Wenfu Information.

In order for you to receive notifications in a timely manner, it is recommended that you notify us in time when your contact information is updated. If you re - confirm your consent to this Guidelines or continue to use our products and/or services after the updated Guidelines come into effect, it means that you have fully read, understood and accepted the updated Guidelines and are willing to be bound by the updated Guidelines.

8.1.3 Accessing the Updated Guidelines

You can view this Guidelines in the Wenfubang App through [Me - Support - Permissions and Privacy - Personal Information Protection]. We encourage and welcome you to check this Guidelines every time you use our services.

8.2 How to Contact Us

If you have any questions, opinions, suggestions or need to consult about this Guidelines, you can contact us through the contact phone number. To ensure the security of your information, we need to verify your identity information first. Generally speaking, we will reply to your request within a maximum of 15 working days after verification.

Contact Phone Number: 13810488871

Email: support@wefullbund.com

IX. Law Application and Dispute Resolution

9.1 Law Application

The formation, effectiveness, performance, interpretation and dispute resolution of this Guidelines shall be governed by the laws of the mainland of the People's Republic of China.

9.2 Dispute Resolution

If you and we have any disputes regarding the content of this Guidelines or its implementation, both parties should resolve them through friendly negotiation; if both parties cannot resolve the disputes through negotiation, both parties agree to submit the disputes to the people's court at the place where Wenfu Information is located for litigation.