Up Way China Bullion Limited ("UPWAY") is a limited company established under the laws of the Hong Kong Special Administrative Region, and its successors or transferees, together with the contracting party ("Customer") to this document.:

Up Way China's Privacy Policy is designed to protect the interests of customers in accordance with the Personal Data (Privacy) Ordinance. When Up Way China uses customer data to provide the best service, it also pays great attention to the arrangements for the use of customer data. Up Way China will strive to fully comply with the requirements of personal data protection in accordance with the provisions of the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region. To this end, Up Way China will ensure that its employees comply with the rigorous security and confidentiality standards prescribed by law.

I. Summary of Privacy and Personal Information Protection

i） The various personal data collected by Up Way China are only used by Up Way China for business operations and other related activities;

ii） Up Way China is committed to ensuring that the website is secure and complies with industry standards, and uses other data protection tools, such as: firewalls, authentication systems (passwords and personal identification numbers, etc.) and control mechanisms to control unauthorized system access and access to data;

iii） Up Way China will keep customer personal data confidential to protect it from theft. Up Way China employees will also respect customer privacy and will never disclose any information to unauthorized persons;

iv） Customers may periodically review and change their personal data stored by Up Way China;

v） Customers agree that Up Way China will disclose all customer information (and other information) to regulatory authorities and other government agencies in accordance with any laws or regulations;

vi） Customers agree that Up Way China will disclose customer personal data to relevant institutions as proof of identity verification when customers make deposits and withdrawals through the payment gateway, in accordance with the arrangements of the network payment system policy;

vii） Up Way China may set and access cookies on the customer's computer to assist Up Way China in analyzing and understanding the effectiveness of its market promotion strategies. Up Way China and its employees may use cookies to track customer browsing on the Up Way China website for products and services, and the collected and shared data is anonymous and cannot be individually identified;

viii） Customers agree that when providing services to customer service, Up Way China may authorize some companies not affiliated with Up Way China to use customer personal data. These include companies that provide services to Up Way China in the form of contracts, such as companies that produce and mail monthly statements, software companies that maintain and develop data processing, etc. These companies authorized by Up Way China must keep customer personal data confidential.

II. This Privacy Policy Will Help You Understand the Following

1. How We Collect and Use Your Information

We collect and use your personal information for the purposes described in this Privacy Policy:
(1) You need to authorize us to collect and use your personal information.

i) Help You Become Our User
To become our user and enable us to provide membership services, we collect sensitive information such as your phone number to comply with the relevant legal requirements for online real-name system. If you only need basic services such as browsing, you do not need to register as our user or provide the above information.
During the registration process, you need to provide your name, ID number, phone number, bank card number, address, etc. However, if you do not provide this information, it will affect your online account opening process, but will not affect the basic browsing functions of using Up Way China platform services.
When you actively cancel your account, we will anonymize or delete your personal information as soon as possible in accordance with applicable laws and regulations.

ii) Information Collected During Service
To understand product adaptability, identify account abnormal states, we collect and associate information about the services you use and how you use them. This information includes:
(1) Log Information: When you use our website or client-provided Up Way China platform services, we will automatically collect detailed usage information about our services for network log retention. For example, your search queries, IP address, browser type, telecommunications operator, access date and time, and the web pages you visit records.

(2) Explanation of User Device Permissions

In order to ensure the normal operation of the APP and the normal provision of services, we need to obtain mobile device permissions including storage, device information, phone, camera, album, and microphone. Before obtaining these mobile permissions, the APP will clearly inform users of the purpose and scope of using the permissions. The use explanations of these permissions are as follows:

Storage Permissions: Used to save files required for the normal operation of "Up Way China", including temporary files for APP operation, log information; media files saved when users send voice or share. As you may need to select image files from the phone album in scenarios such as posting, changing avatars, and feedback, if you do not enable the corresponding permissions, you will be unable to select images in scenarios such as posting, changing avatars, and feedback, but it does not affect the use of other services we provide.

Mobile Device Information Permissions: To ensure the smooth implementation of various message notification functions during operation, we can provide you with notifications for important matters (such as activities, industry important announcements, system upgrades, etc.), service information notifications, interactive message notifications, and transaction information reminders. If you do not enable the corresponding permissions, it will affect the provision of notifications for important matters (such as activities, industry important announcements, system upgrades, etc.), service information notifications, interactive message notifications, and transaction information reminders, but it does not affect your use of other services we provide.

Phone Permissions: Used to ensure that you are not disturbed by making/receiving calls during operation and unable to restore the corresponding services.

Camera Permissions: Used to ensure that when you use functions such as setting avatar pictures and screenshot feedback, you need to enable camera permissions and/or album permissions (depending on the specific functions you use) so that you can take real-time photos or upload pictures/videos. If you do not enable the corresponding permissions, you will not be able to use specific functions related to real-time photography or image/video uploads, but it does not affect your use of other services provided by the APP.

