Mainland China(中国内地)
Privacy Policy of E Fund Management Co., Ltd.
Date of release of this version: June 26, 2023
Effective date/date of update of this version: June 26, 2023
E Fund Management Co., Ltd. (hereinafter referred to as “we” or “us”) respect and protect the privacy of users (hereinafter referred to as “you”). When you use E Fund Services (as defined below), we will collect, store, use and provide your Personal Information in accordance with this Customer Privacy Policy of E Fund (“this Privacy Policy” or “this Policy”).
We suggest that you read this Policy carefully before using our services and confirm that you have fully understood all content of this Policy, especially the content to which we remind you to pay special attention by making the content bold or other ways. By checking the relevant box on the page, clicking Confirm, agreeing in writing, or opening an account with E Fund, actually using E Fund Products or indicating your confirmation in other ways, You agree to the provisions of this Privacy Policy and agree that We may process your Personal Information in accordance with the provisions of this Privacy Policy, including but not limited to agreeing that E Fund, its affiliates and relevant partners may collect, store, use and provide your Personal Information in accordance with the requirements of this Privacy Policy; and send financial product or service marketing information, activity notice and other commercial information to You (if You do not want to receive such information, You may choose to unsubscribe by the method We suggest). Please be aware that, depending on the types of services we provide, we may collect and use different types of your Personal Information.
If you do not agree to or do not understand part or all of the content of this Privacy Policy, You should immediately stop using the E Fund Services and contact us through the contact information set out in Article 12 of this Privacy Policy.
This Privacy Policy will help you understand the following:
1. How we collect information
2. How we use information
3. How we provide information to external entities
4. How we store information
5. How we protect information
6. Cookie and other technologies
7. Your rights
8. Governing law and dispute resolution
9. Revisions to this Privacy Policy
10. How you can contact us
We are deeply aware of the importance of Personal Information to You and will use our best efforts to protect the security of your Personal Information. We are committed to maintaining your trust in Us and protecting your Personal Information in strict compliance with the principle of alignment between rights and responsibilities, the principle of clear purposes, the principle of voluntary consent, the principle of collecting and processing the least information that is enough, the principle of ensuring safety, the principle of subject participation, the principle of openness and transparency, etc. Meanwhile, we undertake to take corresponding security protection measures to protect your Personal Information according to mature security standards in the industry.
Article 1 Definitions
To help you better understand this Privacy Policy, some terms used in relevant clauses are explained as follows:
1. Personal Information shall refer to all kinds of information electronically or otherwise recorded that relates to any identified or identifiable natural person, excluding Anonymized information.
2. Sensitive Personal Information shall refer to Personal Information that, once leaked or illegally used, can easily lead to violation of human dignity of the natural person concerned or endanger personal or property safety of the natural person, including biometric authentication, religious belief, specific identity, health care, financial account, whereabouts and travel path information, and Personal Information of minors under the age of fourteen.
3. Cookie shall refer to a mechanism that enables a server (or script) to store and retrieve information on the client side, extending Web-based client/server applications by adding a simple, persistent, client-side state. A server, when returning an HTTP object to a client, also sends a piece of state information which the client will store. Included in that state object is a description of the range of URLs for which that state is valid. Any future HTTP requests made by the client which fall in that range will include a transmittal of the current value of the state object from the client back to the server. The state object is called a Cookie.
4. De-identification shall refer to the process in which Personal Information is processed so that the specific natural person concerned cannot be identified from such information without the help of additional information.
5. Anonymization shall refer to the process in which Personal Information is irreversibly processed so that the specific natural person concerned cannot be identified from such information.
6. We or E Fund shall refer to E Fund Management Co., Ltd.
7. E Fund Affiliates shall refer to the enterprises in which E Fund Management Co., Ltd. directly or indirectly holds a controlling or non-controlling interest, such as E Fund Asset Management Co., Ltd., E Fund Private Fund Management (Shanghai) Co., Ltd., and E Fund Management (Hong Kong) Co., Limited.
8. E Fund Platforms shall refer to the service platforms operated by E Fund, including but not limited to the official website of E Fund (website address: www.efunds.com.cn), its mobile application (name: “E Fund e Wallet”), We Chat Official Account (name: “E Fund Wealth”), We Chat Mini Program (name: “E Fund Easier Services”), and other service pages, etc., online service platforms which, through connection to the systems of partners of E Fund (including but not limited to using any links that jump to H5 pages, application programming interface (API) or software development kit (SDK) or prepositioning front-office business system), enable You to directly or indirectly access E Fund’s information system for queries, provide You with information on E Fund Products, related services and market trends, and provide information management and technical support for product investments, transaction and information management and queries, transaction settlement (provided by legally qualified institutions) and other activities carried out through E Fund’s partners. The specific website addresses are as shown below:
1) www.efunds.com.cn
2) https://e.efunds.com.cn
4）https://vip.efunds.com.cn
If E Fund announces or otherwise discloses a new website, please log in to the new website.
9. E Fund Products shall refer to the products issued and managed by E Fund as the manager in accordance with relevant laws and regulations, or the mutually recognized funds or other products sold by E Fund as the Chinese mainland agent.
10. E Fund Services shall refer to the information display, product sale, product trading, trading assistance, investment consulting, information management, technology support and other services provided by E Fund to You through the E Fund Platforms or in other ways on the basis of the service agreements signed with You (such as the Service Agreement of E Fund Management Co., Ltd. on Online Trading of Open-ended Securities Investment Funds).
11. E Fund Partners shall refer to relevant service institutions that provide You with account opening, product promotion and sale, asset custody, transaction payment, information technology and other services based on E Fund Services in accordance with laws and regulations or agreements, including but not limited to E Fund Affiliates and other related parties, fund sales institutions, custodian institutions, payment institutions, technical service institutions and other third-party service institutions that possess relevant business qualifications.
Article 2 Scope of Application
This Privacy Policy will be applicable when you use the following E Fund Services (but the specific scope of application may vary with the scope of our services):
- When you use the E Fund Platforms;
- When you buy our products;
- When you use the services we provide.
The E Fund Platforms may contain links to other websites. We will, in accordance with laws, regulations and regulatory requirements, take reasonably practicable measures when necessary to review relevant websites (including reviewing the basic qualifications of website operators, reasonably and preliminarily identifying the security status of relevant websites through technical means, and urging such website operators to protect the security of your Personal Information in accordance with the law, etc.). However, we cannot guarantee that the operators of such linked websites will take protective measures as required by us. We recommend that you review the privacy policies of such linked websites in advance to learn about how they process your information so that you can make prudent decisions.
