Privacy Policy

This Privacy Policy applies to our users (the “Users”) of our services (the “Services”), which are provided by Lite Pay Company Limited (“Lite Pay”) and its affiliates (collectively, referred to as LL Pay Group) to facilitate payments in connection with certain online transactions on your sites. Unless otherwise indicated or the context requires otherwise, reference to “you” or “your” are intended to refer to a User, and reference to “we”, “us” or “our” in this Policy are intended to refer to “Lite Pay” and include relevant companies in LL Pay Group that are involved in providing the Services (each an “Affiliate” or member of the “LL Pay Group”).

Lite Pay (including any entities that actually provide the Services to you) attaches significant importance to the protection and maintenance of your privacy and personal data. We may collect and use your relevant information data when you use our Services. This Privacy Policy (“Privacy Policy” or “Policy”) sets out how we may collect, use, store, share and transfer such information data as well as any available methods for you to manage and control your information data in connection with our Services.

We want you to understand:

ARTICLE I. What Personal Information Do We Collect About You?

The personal information we collect includes:

(a) your basic personal details (including first and last name, and copies of your personal ID documents);

(b) Your ultimate beneficial owners’ information and your directors’ information (including first and last name, residential address, and shareholdings);

(c) contact information (including your business address, residential address, billing address, phone number, email, and other information);

(d) account information (including bank account and payment details);

(e) registration details;

(f) financial information and tax identification information;

(g) transaction details (including purchase orders, your end users’ personal detail and card information); and

(h) technical information, including:

1) information about the device you use to interact with us, and

2) information from your visits to our websites.

ARTICLE II. How We Obtain Your Personal Information?

We collect personal information about you in connection with the Services. For example, we collect your personal information when you browse our website, integrate with our system, enquire about or register to use any of the Services, sign a contract with us, provide your personal information during the User on-boarding process (including but not limited to“know your customer” process and our risk assessment process), log into your account to use the Services; or when you communicate with us via e-mail, phone, SMS, or any other electronic means.  We also receive personal information about you from other sources, including:

(a) other third parties, including those who support the ability to make payments and conduct transactions through the Services;

(b)  affiliates;

(c)  suppliers providing services on our behalf;

(d)  banks and other payment institutions that we cooperate with to provide you with the Services; and

(e)  publicly available sources.

We combine information that we have about you from various sources, including the information you have provided to us.

ARTICLE III. How We Use Your Personal Information?

We use the information we collect to operate our business, including the Services. For example, we may use your personal information for the following purposes:

1. verifying your identity, including during account creation and password reset processes;

2. verifying your eligibility as a User of Services;

3. processing, maintaining and managing your registration as a User;

4. providing you with the Services and related User services, including operating the Services and enabling transactions, customizing your user experience, enabling the receipt of your end users’ 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;

5. contacting you in relation to our provision of the Services, contacting you in connection with any communication preferences or requests you have expressed, asking you for feedback about the 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; sending you information about products and services, including for promotional purposes; and contacting you for legal purposes;

6. assessing, detecting, investigating, preventing or remediating fraud, data breaches or other potentially prohibited or illegal activities and otherwise protecting the integrity of our platform;

7. managing our risk, performing creditworthiness and solvency checks, or detecting, investigating, preventing or remediating violations of your agreements with us or any of our applicable policies, industry standards, guidelines, laws and regulations, etc.;

8. making disclosures as may be required by any rules, law or regulation, regulatory authorities, government official or other third party, including any 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);

9. making disclosures to third parties including relevant 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;

10. improving and optimizing the Services;

11. managing our business including to 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; and

12. otherwise for everyday business purposes, to comply with law, or in other ways for which we provide specific notice at the time of collection.

ARTICLE IV. With Whom Do We Share Your Personal Information?

We share your personal information to operate and manage our business, including for the purposes indicated under ARTICLE III. Thus, for example, we may share your information with:

(a)  Affiliates;

(b)  Third parties, including:

1) any agent, contractor or third party service provider that we work with in providing the Services. For example, we work with third parties 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;

2) banks, card associations, payment networks or acquiring institutions, and others, including those involved in processing of payments and conducting transactions through the Services; and

3) law enforcement agencies, insurers, government and regulatory authorities or any other organizations to which Lite Pay, or any Affiliate or third party service provider, is under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement.

(c) 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

(d) our own and others’ professional advisors (e.g., lawyers, accountants, auditors, and trustees).

ARTICLE V. How Do We Store and Protect Your Personal Information?

We will keep your personal information in accordance with our policies and for as long as it is necessary to provide you with our Services or other purposes as set out in this Policy.  In addition, we may retain your personal information for a longer period if it is necessary to comply with laws and regulations applicable to us.

We use a variety of security measures and technologies designed to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws and regulations. You are responsible for maintaining the security of your account information (username, password, etc.) for our Services in your possession or control.

ARTICLE VI. How Do We Process Personal Information About Children?

Our service is not directed towards children under 18 years old, nor does Lite Pay knowingly collect information from children under 18. If you are under 18, please do not use the Services or submit any personal information to us.

If you, acting as a guardian of a child, have relevant questions in respect of a child’s personal information, please contact us using the details set out in theARTICLE XI.section below.

ARTICLE VII. Third Party Services and Sites

The Services and our website 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.

ARTICLE VIII. Changes to This Policy

We may change, amend or revise this Policy from time to time. We will notify you of any substantive or material change in this Policy by updating this web page, sending notifications, e-mails or letters, by phone or by publishing announcements on our website. You can also review this Policy at the home page of our website.

ARTICLE IX. Your Rights with Respect to Your Personal Information

In accordance with applicable data protection and privacy laws and regulations, you may be entitled to:

(a) ask us about the processing of your personal information, including to request a copy of your personal information;

(b) request the correction and/or (in some cases) deletion of your personal information;

(c)  in some cases, request the restriction of the processing of your personal information, or object to that processing;

(d) withdraw your consent to the processing of your personal information (where Lite Pay is processing your personal information based on your consent);

(e)  request receipt or transmission to another organisation, in a machine-readable form, of the personal information that you have provided to Lite Pay where we are using your personal information based on consent or performance of a contract; and

(f) complain to the relevant supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.

Where you are given the option to share your personal information with us, you can always choose not to do so.  If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your personal information with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described (see How we use your personal information) or that you are unable to make use of the services and products offered by us.  After you have chosen to withdraw your consent, Lite Pay may be able to continue to process your personal information to the extent required or otherwise permitted by applicable data protection and privacy laws or regulations.

If you would like to exercise your rights, contact us using the details set out in ARTICLE XI. section below.

ARTICLE X. Transfers of Your Personal Information outside of Hong Kong

Your personal information may be processed by us, companies in the LL Pay Group and our trusted third party suppliers outside of Hong Kong, including in the regions and/or countries where data protection and privacy laws or regulations may not be equivalent to, or as protective as, the data protection and privacy laws and regulations in Hong Kong.

These regions and/or countries include, among others:

· Mainland, PRC.

· Brazil

In accordance with applicable data protection and privacy laws and regulations, we will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of Hong Kong to a jurisdiction.

We may also transfer your personal information outside of Hong Kong as permitted by applicable data protection and privacy laws and regulations. Examples include where we need to transfer your personal information: (a) to perform a contract with you (or to take steps before the contract at your request); (b) perform a contract in your interests; or (c) in relation to legal claims.

ARTICLE XI. Contact Us

If you have questions or requests about the privacy of your personal information, please contact us by email via or at our business address: Room 1116-19, Sun Hung Kai Centre, 30 Harbour Road,Wan Chai, Hong Kong.