Privacy Policy

1. SCOPE

This Privacy Policy applies to personal information processed by us, including through our website, mobile applications, and other online or offline offerings. For readability, our website, products, solutions, and other offerings are collectively referred to as "Services."

Important Note: This Privacy Policy does not apply to personal information that our customers process using Winupay’s products and services ("Customer Data"). Customer Data is governed by our customers’ respective privacy policies, and our processing of Customer Data is regulated by the contracts we have with our customers—not this Privacy Policy. If you are an end user of the Services through one of our customers, direct any questions or requests regarding Customer Data to that customer.

For clarity: Winupay is a controller for personal information we collect from customers to market, service, and provide access to the Services. For Customer Data entered into the Services, the customer is the controller, and we act as a processor or service provider (as defined by applicable laws). We only process Customer Data as agreed to provide Services under our Terms and Conditions or other customer contracts, and where applicable. The Services (and personal information collected in connection with them) are intended for business use, not personal, family, or household purposes.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us and our Services, as well as applicable legal requirements. We collect information you provide directly, information obtained automatically when you use our Services, and information from other sources (e.g., third-party services and organizations), as detailed below.

Information You Provide Directly

We may collect the following personal information you voluntarily provide:

Account Creation: Information such as a unique customer ID, email address, or phone number when you create an account.
Communications: Personal information (e.g., email address, phone number, mailing address) when you request information about our Services, register for our newsletter, seek customer or technical support, apply for a job, or otherwise communicate with us.
Surveys: If you choose to participate in surveys, we may collect personal information as part of the survey responses.
Business Development: Personal information from individuals and third parties to assess and pursue potential business opportunities or strategic partnerships.

Information Collected Automatically

We may automatically collect personal information when you use our Services:

Website Usage Data: Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location from IP address), and Internet service provider. We also collect usage details such as pages visited before, during, and after using our Services, links clicked, content interactions, activity frequency and duration, and other usage patterns.
Service Usage Data: Technical information about your use of our Services, such as "telemetry" metrics. This technical information is not linked to your personal information or Customer Data and is only used to improve our Services.
Cookies, Pixel Tags/Web Beacons, and Other Technologies: We and third parties providing content or functionality on our Services may use cookies, pixel tags, local storage, and other technologies ("Technologies") to automatically collect information. You can manage cookie preferences via the "Cookie Manager" in the footer.

Our use of these Technologies falls into three categories:

Essential: Technologies required to access the Services, identify irregular website behavior, prevent fraud, improve security, or enable core functionality.
Marketing and Analytics: Technologies to assess Service performance and conduct analytics to understand how users interact with our Services.
Advertising: Technologies that enhance functionality, such as identifying you when signing into the Services or tracking preferences, interests, or past viewed items.

We also use third-party tools for analytics and support, including:

Analytics: We use tools like Google Analytics. For more details, refer to the Privacy Policy of the respective analytics provider. You can opt out of such analytics as permitted by their policies.
AI-Powered Support: We use Inkeep, Inc.’s service for self-service support. Refer to their Privacy Policy for details.
Support Tickets: We use Not Just Tickets Ltd (d/b/a Plain) for support ticket management. Refer to their Privacy Policy for details.

Social Media Platforms: Our Services may include social media buttons (e.g., LinkedIn, Twitter) or widgets (e.g., "share this" buttons). These features may collect your IP address, the page you are visiting, and set cookies to function properly. Your interactions with these platforms are governed by the respective platform’s privacy policy.

Information Collected from Other Sources

We may obtain information about you from third-party services and organizations. For example, if you access our Services through a third-party application (e.g., app store, third-party login service, social networking site), we may collect information you have made available via your privacy settings on that platform.

3. HOW WE USE YOUR INFORMATION

We use your information for various business purposes, including providing our Services, administrative tasks, and marketing our products and Services, as outlined below.

Provide Our Services

We use your information to fulfill our contract with you and deliver the Services, such as:

Managing your information and accounts;
Granting access to specific areas, functionalities, and features of the Services;
Responding to customer or technical support requests;
Communicating with you about your account, Service activities, and policy changes;
Processing job applications submitted through our Services;
Allowing you to register for events.

Administrative Purposes

We use your information for administrative needs, such as:

Pursuing legitimate interests (e.g., direct marketing, research and development, network and information security, fraud prevention);
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible;
Measuring interest and engagement in our Services;
Improving, upgrading, or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities;
Debugging to identify and repair Service errors;
Auditing related to interactions, transactions, and compliance activities;
Enforcing our agreements and policies;
Complying with legal obligations.

Marketing and Advertising

We may use personal information to tailor and deliver content and advertisements, as permitted by applicable law. This includes email campaigns.

If you have questions about our marketing practices or wish to opt out of marketing-related use of your personal information, contact us as detailed below.

Other Purposes

We also use your information for other purposes as requested by you or permitted by applicable law:

Consent: For purposes clearly disclosed to you when you provide personal information or with your explicit consent;
De-identified and Aggregated Information: Creating de-identified and/or aggregated information (e.g., de-identified demographic data, location data, device information) for analysis;
Share Content: Enabling you to share content with friends or colleagues through referral services (e.g., sending an email inviting a friend to use our Services).

4. HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for business purposes, including providing our Services, protecting ourselves or others, or in connection with major business transactions (e.g., mergers, sales), as described below.