Article 3 How We Collect Information
In the process of your use, you allow and authorize us to collect from you or collect through E Fund Affiliates or E Fund Partners information provided or generated in the process of or as a result of your use of the services, in order to provide you with services, optimize our services, ensure the security of your accounts, etc.:
1. Circumstances in which information needs to be collected according to laws, regulations or self-regulatory guidelines or to perform corresponding obligations
(1) Circumstances in which information needs to be collected for your purchase of E Fund Products or use of E Fund’s sales services
To comply with laws, regulations or regulatory requirements related to fund sales, anti-money laundering efforts, counter-terrorist financing efforts, due diligence on tax-related information on non-residents’ financial accounts, user identification, real-name system for accounts, etc., when You access services of registration, account opening, password recovery, account settings, feedback, as well as transaction-related services, We need to collect your relevant Personal Information directly from You or through E Fund Affiliates or E Fund Partners, including name, gender, date of birth, nationality, occupation, domicile or employer address, contact information (landline phone number, mobile phone number and email address), type, number, validity period and photocopies of the identity certificate or other proof of identity (herein referring to ID Card, household register, Chinese passport, military officer certificate, soldier certificate, civilian cadre certificate, police officer certificate, Mainland Travel Permit for Hong Kong and Macao Residents, Mainland Travel Permit for Taiwan Residents, Hong Kong, Macao or Taiwan residence permit, foreign passport, permanent residence certificate for foreigners or other valid certificates), educational attainment, tax resident status, actual beneficiaries and controllers, whether there is any record of dishonesty, and other information prescribed by laws and regulations, regulatory requirements and industry self-regulatory guidelines. The foregoing information shall be collected through your voluntary provision or the lawful provision by E Fund Affiliates or E Fund Partners. If You do not provide the foregoing information, We may be unable to complete the corresponding obligations under laws, regulations and self-regulatory guidelines related to anti-money laundering efforts, counter-terrorist financing efforts, due diligence on tax-related information on non-residents’ financial accounts, user identification, real-name system for accounts, etc., and thus be unable to provide You with services.
For performance of the investor suitability obligations and qualified investor accreditation, when You access services of registration, account opening, account settings, as well as transaction-related services, We need to collect your relevant Personal Information from You or through E Fund Affiliates or E Fund Partners, including name, address, occupation, age, contact information, your financial standing (source(s) and amount of income, assets and debts), you’re learning and working experience related to investment and your investment experience, investment objectives (investment horizons, types of investments and expected returns), your risk appetite, risk tolerance, investment preferences, planned investment horizons, the proportion of investments in financial products in total assets, the proportion of salary that can be saved or invested, your integrity record, and other information prescribed by laws, regulations, regulatory requirements, and industry self-regulatory guidelines. The foregoing information shall be collected through your voluntary provision or the lawful provision by E Fund Affiliates or E Fund Partners. If you do not provide the aforesaid information, we may be unable to complete the corresponding qualified investor accreditation and thus be unable to provide you with services.
In order to provide you with product sales services, according to the provisions of laws, regulations and self-regulatory guidelines, we need to manage the transaction information generated during your transactions. For this purpose, We need to collect information related to your transactions from You or through E Fund Affiliates or E Fund Partners, including the transaction number, names of the two parties to the transaction, transaction amount or shares traded, transaction time, product name, product code, payment method, settlement account information, and other information prescribed by laws, regulations, regulatory requirements, and industry self-regulatory guidelines. The foregoing information shall be collected through your voluntary provision, system generation, or the lawful provision by E Fund Affiliates or E Fund Partners. If you do not provide the aforesaid information, we may be unable to provide you with the corresponding product sales services.
(2) Circumstances in which additional information needs to be collected for your use of our investment advisory services
When You use the investment advisory services provided by E Fund, according to laws, regulations and self-regulatory guidelines, in addition to the customer information mentioned in (1) above, We need to collect from You or through E Fund Affiliates or E Fund Partners information needed for Us to judge your risk identification ability, risk tolerance, investment objectives, etc., including investment experience, risk preferences, source(s) and amount of income, financial standing, investment horizons, investment objectives, and expected returns related to the investment advisory business, as well as information related to your transactions, including the transaction number, names of the two parties to the transaction, transaction amount or shares traded, transaction time, product name, product code, payment method, settlement account information, transaction records, and other information prescribed by laws, regulations, regulatory requirements, and industry self-regulatory guidelines. The foregoing information shall be collected through your voluntary provision, system generation, or the lawful provision by E Fund Affiliates or E Fund Partners. If you do not provide the aforesaid information, we may be unable to provide you with the corresponding investment advisory services.
(3) Circumstances in which additional information needs to be collected for your use of the funds transfer service
When You link a bank card of yours to your fund trading account or transfer to our account funds paid for fund sales, We need to collect your relevant information from You or through E Fund Affiliates or E Fund Partners, including bank card information, such as name, bank card number, type and number of the identity certificate or other proof of identity, mobile phone number notified to the bank, bank card photocopies, and other information prescribed by laws, regulations, regulatory requirements and industry self-regulatory guidelines. The foregoing information shall be collected through your voluntary provision or the lawful provision by E Fund Affiliates or E Fund Partners. If you do not provide the aforesaid information, we may be unable to conduct verification and link the bank card to your account or process your corresponding fund subscription/purchase application and thus be unable to provide you with the corresponding funds transfer service.
(4) Circumstances in which additional information needs to be collected for your use of services such as ownership transfer not related to transactions and revision of account information
When You use services such as ownership transfer not related to transactions and revision of account information, We need to collect your relevant business information from You or E Fund Affiliates or E Fund Partners, including notarial documents, legal documents, mediation agreements, court-issued confirmation documents, proof of change, and other information prescribed by laws, regulations, regulatory requirements and industry self-regulatory guidelines. The foregoing information shall be collected through your voluntary uploading or the lawful provision by E Fund Affiliates or E Fund Partners. If you do not provide the aforesaid information, we may be unable to provide you with the corresponding services such as ownership transfer not related to transactions and revision of account information.
