Privacy Policy

1. Purpose and scope

UniBowl (also known as "we", "us", "UniBowl wallet", "UniBowl App", "our") is a digital payment company registered in Richmond, Canada and holding a Canadian MSB license. Its registered address is 150-10451 SHELLBRIDGE WAY, RICHMOND BC V6X 2W8, CANADA.

This policy contains important information about how we will collect and use your personal data. By using or accessing the website operated by UniBowl, including the UniBowl App and any services provided through the website, any related mobile applications and APIs, such as any related software, forums, blogs, social media pages, and other related platforms operated or maintained by UniBowl (collectively referred to as "Services"), you ("User") are deemed to have understood and agreed to all the terms and conditions of this policy. Please read and consider the terms of this policy carefully. If you do not agree to this policy, you must stop using the Services immediately.

If you continue to use any of the Services, you are deemed to have read and agree to be bound by this policy. We review this Policy regularly, please check this policy from time to time for the latest changes to ensure you are aware of the most recent version which will apply each time you use the Services.

If you have any questions about data processing, please contact our data protection officer via [email protected].

2. Controller of personal information

According to the Data Protection Law, UniBowl is the data controller responsible for processing your personal data related to the Services. In this context, the term "personal data" refers to any information that can be used to identify you personally (such as a combination of your name and postal address).

As the data controller, we have a responsibility to ensure the security of your personal data provided to us, especially to prevent unauthorized access to your personal data.

We are also responsible for ensuring that all users have the opportunity to enjoy the rights related to their personal data. When processing your personal data, we follow the following principles:

a) legality, fairness, and transparency: [we collect your personal data in a lawful and fair way for a purpose directly related to our Services, and notify you of the purpose of data collection and the class of persons to whom your data may be transferred];

b) purpose: [we collect your personal data for the purpose directly related to our Services, unless voluntary and explicit consent from you is obtained];

c) accuracy: [we strive to ensure your personal data is accurate];

d) data retention: [we retain your personal data only for as long as necessary to fulfil the purpose for which it is used];

e) security: [we take practicable steps to safeguard your personal data from unauthorised or accident access, processing, erasure, loss or use];

f) data access and correction: [you are given access to your personal data and to make corrections where the data is inaccurate].

3. What personal information we collect

• Equipment and technical information

We may collect information from your computer, mobile phone, or other devices you use, including but not limited to: your computer IP Address, device ID or identification code, device type, geographic location, mobile network information, website access traffic, standard network log data, and other information.

• Identity information

We may collect your identity information, such as your name, surname, personal identification code, date of birth, country of birth, address, nationality, citizenship, gender, passport and its details (such as type, number, place and date of issuance, valid period, etc.), address proof documents, bank statement proof documents, your facial visual scan or captured image or image provided by your mobile phone camera when using our recognition application, your IP address.

We may also collect your existing bank account details, such as Financial Institution account number, IBAN number; your financial information, such as wallet balance, encrypted transactions, and other similar transaction data; your account activity information, such as recent activities, account management, and historical transactions.

• Currency operation details

We may collect the currency operation details, for examples, currency, amount, location, date, time, currency, your IP address, payer and recipient names and registration information, messages and files sent or received with payment.

• Anti-fraud information

To avoid fraud, we may collect information about your transaction activity and your interactions when using our Services. To identify malicious software, we may evaluate your computer, mobile phone or other device.

• Other information

We may collect your feedback, such as information about your contact with our technical support team or information you complete in our surveys.

We may also receive information about you when our payment service providers settle payments on your behalf or from your bank in the event of a payment failure.

In order to provide personalized services, we provide extended functions. Under the premise of complying with legal provisions and your specific authorization, we will collect and use the following information in the specific functions and business scenarios you choose. If you choose not to provide it, it will not affect your use of UniBowl's basic functions.

1. Enabling the system camera permission means that you authorize UniBowl to use your camera for taking photos, scanning, and other operations, so that you can perform identity authentication, QR code payment, etc. You can also choose to disable this permission. After disabling it, you will not be able to use the above functions, but it will not affect your basic use of UniBowl.
2. Enabling the system album permission means that you authorize UniBowl to access your album to select and upload pictures, so as to recognize QR code address information. You can also choose to disable this permission. After disabling it, you will not be able to use the above functions, but it will not affect your basic use of UniBowl.

4. Third party personal information

We collect most of the personal data described in Section 3 directly from you.

However, we may also collect your personal information from third parties, including:

• [Recommend or nominate you as an existing UniBowl employee for our position.]
• Government authorities (such as local tax authorities);
• [You requested the designated recommender to provide us with a recommendation letter.]
• [Any third-party e-recruitment testing partner we work with.]
• [Third-party background screening providers, credit reference agencies, fraud prevention agencies, sanction screening, and crime conviction screening agencies, as permitted by law;] and other public sources, such as social media sites (such as LinkedIn, Instagram, and Twitter), as permitted by law.