Disclosures to Provide Our Services

We may share your personal information with the following categories of third parties to deliver our Services:

Service Providers: Third-party service providers that assist us in delivering the Services (e.g., IT support, hosting, payment processing, customer service, SMS authentication);
Business Partners: Partners to provide a product or service you requested, or with whom we jointly offer products or services;
Advertising Partners: Third-party advertising partners that may set Technologies and tracking tools on our Services to collect activity and device information (e.g., IP address, cookie identifiers, visited pages, location). These partners use this information to deliver personalized advertisements (commonly called "interest-based advertising");
APIs/SDKs: Third-party Application Program Interfaces (APIs) and software development kits (SDKs) used to enhance Service functionality. Contact us for more details about our use of APIs and SDKs.

Disclosures to Protect Us or Others

We may access, preserve, and disclose stored information about you to external parties if we reasonably believe it is required or appropriate to:

Comply with law enforcement or national security requests and legal process (e.g., court orders, subpoenas);
Protect your, our, or others’ rights, property, or safety;
Enforce our policies or contracts;
Collect amounts owed to us;
Assist with investigations or prosecutions of suspected or actual illegal activity.

Disclosure in Business Transactions

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, asset purchase or sale, or service transition to another provider, your information may be sold or transferred as part of the transaction (as permitted by law and/or contract).

5. YOUR PRIVACY CHOICES AND RIGHTS

Your privacy choices and rights are determined by applicable law, as described below.

Your Privacy Choices

Email and Telephone Communications: Unsubscribe from unwanted promotional emails using the link at the bottom of the email. You will still receive transaction-related emails (e.g., about requested products or Services) and non-promotional communications (e.g., Service updates, policy changes), which cannot be opted out of. We process do-not-mail, do-not-phone, and do-not-contact requests as required by law;
Do Not Track (DNT):
DNT is a browser setting for privacy preferences. We do not respond to or honor DNT signals or similar browser mechanisms;
Cookies and Interest-Based Advertising: You can stop or restrict Technologies on your device or remove them via browser/device settings. Note that adjusting these preferences may affect Service functionality. Cookie-based opt-outs do not work on mobile applications, but you can opt out of personalized ads on mobile apps by following platform instructions (e.g., Android, iOS). Access our cookie management dashboard via the "Cookie Manager" in the footer. You can also opt out of targeted ads from participating data and advertising partners through industry self-regulatory programs (e.g., Network Advertising Initiative, Digital Advertising Alliance). Opt-outs must be completed separately for each browser and device.

Your Privacy Rights

Under applicable law, you may have the right to:

Access Personal Information: Confirm if we are processing your personal information, obtain access to or a copy of it, or receive an electronic copy of personal information you provided (or request we send it to another company, known as the "right of data portability");
Request Correction: Correct inaccurate or incomplete personal information (some self-service tools may be available for updates);
Request Deletion: Request deletion of your personal information;
Request Restriction or Objection: Restrict or object to our processing of your personal information;
Withdraw Consent: Withdraw consent to our processing of your personal information.

To exercise any of these rights, contact us as detailed below. We will process requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take steps to secure your information in compliance with this Privacy Policy. However, no system is 100% secure, and we cannot guarantee the absolute security of information you provide to us.

We have implemented appropriate safeguards to protect personal information and require our third-party service providers and partners to do the same. To the fullest extent permitted by applicable law, we are not liable for unauthorized disclosure.

By using our Services or providing personal information, you agree to receive electronic communications from us regarding security, privacy, and administrative matters related to your use of the Services. If we learn of a security breach, we may notify you electronically (e.g., via a Service notice, email) or by mail.

7. INTERNATIONAL DATA TRANSFERS

All information we process may be transferred, processed, and stored worldwide—including in Hong Kong or other countries with different data protection laws than your place of residence. We strive to protect your information in compliance with applicable laws.

If you are a resident of the European Economic Area, Switzerland, or the United Kingdom, refer to our supplemental GDPR notice for additional details.

8. RETENTION OF PERSONAL INFORMATION

We store personal information collected under this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected. This includes providing our Services, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing our agreements, and complying with applicable laws.

9. CHILDREN’S INFORMATION

Our Services are not intended for use by children under the age of 16.

If we become aware that a child has provided personal information in violation of applicable law, we will delete the collected personal information.

10. OTHER PROVISIONS

Third-Party Websites/Applications: Our Services may contain links to other websites/applications, and third-party sites may link to our Services. We do not control these third-party services. We encourage you to read their privacy policies before interacting with them. We do not endorse, screen, or approve third-party privacy practices or content, and providing personal information to third-party sites is at your own risk;
Supervisory Authority: If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to file a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law;
Changes to This Privacy Policy: We may revise this Privacy Policy at our sole discretion. For material changes, we will notify you as required by law. Your continued use of the Services after the updated Privacy Policy takes effect constitutes acceptance of the changes.

11. CONTACT US

If you have questions about our privacy practices, this Privacy Policy, or wish to exercise your privacy rights, contact us at:

Company:HK RUNTOO TRADE CO., LIMITED
Address:ROOM 1009 10/F FRONT BLOCK MING SANG INDUSTRIAL BUILDING 19 HING YIP STREET KWUN TONG KL

Email:service@winuone.com