2. Information that You authorize E Fund to collect when You use services of E Fund
To improve the stability and security of our services You use, protect the security of your account and funds, identify You, conduct security and fraud detection, prevent transaction and funds risks, and prevent viruses, Trojans or other malicious programs and websites, We need to receive and record information related to each device You use, including device identification information (MAC, Android ID, IDFV, and ad tracking ID), device attribute information (device brand and model, device screen specifications, operating system version, device settings, list of applications installed, and information on other hardware and software features), device connection information (IP address, browser type, telecom operator, language used, date and time of access, and records of web pages requested by you) and information on use of functions (page clicking frequency, dwell time, and access path). The foregoing information shall be collected by reading the information on your device with your authorization. If you do not provide the aforesaid information, verification of security of the transaction environment may be affected, the security of your account, funds and services may not be guaranteed, and there is also the risk of funds loss.
The device identification information may be used for a variety of purposes, including security and fraud detection, synchronization service (such as the user’s email inbox), and recording of the user’s preference settings. We may associate the information collected from your devices so that we can provide you with consistent services on your devices. If you have any question regarding this, you may contact us through the E Fund Platforms or the contact information provided in this Privacy Policy.
When you participate in an activity organized by E Fund, We need to collect your relevant information from you or through E Fund Affiliates or E Fund Partners, including name, type and number of the identity certificate or other proof of identity, mobile phone number, bank card number and address. The foregoing information shall be collected through your voluntary provision or the lawful provision by E Fund Affiliates or E Fund Partners. If you do not provide the aforesaid information, we may be unable to provide you with the corresponding rights and interests related to the activity.
To download the proof of assets and statements, you need to provide us with your email address so that we can send you the documents you require. You shall enter the email address on your own initiative or use the email address you previously entered.
When you log in to E Fund Platforms, You may choose the mobile phone number login, certificate number login, gesture login, fingerprint login and face swiping login services provided by us. Different login methods require you to provide the corresponding information to log in to E Fund Platforms:
(1) When you log in using your mobile phone number, you need to provide us with your mobile phone number and login password through your voluntary entry for verification.
(2) When you log in using your identity certificate number, you need to provide us with your identity certificate number and login password through your voluntary entry for verification.
(3) You can opt to enable the gesture password function. After enabling such function, when you log in to E Fund e Wallet APP, You need to use your gesture password for verification. You may disable the gesture password login function through “Security Center - Login Management - Gesture Password” in E Fund e Wallet app. Disabling this function will not affect your normal use of other functions or services of E Fund e Wallet app. You need to set the gesture password proactively, which will be saved on your device after being collected.
(4) After enabling the fingerprint login/face swiping login function, You may disable the gesture password login function through “Security Center - Login Management - Fingerprint Login/Face Swiping Login” in E Fund e Wallet app. Disabling this function will not affect your normal use of other functions or services of E Fund e Wallet app. We will not collect your fingerprints.
When You use the transaction password recovery, login password recovery, and mobile phone number change functions of E Fund Platforms, You may choose to recover and change your password after completing identity authentication through the mobile phone number/email address previously notified for the account, account transaction information, bank card authentication or facial verification or by contacting the customer service staff for authentication. When you use the mobile phone number change function of E Fund Platforms, You may change your mobile phone number after completing identity authentication through the mobile phone number previously notified, bank card authentication, or facial verification. To protect the security of funds in your account and make sure that the requests for password identification and recovery and mobile phone number change are made by you, different authentication methods require you to provide different information. The information set forth below shall be provided through your voluntary entry:
(1) For authentication through the mobile phone number/email address previously notified for the account, You need to provide your name, type and number of your identity certificate or other proof of identity and mobile phone number/email address previously notified, and complete the identity authentication through the SMS verification code/by email;
(2) For authentication through the account transaction information, You need to provide your name, type and number of your identity certificate or other proof of identity, account number and account transaction information to complete the identity authentication;
(3) For authentication through bank card authentication, You need to provide your name, type and number of your identity certificate or other proof of identity, bank card number, mobile phone number previously notified to the bank and the SMS verification code to complete the identity authentication;
(4) For facial verification, You need to provide your name, type and number of your identity certificate or other proof of identity, and facial information related to facial verification;
(5) If You contact customer service staff for authentication, You need to provide your name, type, number and a photocopy of your identity certificate or other proof of identity, a photo in which your hold your identity certificate in your hand, and other information required by laws, regulations, regulatory requirements and industry self-regulatory guidelines.
3. Information and permissions which you may select whether to grant when you use services of E Fund
To enable you to use the services of E Fund more conveniently and smoothly, the functions we currently provide or may develop in the future may collect and use your Personal Information, and you may select whether to grant us the following permissions:
(1) Webcam (camera)-based functions: You may use identity authentication, bank card identification, ID card identification, facial verification, online customer service, function suggestion, and feedback services.
(2) Album-based functions: You may enable the album function so that You can store the photo taken in your device and then upload it or directly select a photo from the album and then upload it when You use the image upload, image saving, bank card and ID Card identification, online customer service, function suggestion, and feedback functions.
(3) Location-based functions: You may enable the location service, which enables you to more conveniently fill in your address information and enhances the security of your personal account.
(4) Address book-based function: You may import the contact information in the address book when using payment services provided by payment institutions which are partners of E Fund or recommending services provided by E Fund or E Fund Partners to your friends. By enabling this function, you don’t need to manually fill in the aforesaid information.
(5) Fingerprint/face-based functions: You may grant the permission to invoke the fingerprint and facial verification system of the device you use to help E Fund Platforms complete personal identification, login and authentication instruction-related operations.
(6) Storage permission-based functions: You may grant the permission to enable the storage permission so that You can store the photo taken in your device and then upload it or directly select a photo from the album and then upload it when You use the image upload, bank card and ID Card identification, online customer service, function suggestion, and feedback functions.
(7) Device status: Such information is used to determine the device identification number (IMSI, ICCID, IMEI, or Sim Serial Number) to ensure login security of account login.
(8) Network status information: Such information is used to optimize network communication with the server (SSID, BSSID, and base station information) and check the network status to ensure the security of account login.
(9) Clipboard reading: To enable you to copy and paste the SMS verification code instead of manually entering the verification code, we will read the SMS verification code you copy to the clipboard.
(10) User behavior analysis: We will collect the following information of yours in order to help solve the faults of your device that result from use of the E Fund Platforms, provide device troubleshooting and diagnosis services and perform statistical analysis of data so as to ensure the normal functioning and update of the E Fund Platforms and further improve your user experience: Page addresses/functions accessed by the user, time of access, IP address, mobile phone information, browser information and mobile phone model. The aforesaid functions may require you to grant us the permission to access the webcam (camera), album, geographical location (location), address book and other functions in your device so as to collect and use the information that such functions involve. By confirming and agreeing to enable the aforesaid permissions, you authorize us to collect and use such information to enable the aforesaid functions.
