PRIVACY POLICY

Last updated: 03/27/2019

 

CreditEase FinTech Investment Fund (“CEFIF”)  (“CEFIF”, or “we,” “us,” or “our”) provides the website located at www.cefintechfund.com (the “Website”). We respect the importance of your privacy, and we have created this Privacy Policy to set forth our privacy practices and policies.

 

For the purposes of European Union data protection laws ("Data Protection Law") and this Privacy Policy, CEFIF is a data controller (i.e., who is responsible for, and controls the processing of, your personal data). 

 

This policy applies to information we collect on this Website and in email, text and other electronic messages between you and CEFIF through or regarding this Website.  It does not apply to information collected by CEFIF offline or through any other means, including on any other website operated by CEFIF or any third party.

 

BY USING OR ACCESSING IN ANY WAY THE WEBSITE, YOU ASSENT TO THIS PRIVACY POLICY.

 

INFORMATION COLLECTION AND USE

When you use the Website, or when you correspond with CEFIF regarding the Website, we will collect or obtain certain personal information from you:

  • Personal Contact Information. We collect basic information about you (including your name, telephone number, time zone, type of computer you use and e-mail address) in order to be able to process and notify you about your request, to provide service and support, to operate and improve our business and services, and to communicate with you, including for marketing purposes.  For information about updating your communication preferences, please see “Promotional Communications” below.  We will share this information with third parties who provide services to us (“Service Providers”) who need it for these purposes.  We will not sell or provide this information to a third party for their own marketing purposes unless we obtain your consent.

  • Device and Usage Data. We use common information-gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information, which may contain details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website (behavioral tracking). We also collect information about your computer and Internet connection, including your IP address, operating system and browser type. For more detailed information, please see “Information Gathering Tools” below.

  • Evaluation and Feedback. From time to time, we may ask users of the Website to evaluate CEFIF or our services. The completion of this evaluation is at your discretion; if you choose to submit your evaluation to us, it will be used internally by CEFIF, and will be shared with our Service Provider(s) who process statistical information but not with any other third party unless otherwise provided in this Privacy Policy. If you provide us with your own comments about our services, we may use your comments in our marketing and promotional materials and/or on the Website only after you have given us permission to do so.

 

LEGAL BASIS FOR PROCESSING IN THE EUROPEAN UNION ("EU")

In the EU, the purposes for which we process your personal data are:

 

  1. the provision of personal data by you may be necessary for the performance of any contractual relationship we have with you;

     

  2. where it is necessary for compliance with our legal obligations as set forth in EU law;

     

  3. for our legitimate interests (this includes our own legitimate interests and those of other entities and branches in our group of companies) such as the following (provided these are not overridden by your interests and fundamental rights and freedoms):

     

a)     to contact you and respond to your requests and enquiries;

b)     for business administration, including statistical analysis;

c)     to provide the Website and any services to you; and

d)     for fraud prevention and detection; and

e)     to comply with applicable laws, regulations or codes of practices.

 

We may also process your personal data on the basis of your consent. You should be aware that you are entitled under Data Protection Law to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your personal data, this may adversely affect your ability to access and use the Website.

 

INFORMATION GATHERING TOOLS

As is true of most websites, CEFIF and our Service Providers gather certain information automatically through the Website and store that information as a web browser cookie or in log files. This information includes internet protocol (IP) addresses, browser type, Internet service provider (ISP) information, referring/exit pages, operating system information, date/time stamps, clickstream data, and Website user login information. We and our Service Providers use this information, which does not identify individual users, to analyze trends, to administer the site and services, to track users’ movements around the site and services, and to gather demographic information about our user base in aggregate. We do not link this automatically-collected data to personally identifiable information. We use third-party tracking services called Google Analytics that may use cookies, flash cookies and web beacons to track non-personally identifiable information about visitors to our site in the aggregate for marketing research purposes. The non-personal information we automatically collect is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and deliver a better and more personalized service, including by enabling us to:

 

  • Estimate our audience size and usage patterns.

  • Store information about your preferences, allowing us to customize our Website according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to our Website.

 

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

  • Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

 

PROMOTIONAL COMMUNICATIONS

We may contact you with special offers, promotional deals, newsletters, other marketing announcements regarding CEFIF and our service offerings. If you wish to opt-out any such promotional communications, simply contact cefintechfund@creditease.cn or select the “unsubscribe from email” located at the bottom of the email you received from CEFIF.