5. Data related to criminal convictions and crimes

We also collect and store personal data related to criminal convictions and offenses where required and permitted by law. If we need to determine the legal basis for such processing, such processing will be carried out with your consent in accordance with local law to comply with our legal obligations or based on our legitimate interests (to ensure that we hire suitable candidates). This data will only be processed when necessary for the following purposes:

• Comply with or assist others in complying with regulatory requirements, which involve UniBowl taking measures to determine whether you have engaged in illegal activities or engaged in dishonesty, malfeasance, or other serious misconduct.
• Prevent or detect illegal activities (including fraud).
• Any legal proceedings (including potential legal proceedings);
• Obtain legal advice; or
• Establish, exercise, or defend legal rights.

6. Data sharing and disclosure

We may share your personal data with our subsidiaries and/or affiliates. We may also share your personal data with trusted third parties, including

• Our group company processes your application when necessary;
• Professional consultants (including lawyers, accountants, and auditors) when necessary.
• Legal and regulatory authorities (such as tax authorities) when necessary to fulfill our legal obligations.
• Our third-party service providers, including [our data hosting service provider, background screening check provider, and online recruitment testing service provider].
• Analytics and search engine providers who assist us in improving and optimizing our services.

Wherever your personal information is transferred, we will ensure the security of your personal information and will take all steps reasonably necessary to ensure that your personal information is handled securely and in accordance with this policy and applicable laws.

We will not provide your information for marketing purposes or for marketing companies.

In addition, we may disclose your personal information to third parties:

• If we sell or purchase any business or asset, in which case we may disclose your personal data to a potential seller or buyer of that business or asset.
• If we, our business, or our assets are acquired by a third party, in which case personal data we hold about our users, suppliers, or customers will be one of the transferred assets; and
• If we are responsible for disclosing or sharing your personal data to comply with any legal obligation, or to protect the rights, property, or safety of us, our users, our customers, or others, we are responsible for disclosing or sharing your personal data; or we have reason to believe that it is necessary to do so.

7. How we protect and store personal information

We will take reasonable measures to protect your personal data from loss or destruction. If you have a username or password (or other identifying information) that allows you to access certain Services or parts of our website, you are responsible for keeping that password confidential. We ask that you do not share your password with anyone.

Unfortunately, the transmission of information over the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the personal data you transmit to our website; any transmission risk is at your own risk. Once we receive your personal data, we will use strict procedures and security features to prevent unauthorized access.

If we share your personal data with any third party, we will take all necessary measures to ensure that the third party processes your personal data lawfully and securely.

We store your personal information through computer equipment and devices installed in other countries. To protect your information, we are committed to using various security technologies and supporting management systems to prevent your information from being leaked, tampered with, or damaged, such as firewall technology, information encryption storage, strict restrictions on data center access, and open information access authentication. Please understand that due to technical limitations and possible malicious tricks, we cannot guarantee that your personal information will not be leaked, tampered with, or damaged. Therefore, we encourage you to take sufficient preventive measures to protect your personal information.

Once a personal information security incident occurs, we will promptly inform you electronically. When you use our Services, you are deemed to agree that we communicate with you electronically. We will publish the personal information security incident in the application and send you an email notification through the email address you provided to us.

8. Your rights

In our use of your personal data, you have various rights:

• Access: You have the right to request a copy of your personal data held by us. Please note that there are exceptions to this right, for example, if providing you with information would disclose someone else's personal data, or if we are prohibited by law from disclosing such information, your right of access may be denied. You have the right to view your personal data. If you wish to view it, please contact us through the contact information below.
• Accuracy: Our goal is to keep your personal data accurate, up-to-date, and complete. If any of your personal data is inaccurate or changes, we encourage you to contact us through the contact information provided below so that we can timely update your personal data. You can also log in to your account on our website to view and correct/update some of your personal data.
• Object: In some cases, you also have the right to object to the processing of your personal data and request that we block, delete, and restrict your personal data. If you would like us to stop using your personal data, please contact us through the following contact information.
• Transfer: You have the right to request that some of your personal data be provided to you or another data controller in a commonly used, machine-readable format.
• Deletion: You have the right to delete your personal data when it is no longer needed for the purpose for which it was collected, or when it has been unlawfully processed.
• Complaint: If you believe that your data protection rights may have been violated, you have the right to file a complaint with the applicable supervisory authority or seek redress through the courts.

Please note that not all of these rights are absolute, and if applicable data protection laws provide for exemptions, we may not be required to comply with your request.

You can exercise these rights by sending an email to [email protected].

If we have reasonable doubts about the identity of the person making the request, we may request additional information necessary to confirm your identity.

We will do our best to respond to your request within [one month], and in any event within the time limit specified by applicable law.

9. How long we keep your personal data

We will retain your personal data for as long as is necessary to achieve the purposes stated in this policy or in the terms of any contract we enter into, or for as long as may be required by law. Thereafter, we will delete or anonymize your personal data where permitted by law and this policy. If you require any additional information in this regard, please contact us via [email protected].