You may also refuse to grant the permissions or follow the instructions from the operating system of the device you are using to turn off the corresponding permissions. In this case, we will no longer collect and use such information about you, and will be unable to provide you with the functions corresponding to the permissions. However, this will not affect your use of the basic functions and services of the E Fund Platforms, or your use of other services provided by E Fund.
4. Permit us to collect information from third parties
When You trigger, apply for or use services of the E Fund Partners through the E Fund Platforms, to cooperate with the E Fund Partners in timely updating your information (including identity authentication and risk assessment information) or lawfully completing real-name management and investor suitability management of You and to fulfill the anti-money laundering requirements and requirements for due diligence on tax-related information on non-residents’ financial accounts, We will collect the Personal Information that You provide to E Fund Partners for identity authentication (if applicable), bank account linking (if applicable) and risk assessment (if applicable), including account information, risk assessment information, transaction information (including names of financial institutions providing the products traded, names of the products traded, amount of the products traded, and information on the product transaction history), education background, phone number, address, email address, occupation, company name and address, income, personal financial or accounts information and information related to your credit performance that are obtained from You, and other information prescribed by laws, regulations, regulatory requirements and industry self-regulatory guidelines. We will use a reasonable mechanism to review whether such institutions can lawfully provide us with such information.
When You interact with the E Fund Affiliates or E Fund Partners to use the E Fund Services, or use related products or services provided by the E Fund Affiliates or E Fund Partners, in order for Us to jointly provide You with services, carry out cross-verification of information and improve service quality and user experience, You allow and authorize Us to, to the extent permitted by law, collect your Personal Information related to the E Fund Services which is retained or generated by the E Fund Affiliates or E Fund Partners when You use the products or services provided by the E Fund Affiliates or E Fund Partners. Unless otherwise required by laws and regulations or otherwise required by regulators, the E Fund Affiliates and E Fund Partners may provide us with your relevant information collected and stored by such institutions. We will use a reasonable mechanism to review whether such institutions can lawfully provide us with such information.
In order to enable Us to accurately assess and prevent the compliance risks of doing business with Yuan prevent illegal activities, You allow and authorize Us to inquire about and verify the information related to your use of the E Fund Services by ourselves or through professional data service providers or other third-party institutions We partner with, and to view, collect, use and retain the verification and validation results obtained.
5. Third-party access management
In order to enable You to receive the push message, log in to the third-party platforms, share on third-party platforms the Personal Information uploaded or generated when You use the E Fund Platforms, use the map service, use the facial verification service and use the bank card services, optimize the pages browsed, and enhance the security capability and other functions, SDKs or other similar applications of licensed partners are embedded in the E Fund Platforms (especially the mobile application).
The aforesaid SDKs or other similar applications may request collection of relevant information about you, and have already configured information collection functions within the relevant programs. In normal circumstances, we will transmit De-identified Personal Information in accordance with laws and regulations to ensure the security of your Personal Information. With respect to the third-party programs embedded, We will use reasonable assessment procedures, such as conducting security tests and signing agreements, to ensure that the third-party products or services embedded (such as software tool development kits (SDKs) and application program interfaces (API)) take appropriate confidentiality and security measures to transmit and process your Personal Information.
For details concerning transmission of Personal Information by the embedded third-party codes and add-ins, please refer to the List of Third-party SDKs Embedded in E Fund Platforms, a schedule to this Privacy Policy. Please note that the counterparties to the transactions you conduct, the operators of the third-party websites you visit, the third-party services accessed through the E Fund Platforms and the third parties receiving your Personal Information from E Fund may have their own privacy policies. When you view web pages created by third parties or use applications developed by third parties, the third parties may place their own Cookies or web beacons. Such Cookies or web beacons are beyond our control and the use of them is not subject to this Policy. We recommend that you contact them for details about their privacy policies. If you find that web pages created by third parties or applications developed by third parties pose risks, we recommend that you terminate relevant operations to protect your legitimate rights and interests.
6. Processing of Sensitive Personal Information
When you use the E Fund Services, We may collect and process your Sensitive Personal Information in accordance with relevant laws, regulations, regulatory rules, and business needs and this Privacy Policy. The aforesaid content in bold specifies the Ssensitive Personal Iinformation we will collect and the purposes for which it will be collected. If You do not agree to the collection of such Sensitive Personal Information, We may be unable to deliver the corresponding services or functions. Your agreement to this Privacy Policy and the Authorization for Sensitive Personal Information during your use of the E Fund Services means that you agree to our processing of the aforesaid Sensitive Personal Information.
If We need to collect from You and process other Sensitive Personal Information that is not specified in this Privacy Policy, We will, in accordance with requirements of applicable law, lawfully inform You of the purpose for which We collect your Sensitive Personal Information, the method by which such information will be processed, and other information legally required to be informed, and seek your separate consent.
Article 4 How We Use Information
In order to enable us to do better in providing you with safe, smooth and efficient services, and ensure that our risk prevention and control capabilities can protect your and our legitimate rights and interests, you allow and authorize us to use your information for the following purposes:
(1) To achieve the purposes described in Article 3 of this Privacy Policy, “How We Collect Information”, or the purposes directly or reasonably related to such purposes;
(2) To provide You with good user experience and services and send service status notifications to You when You use the E Fund Services; if You do not need the E Fund Platforms to push relevant information, You may contact the E Fund Platforms to cancel or unsubscribe the information push service; All information We use is E Fund’s own data, and We do not push information from third parties to you;
(3) You allow and authorize E Fund and the E Fund Affiliates to, in light of your risk tolerance, past purchases and other factors and in accordance with regulatory requirements, invite you to learn about the products, services and activities suitable for you through push service. If You do not want to receive such information, You may choose to unsubscribe by the method We suggest (for example, email, SMS, WeChat and other services can be unsubscribed in the E Fund Online Trading -> Account Management -> Information Settings module; the push service of an app can be turned off by clicking “My - Service Center - Function Settings - Push Notification Settings” in the app);
(4) To prevent, detect and investigate frauds, security hazards, illegal behaviors or violations of agreements with Us, our policies or rules so as to protect your or our legitimate rights and interests or the legitimate rights and interests of our other users;
(5) To assess your credit standing and risk tolerance;
(6) We may combine the information from a certain service with the information from E Fund, the E Fund Affiliates or third-party partners to provide You with better services, content and suggestions;
(7) To collect from you all kinds of fees payable (if any);
(8) To make it easier for You to learn about our activities, when You use the services of E Fund, We may push activity information to You based on the account information you previously reserved; if You do not want to receive such messages, You may contact Us through the contact information provided by the E Fund Platforms;
(9) To comply with the information disclosure requirements of any laws, regulations and other regulatory provisions binding on us.