 

INFORMATION SHARING AND DISCLOSURE

  • Service Providers.  CEFIF uses Service Providers to perform certain of the technical processing, administration and support of the Website and services.  Such Service Providers generally are permitted to use and disclose your personally identifiable information only as provided in this Privacy Policy.  However, with respect to certain services, some Service Providers may have their own privacy policies that will apply to their use or disclosure of your information obtained through those services.  You will be notified of any other privacy policies or terms when you sign up for these services.

 

  • Others.  CEFIF and its Service Providers reserve the right to disclose information about you, including the content of your communications through the Website, in order to:  (a) comply with the law or respond to lawful requests or legal process; (b) protect the rights or property of CEFIF, its providers, suppliers and licensors or other clients or third parties; or (c) act on a good faith belief that such access or disclosure is necessary to protect the personal safety of CEFIF, its providers, suppliers and licensors or other clients or third parties.

 

INFORMATION RETENTION

CEFIF will retain your personal information as needed to (a) fulfill the purposes for which it was collected or obtained, (b) comply with our business requirements or legal obligations, (c) resolve disputes, (d) protect our assets and interests, and (e) enforce our rights and agreements.

 

For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data, except if required otherwise by law.

 

LINKS TO OTHER SITES

The Website contains links to third party sites that are not owned or controlled by us. We are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information.  In addition, certain Service Providers may have their own privacy policies that will apply to certain services, as described above.

 

SECURITY

We take precautions including organizational, technical, and physical measures, to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the personal information we process or use. While we follow generally accepted standards to protect personal information, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our websites, please email us at cefintechfund@creditease.cn.

 

BUSINESS TRANSITION

In the event that CEFIF goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information will likely be among the assets transferred.  CEFIF does not guarantee that any entity receiving such information in connection with one of these transactions will comply with all terms of this policy.

 

CONSENT TO TRANSFER AND PROCESSING

Personal information collected through the Website and/or its services may be stored and processed in the United States or in any other country in which CEFIF or its providers (or its or their affiliates or providers) maintain facilities.  By using the Website and/or its services, you consent to any such transfer and processing of information outside of your country.   We will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy. Such transfers are made pursuant to appropriate safeguards. If you wish to enquire further about these transfers, please contact us using the details set out at the end of this Privacy Policy.

 

CONSENT TO ELECTRONIC COMMUNICATIONS

By using the Website or otherwise providing personal information to us, you agree that we may communicate with you electronically (including by posting a notice on the Website or by sending you an email) regarding security, privacy and administrative issues relating to such use, including but not limited to notifying you of a security breach.

 

YOUR CALIFORNIA PRIVACY RIGHTS

Under California Civil Code Section 1798.83, California residents have the right to request from companies conducting business in California a list of third parties to whom the companies have disclosed, during the preceding calendar year, your personal information for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.

 

CEFIF qualifies for the alternative option. We have a comprehensive privacy statement, and provide you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.

 

If you are a California resident and have any questions about how to exercise your third party disclosure choices, you may contact us by sending us an email at cefintechfund@creditease.cn.

 

FOR RESIDENTS IN THE EU AND SWITZERLAND

If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:

 

  1. Right to object. YOU HAVE A RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION. YOU CAN OBJECT TO MARKETING ACTIVITIES FOR ANY REASON WHATSOEVER.

 

  1. Right of access. The right to obtain access to your personal data.

 

  1. Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.

 

  1. Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.

 

  1. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.

 

  1. Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.

 

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.  Please note that if you do exercise one of these rights, your ability to access or use the Website may be impaired.

 

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

CHILDREN’S PRIVACY

If you are under the age of 13, please do not use or access the Website in any way.  We will not knowingly collect or use any personal information from any children under the age of 13.  If we become aware that we have collected any personal information from children under 13, we will promptly delete such information from our databases.

 

TERMS OF USE

Your use of the Website is governed by our then-current Terms of Use: http://www.cefintechfund.com/Index/tree/id/31 


CHANGES TO THIS POLICY

CEFIF may update this Privacy Policy from time to time, and when we do, we will also revise the “last updated” date at the top of this Privacy Policy.  If we consider any change to this Privacy Policy to be material, we will place a prominent notice on the Website or we may notify you directly by e-mail, at our discretion.  Changes are effective upon posting to the Website, unless we say otherwise in our notice, so please check this site often for changes.

 

UPDATING YOUR INFORMATION; QUESTIONS

Please feel free to contact us at cefintechfund@creditease.cn, to assist in updating your personal information or if you have any questions regarding this Privacy Policy.


HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Website, please contact us at cefintechfund@creditease.cn.