Microphone Permissions: Used to ensure that users can use the microphone function when private messaging so that users can send voice messages. If you do not enable the corresponding permissions, you will not be able to use the smart voice function, but it does not affect your use of other services we provide.

Call Permissions: Used to ensure that you can directly call customer service or answer calls from staff without being interrupted during operation, thereby improving customer service efficiency. If you do not enable the corresponding permissions, it will affect answering questions and solving problems related to usage, account opening, certification, and transactions through timely phone calls, but it does not affect your use of other services we provide.

MAC Address Permissions: Used to remember your identity, analyze your use of our services, and optimize advertising delivery.

Location Permissions: You can enable location permissions to view or obtain services in your current area. If you do not enable this permission, you will not receive notifications based on your current location, but it does not affect your use of other services.

Read Clipboard: Used for data transmission, you can copy or move the content of documents to this "clipboard" within the application, providing you with the ability to copy and paste document content. And when you use the clipboard, we will obtain your source data to optimize advertising delivery.

Please note that individual device information, log information, etc., cannot identify specific individuals. If we combine such non-personal information with other information to identify specific individuals or use it in conjunction with personal information, during the combined use period, such non-personal information will be treated as personal information, and except with your authorization or as otherwise provided by laws and regulations, we will anonymize and de-identify such personal information. When you contact us, we may retain your communication/call records and content or the contact information you leave to contact you or help you solve problems, or record the processing plan and results of related issues.

V. How to Delete or Deactivate Your Personal Account

When you actively delete or deactivate your account, you can click on "My - More - More Business Handling - Investor Account Deactivation" to deactivate your account. There will be a 15-day freeze period after initiating the deactivation. If you log in to the account again during the freeze period, the account deactivation request will be canceled.

VI. How to Revoke Consent to the Privacy Agreement

You can contact us to revoke the consent agreement as long as there is no outstanding debt with the company. Up Way China Bullion Limited reserves the right to use customer privacy up to the revocation date. After a revocation, Up Way China Bullion Limited guarantees to stop using it. Note: Revoking consent to the privacy policy will result in the inability to use Up Way China Bullion Limited's product-related services.

VII. Authorization Terms

For advertising monitoring services, our products may integrate third-party SDKs or similar applications. Baidu Analytics SDK: It may need to collect necessary fields such as the International Mobile Equipment Identity (IMEI) of your device, iOS Advertising Identifier (IDFA), and phone number.

Baidu Internet Information Technology (Beijing) Co., Ltd. is our company's network promotion service provider. In order to improve and optimize the effectiveness of advertising delivery on the client side, it needs to collect your device attribute information (your hardware model, operating system version, device configuration, unique device identifier CUID, International Mobile Equipment Identity IMEI, MAC address of network device, Advertising Identifier IDFA, network connection type).
Privacy Policy Link: "Baidu Analytics Privacy Policy"

Umeng Notification SDK: It needs to collect your device information for message notification. Umeng (Beijing) Technology Co., Ltd. is our company's network promotion service provider. In order to provide better notification of key matters (such as activities, important industry announcements, system upgrades, etc.), it needs to collect your device identifier (IMEI/MAC/Android ID/IDFA/OPENUDID/GUID, SIM card IMSI information).
Privacy Policy Link: "Umeng Privacy Policy"

Tencent Bugly: In order to provide better crash monitoring, crash analysis, and other quality tracking services, it needs to collect your crash information and thread stack, ROM/RAM/SD card capacity, network/language, etc. App information: package name, version, process name, device information: IMEI and other device identification.
Privacy Policy Link: "Tencent Bugly User Agreement"

For your information security, we have agreed with third-party SDK service providers to strict data security and confidentiality obligations. These companies will strictly comply with our data privacy and security requirements. Without your consent, we will not share your other personal information with them.

VIII. Revision of This Policy

We may revise this privacy protection guideline from time to time. When the terms of the privacy protection guidelines change, we will notify you of the revised privacy protection guidelines and explain the effective date to you through notification prompts or other means during version updates. Please carefully read the content of the revised privacy protection guidelines. Your continued use indicates that you agree to us processing your personal information in accordance with the updated privacy protection guidelines.

IX. How to Contact Us

i) If you have any questions, opinions, or suggestions regarding this privacy policy or your personal information, please contact us through various methods such as visiting the online customer service system or calling any of our customer service numbers.

ii) Contact Address: 21/F, Nina Tower 2, 8 Yeung Uk Road, Tsuen Wan, N.T., Hong Kong

iii) Information Security Contact Phone: (+852) 23850868