When We intend to use your information for other purposes or uses not specified in this Privacy Policy, We will inform You again and seek your prior consent; however, pursuant to relevant laws, regulations and national standards, We may lawfully collect and use your Personal Information without your consent in the following circumstances:
(1) Such acts are necessary for the conclusion and performance of a contract to which you are a party;
(2) Such acts are necessary for performance of statutory responsibilities or obligations of E Fund;
(3) Such acts are necessary to respond to a public health emergency or protect your life, health and property in an emergency;
(4) We may reasonably process your Personal Information for news reporting, supervision of public opinions or other activities conducted in the public interest;
(5) We may, in accordance with regulations, reasonably process the Personal Information about You that has been publicly disclosed by you or otherwise lawfully disclosed publicly;
(6) Other circumstances prescribed by any law or administrative regulation.
Article 5 How We Provide Information to External Entities
1. Sharing
We undertake to keep your information confidential in accordance with relevant laws, regulations and regulatory provisions. We will share your information with third parties (including competent authorities, regulators, self-regulatory organizations, our affiliates or partners, etc.) as required by laws, regulations or regulators, as necessary to provide services to You, or upon your authorization. Before sharing the information, we will conduct a commercially reasonable review of the third parties, assess the lawfulness, legitimacy and necessity of the collection of information by them, and urge them to process your information in accordance with legal provisions and relevant regulatory requirements. If the aforesaid conditions are met and, pursuant to laws and regulations, relevant legal documents need to be signed, We will sign relevant legal documents with the third parties and require the third parties to use your Personal Information complying with laws and regulations and use our best efforts to require the third parties to take measures to protect your information.
In order to enable Us to provide services to You, You allow and authorize Us to share your information with the E Fund Affiliates, E Fund Partners or other third parties (such as sales agencies, banks and third-party payment institutions) in the following circumstances:
(1) When your trigger, apply for or use the services of the E Fund Partners, to enable You to establish a service relationship with the E Fund Partners, complete the transaction procedures and achieve the goals of trading, You allow and authorize Us to provide the partners with your identity information, information on the linked card (bank card number and mobile phone number), account information and other Personal Information which needs to be collected to achieve the purposes specified in this article, except Personal Information prohibited by laws, regulations and regulatory requirements from being provided;
(2) Your Personal Information may be shared, stored and used within E Fund and the E Fund Affiliates in order to fulfill the requirements of laws, regulations and self-regulatory guidelines. Such sharing is bound by the purposes stated in this Privacy Policy. The scope and circumstances of such sharing will depend on the specific business situation, including submitting statistical information to regulators as required, overall risk management needs, anti-money laundering efforts, anti-fraud efforts, counter-terrorist financing efforts, due diligence on tax-related information on non-residents’ financial accounts, user identification, real-name system for accounts, investor suitability management, qualified investor accreditation, provision of services for You, etc. You allow and authorize Us to share your identity information, account information, risk assessment information, information concerning qualified investor accreditation, transaction information, asset information, contact information and other relevant information We have collected with the E Fund Affiliates to the extent necessary, or submit the same to competent authorities and other institutions designated by them;
(3) Some of the services and/or product functions you use may be provided by the partners or jointly provided by us and our partners. When you trigger, apply for and use the services of the E Fund Partners, to facilitate your acceptance of services of the E Fund Partners subject to compliance with laws and regulatory provisions, you need to share your Personal Information among the aforesaid partners. To avoid the need for you to repeatedly submit information and facilitate your use of the aforesaid services, you allow and authorize us to share your information with our partners to the extent necessary. For example: In order to facilitate your log in based on E Fund Services or use the front-office business systems of the E Fund Partners, We will provide your Personal Information (including registration information, etc.) retained on the E Fund Platforms for our partners to assist them in completing necessary account registration procedures and the product or service activation procedures for you; provide your identity authentication information retained on our platforms for our partners to assist them in carrying out identity authentication procedures; provide the risk assessment information You authorize Us to collect from the E Fund Partners for our other partners to assist them in continuing suitability assessment of you; provide other information You authorize Us to collect or provide Us with for the E Fund Affiliates and E Fund Partners to assist them in cross-verifying your Personal Information, carrying out point-based marketing campaigns among customers, assessing your credit standing, performance ability and risk tolerance, providing and recommending suitable products or services to You and using the information for other purposes related to your use of the services;
(4) You allow and authorize Us to provide your transaction counterparties, banks We partner with for relevant business, guarantee institutions, insurance institutions and the like with information concerning your performance and defaults under relevant agreements if You breach relevant agreements with the E Fund Affiliates or E Fund Partners;
(5) Pursuant to legal provisions and reasonable usual business practices, when E Fund merges with or is acquired by another company or carries out other activities in the capital market (including IPO and bond issuance), and in other circumstances when any other third party conducts due diligence on E Fund, You allow and authorize Us to provide your information to the third parties if it is lawful and necessary, but We will require the third parties to take reasonable confidentiality measures for such information by signing a confidentiality agreement with the third parties or other means, and require the third parties to delete your information within a reasonable period after completing necessary work;
(6) When a dispute occurs between You and another person as a result of use of the E Fund Services, in order to protect the legitimate rights and interests of you and that person, You allow and authorize Us to, in accordance with laws and regulations, provide your name, number of your valid identity certificate, your contact information and dispute-related information for regulators or another dispute resolution body agreed upon between You and that person so as to timely settle the dispute, unless any law or regulation expressly prohibits the provision of such information;
(7) We may provide your Personal Information in accordance with laws and regulations to comply with applicable laws and regulations, the requirements of administrative or judicial organs, or for the purpose of litigation. If We ascertain that You have violated any of the applicable laws and regulations, or to protect the rights, property or safety of E Fund, the E Fund Affiliates or other users or the public, We may also provide your information in accordance with laws and regulations, including relevant violations and the measures We have taken against you;
(8) When you choose to use the facial verification service on the E Fund Platforms, You allow and authorize Us to provide your facial information concerning facial verification to Shenzhen Tencent Computer Systems Company Limited or other qualified E Fund Partners for facial verification.
(9) Other circumstances in which your grant prior authorization and consent.
2. Entrustment of processing
To meet the requirements of laws, regulations and relevant regulatory provisions or self-regulatory rules and maintain the effectiveness of internal control, You allow and authorize Us to provide information necessary for services such as audits for the auditors or audit, legal and other external consultants that We or our affiliates engage and require them to process your information in accordance with relevant legal provisions and regulatory requirements.
To provide you with even better and high-quality products and services, some of our services will be provided by our partners. You allow and authorize us to provide our partners with certain Personal Information about You to the extent permitted by laws and regulations, so as to provide better customer service and user experience. We will only provide your Personal Information for lawful, legitimate, necessary, specific and explicit purposes, and will only provide the Personal Information necessary for the services. Meanwhile, we will require our partners to strictly follow our instructions, this Policy and relevant confidentiality and security measures when they process your Personal Information, and require our partners not to use the received Personal Information for any other purposes.
Unless otherwise provided by law, in order to improve the efficiency of information processing, reduce the cost of information processing or improve the accuracy of information processing, we may entrust competent partners to process, analyze and deal with your information on our behalf in accordance with this Privacy Policy and within the limits of authority granted. We will comply with the provisions of laws and regulations on entrustment of processing, fully review and assess the ability of such partners to protect Personal Information and prohibit them from using such information for purposes not authorized by you. When we terminate or end the partnership with a partner, we will require the partner to, in accordance with laws and regulations, no longer store or use the relevant information.
In order to enable Us to verify the accuracy and integrity of your information and prevent or stop illegal activities, You allow and authorize Us to inquire about and verify the information related to your use of the E Fund Services by ourselves or through third-party professional data service providers or other third-party institutions We partner with, and to view, collect, use and retain the verification and validation results obtained.
3. Transfer
We will not transfer your Personal Information to third parties, except in the following circumstances:
(1) We have obtained your separate consent to the transfer;
(2) According to the provisions of laws and regulations and the requirements of competent authorities, your Personal Information needs to be transferred.
In addition, as our business continuously grows, we may enter into mergers, acquisitions, asset transfers or similar transactions, and you agree that your Personal Information may be transferred as part of such transactions. We will notify you of the recipient’s name and contact information before the transfer, and require the new company or organization holding your Personal Information to continue to be bound by laws, regulations and this Policy. If the purposes for which Personal Information is used are changed, we will require the company or organization to obtain your explicit consent again.
4. Public disclosure
We will not publicly disclose your Personal Information except as expressly required by laws and regulations or by competent authorities. If public disclosure is mandatory, We will inform You of the purpose of the public disclosure, the type of information to be disclosed and sensitive information that may be involved, and obtain your separate consent.
5. Exceptions
Pursuant to relevant laws and regulations, we may lawfully share, transfer and publicly disclose your Personal Information without your consent in the following circumstances:
(1) Such acts are necessary for the conclusion and performance of a contract to which you are a party;
(2) Such acts are necessary for performance of our statutory responsibilities or obligations;
(3) Such acts are necessary to respond to a public health emergency or protect your life, health and property in an emergency;
(4) We may reasonably process your Personal Information for news reporting, supervision of public opinions or other activities conducted in the public interest;
(5) We may, in accordance with regulations, reasonably process the Personal Information about You that has been publicly disclosed by you or otherwise lawfully disclosed publicly;
(6) Other circumstances prescribed by any law or administrative regulation.
Article 6 How We Store Information
To meet regulatory requirements, provide services for you and facilitate your inquires about your transaction status or history, we will store the necessary information submitted or generated during your application for or use of the services. We only store your Personal Information when necessary for the purposes described in this Privacy Policy and for such period as required by laws, regulations and regulators.
1. Territory where information is stored
Your Personal Information collected and generated by us within the territory of the People’s Republic of China will be stored within the territory of the People’s Republic of China. If, for cross-border business, We need to transmit to any overseas institution relevant Personal Information about You collected within the territory of the PRC, We will explicitly inform You of the purpose for which the information will be transmitted overseas, the identity of the recipient, relevant security measures and other necessary information, obtain your prior separate consent, and conform to China’s laws and administrative regulations as well as the provisions of relevant regulators. We will also, through effective measures such as signing agreements, assessment and verification, require the overseas institution to keep confidential your Personal Information obtained, except the Personal Information prohibited by laws and regulations from being transmitted overseas.
2. Period of storage
Unless otherwise required by laws and regulations, we will store your information for the following period:
We will store your Personal Information in accordance with the requirements of applicable laws and regulations. For instance, for the time being,
- To perform our obligations under the Anti-money Laundering Law of the People’s Republic of China, We will store your identity information for at least five years from the end of your business relationship with E Fund; meanwhile, we will store your transaction information for at least five years from the end of your transactions with E Fund;
- To perform our obligations under the Management Measures on Identification of Customers of Financial Institutions and Storage of Customers’ Identity Information and Transaction Records, We will store your identity information and transaction information for at least five years from the year when your business relationship with us ends or from the year when accounting for the one-time transaction is completed. If your identity information and transaction records are involved in any suspicious transaction activity subjected to an anti-money laundering investigation, and the anti-money laundering investigation has not been completed when the minimum period of storage expires, We will store your identity information and transaction records until the anti-money laundering investigation is completed;
- To perform our obligations under the Cyber Security Law of the People’s Republic of China, We will store the weblogs obtained by monitoring and recording the network operation status and network security incidents for no less than six months;
- To perform our obligations under the Securities Investment Fund Law of the People’s Republic of China, We will store the data related to your status as a holder of fund shares, such as your name, your identity information and fund share details, for no less than 20 years from the date of closing of your fund account;
- To perform our obligations under the Measures for Supervision and Management of Institutions Selling Publicly Offered Securities Investment Funds, We will store the information related to your status as an investor for no less than 20 years from the year when the business relationship ends, and store other information related to the fund sales business with You for at least 20 years from the year in which business is conducted;
- Other periods of storage of data and information required by laws, regulations or regulators;
If different laws, regulations and regulatory provisions require different periods of storage, we will store your Personal Information for the longest period required.
To provide the E Fund Services for You, We will store your Personal Information until the information is no longer necessary for provision of the E Fund Services, or delete or Anonymize your Personal Information after You withdraw the relevant consent/authorization or choose to close your account; if the period of storage prescribed by laws and administrative regulations has not expired, or it is technically difficult to delete or Anonymize the Personal Information, We will stop processing the information except storing it and taking necessary security measures.
If data have been stored for a period longer than the period of storage required by regulations, we will Anonymize and seal up the data or delete the data. Upon being anonymized, your Personal Information will become data that can be used and circulated. We do not need to notify you and obtain your consent for the storage and processing of such data.
Article 7 How We Protect Information
1. We have used security measures that meet industry standards to protect the Personal Information You provide from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably practicable measures to protect your Personal Information. For example, the exchange of data (such as debit card information) between your browser and the E Fund Platforms is protected by SSL encryption; We also provide secure HTTPS browsing modes for the E Fund Platforms; We will use encryption technology to ensure the confidentiality of data; We will back up data to other servers to ensure that the information We have will not be lost; We will use a trusted protection mechanism to prevent malicious attacks on our data; We will deploy an access control mechanism to ensure that only authorized personnel have access to the Personal Information; and We will organize security and privacy protection training courses to enhance staff’s awareness of the importance of protecting Personal Information. Although we have these security measures in place, please note that there is no such thing as “perfect security measure” on the information networks. If you find that your Personal Information is leaked, especially your member account or password, you should immediately contact us through the contact information provided by the E Fund Platforms so that we can take corresponding measures.
2. The Internet is not an absolutely secure environment, and emails, instant messages and communication with other users are not encrypted. We strongly recommend that you do not send Personal Information through such means.
3. Member account information is very important Personal Information, and you can only use your member account through your password. Please help us keep your account secure by using a complex password. When you use the E Fund Services, please properly keep the identity verification information associated with your account. We will use such information to identify you. Once you divulge the identity verification information associated with your account, you may lose your information and there may be legal consequences against you. Therefore, please properly set and keep the information on your member account with the E Fund Platforms. If you find that your account and password have been or will be compromised for any reason, please contact us immediately so that we can take corresponding measures to prevent or reduce relevant losses.
4. You understand and agree that the information that is generated on the E Fund Platforms or collected by the E Fund Platforms with authorization and stored in a certain form when You use the E Fund Services or use the services of the E Fund Partners based on the E Fund Services shall be co-owned by You and the E Fund Platforms; You shall not authorize a third party to collect, use or store such information by ways such as lending your account or using or authorizing the third party to use technical means, unless E Fund has expressly agreed.
5. Security incidents
(1) If an unfortunate Personal Information security incident occurs, We will, in accordance with the requirements of laws and regulations, timely inform You of the basic information on and possible impact of the security incident, the measures We have taken or will take, suggestions on how You may prevent and reduce risks, remedial measures taken for You, etc. We will timely inform you of the relevant information through platform messages, SMS messages, telephone, email and other contact information previously notified by you. If it is difficult to inform relevant persons one by one, we will release an announcement in a reasonable and effective way. In addition, we will timely report Personal Information security incidents and related measures to relevant authorities in accordance with legal requirements.
(2) We will timely deal with security risks such as system vulnerabilities, network attacks, virus attacks and network intrusions. In the event of an incident that endangers cyber security, we will, in accordance with the contingency plan for cyber security incidents, timely take corresponding remedial measures and report the incident to the relevant competent department in accordance with regulations.
(3) If our physical, technical or management protection facilities are damaged, and it leads to unauthorized access to, public disclosure of, tampering with or damage to information and harm to your legitimate rights and interests, We will assume corresponding liability in strict accordance with the law.
6. How we protect minors’ information
We will not proactively collect Personal Information from minors under the age of 14. Minors who use our services must do so under the supervision of their parents or other guardians. We will protect the confidentiality and security of minors’ Personal Information in accordance with relevant laws and regulations of China.
If you are a minor, please ask your parents or other guardians to read this Policy and use our services or provide us with your information after obtaining consent from your parents or other guardians. If minors’ Personal Information is collected and used with the consent of their parents or other guardians, we will use or share such information only if such act is permitted by law, expressly approved by the guardians, or is necessary to protect your rights and interests. If your guardians do not allow you to use our services or provide us with information in accordance with this Policy, please stop using our services immediately and timely inform us so that we can take corresponding measures. If you are a guardian of a minor, please contact us through the contact information in this Privacy Policy if you have any question about the Personal Information of that minor.
In particular, if you are a child under the age of 14, please use our services or provide us with your information after obtaining consent from your parents or other guardians. If your information is used with the consent of your parents or other guardians, in addition to complying with the provisions of this Privacy Policy on users’ Personal Information, We will adhere to the principles of legitimacy and necessity, informed consent, clear purposes, security and lawful use, and store, use and disclose the information in strict accordance with the requirements of the Regulations on Online Protection of Children’s Personal Information and other laws and regulations, and for a period not longer than the period necessary to attain the purposes of the collection and use thereof. Upon the expiration of that period, we will delete or anonymize the Personal Information of the child. If your guardians do not allow you to use our services or provide us with information in accordance with this Policy, please stop using our services immediately and timely inform us so that we can take corresponding measures.
Article 8 Cookie and Other Technologies
To provide you with more relaxing access experience, when you access the E Fund Platforms or use the E Fund Services, We may identify you through small data files so that you will not need to re-enter your registration information or we can help determine the security status of your account. Such data files may be Cookies, Flash Cookies or other local storage provided by your browser or associated applications (hereinafter referred to as “Cookies”). Please understand that some of our services can only be implemented through the use of Cookies. You may modify the level of your acceptance of E Fund’s Cookies or reject E Fund’s Cookies if permitted by your browser or the browser add-ons (the “Help” section of the toolbar of most browsers will tell You how to prevent your browser from accepting new Cookies or how to turn off Cookies completely), but this may affect your secure access to the E Fund Platforms or use of the E Fund Services.
E Fund Platforms may also contain some electronic images (hereinafter referred to as the “Single-pixel GIF Files” or “Web Beacons”), which can help the websites count users browsing the web pages or access certain Cookies. We will collect information about your web browsing activities through Web Beacons, such as the addresses of pages you visit, the locations of the cited pages previously visited by you, your browsing environment, and display settings.
Article 9 Your Rights
In accordance with relevant laws, regulations and standards of China, We highly respect your concerns about Personal Information and provide you with ways to manage your Personal Information and exercise your rights. You have the right to access, correct, delete, withdraw and manage your information and protect your privacy and security.
1. Access and copy Personal Information
We strive to provide you with smooth access to your Personal Information whenever you use our services, except as otherwise required by laws and regulations. You may exercise your access rights in the following ways:
(1) Account information: If You want to access or edit the Personal Information among your member account information and change your password, add security information, etc., You may do so on the online transaction page (Account Management/Basic Information, Security Settings) or e Wallet app (My/Account Settings, My/Security Center).
(2) Use information: You may access the information you post on the online transaction page (Account Management/Basic Information) or e Wallet app (My/Account Settings). To protect the security of your information and our legitimate rights and interests, without our consent, you shall not use other means or authorize a third party to access or collect your Personal Information stored on the E Fund Platforms.
(3) Copy your Personal Information: You may copy your Personal Information in the ways provided by E Fund (such as clipboard) or contact us through the contact information provided by the E Fund Platforms or this Privacy Policy to request a copy of your Personal Information.
2. Correct Personal Information
When you need to update your Personal Information, or find a mistake in our processing of your Personal Information, You have the right to update or correct the information, and submit your application for correction to us. You may submit your application for correction through the online transaction page (Account Management/Basic Information), e Wallet app (My/Account Settings), E Fund Platforms, contact information provided by this Privacy Policy, etc.
3. Delete Personal Information
In the following circumstances, you may request us to delete your Personal Information:
(1) The purpose of processing has been achieved or cannot be achieved or the information is no longer necessary to achieve the purpose of processing;
(2) We have stopped providing the products or services, or the period of storage has expired;
(3) You have withdrawn your consent;
(4) We have processed Personal Information in violation of laws, administrative regulations or agreements;
(5) Other circumstances prescribed by any law or administrative regulation.
You may request us to correct or delete your Personal Information through the contact information provided by the E Fund Platforms. To the extent permitted by laws, regulations and regulatory provisions, if we decide to respond to your request for deletion, we will also notify the partners or third-party institutions that obtain your Personal Information from us and require them to timely delete the information, or require them to obtain your separate consent. When you delete information from our server, we may not immediately delete the corresponding information from the backup system, but we will delete such information in accordance with the requirements of laws and regulations when updating the backup system.
However, please note that if we need to store your Personal Information pursuant to applicable law, or if it is technically difficult to delete Personal Information, We will store such Personal Information, but will not process the information except storing it and taking necessary security measures.
4. Withdraw consent
(1) You may withdraw part of the authorizations via the system permission settings of your mobile phone or request withdrawal of part or all of the authorizations through the contact information provided by the E Fund Platforms.
(2) After you withdraw your consent or authorization, we will be unable to continue to provide you with the services corresponding to the withdrawal of consent or authorization, and we will no longer process your corresponding Personal Information. However, your decision to withdraw your consent or authorization will not affect any previous processing of Personal Information based on your consent or authorization.
5. Close your account
You may apply to close your account through the contact information provided by the E Fund Platforms, or close your account on the e Wallet app by yourself (My/Account Settings/Close the Account), or visit the official website of E Fund (Account Management/Basic Information/Fund Account) to close your account by yourself. Once you close your account, you will not be able to use the services associated with the account, so please conduct operations prudently. Please note that, if you only delete the e Wallet app from your mobile device, we will not close your account and all information about your account will not be deleted. To achieve the said purposes, you still need to close your account. If you close your account on the E Fund Platforms, You only close the corresponding account under the direct sales channel of E Fund, and your accounts under other agency sales channels will not be affected.
To protect your or others’ legitimate rights and interests, We need to verify your identity before closing your member account, and determine whether to support your application for account closing based on your use of the E Fund Platforms. Unless otherwise prescribed by laws and regulations, we will stop providing corresponding services for you after you close your account. We will lawfully retain your Personal Information in accordance with regulatory requirements and will no longer use your Personal Information for our daily business. You may read relevant specifications and requirements on the registration page.
6. Respond to your request
(1) If you are unable to exercise your rights to your Personal Information through the aforesaid methods, or you are unable to close your account, or you have any doubt or questions regarding our collection and use of your Personal Information, You may contact us through the contact information set forth in Article 12. For security purposes, we may need you to provide a written request or otherwise prove your identity. We will reply to your request within 15 working days after receiving your feedback and verifying your identity.
(2) We will use reasonable commercial efforts to meet your requests for access, correction, deletion, withdrawal and management of Personal Information. However, we may rejects requests that violate any law or regulation, are unwarranted, may be unnecessarily repetitive, require excessive technical means (e.g., requests that require the development of a new system or a fundamental change to usual practices), pose risks to the legitimate rights and interests of others, or are highly impractical.
(3) For your reasonable requests, we do not charge fees in principle, but for repeated requests beyond reasonable limits, in light of the situation, we will charge a fee to cover the cost.
7. Rights of relatives of deceased users
Unless otherwise arranged by the deceased user, we guarantee the rights of the close relatives of a deceased user to lawfully consult, copy, correct and delete the relevant Personal Information of the deceased user for their own lawful and legitimate interests. We will respond to their requests in accordance with relevant laws, regulations, regulatory requirements and relevant rules set forth in this Privacy Policy.
8. Exceptions
According to relevant laws, regulations, regulatory requirements and other provisions, we may not be able to respond to your request if any of the competent authorities or regulators of China requires so in any of the following circumstances, or any of other circumstances agreed below occurs:
(1) Our performance of obligations under laws and regulations is involved;
(2) National security or national defense security is directly involved;
(3) Public security, public health or vital public interest is directly involved;
(4) Any criminal investigation, prosecution, trial, enforcement of a judgment or the like is directly involved;
(5) There is sufficient evidence of your subjective malice or abuse of rights;
(6) We do it to protect your or other individuals’ life, property or other major legitimate rights and interests, but it is difficult to obtain your consent;
(7) Responding to your request would result in serious harm to your legitimate rights and interests or the legitimate rights and interests of other individuals or organizations;
(8) Any business secret of us or a third party is involved.
Article 10 Governing Law and Dispute Resolution
1. Governing law
The implementation and interpretation of and resolution of disputes arising from this Privacy Policy shall be governed by the laws of the People’s Republic of China (For the avoidance of ambiguity, the laws of the Hong Kong Special Administrative Region, the Macao Special Administrative Region, and Taiwan are not included here.).
2. Dispute resolution
Any dispute between you and us regarding the content or implementation of this Privacy Policy shall be resolved by the two parties through friendly negotiations; if the parties cannot resolve the dispute through negotiations, the parties agree to refer the dispute to the people’s court having jurisdiction in the place where E Fund is located.
Article 11 Revisions to this Privacy Policy
Our Privacy Policy is subject to changes. Without your express consent, we will not curtail your rights under laws and regulations. We will publish any change to this Privacy Policy on the official website of E Fund, E Fund e Wallet, E Fund Small-amount Wealth Management and other channels. For major changes, we will show you the changed Privacy Policy through a pop-up window when you log in to the E Fund Platforms; please note that we will collect, use, and share and store your Personal Information in accordance with the changed Privacy Policy only after you click the Agree button in the pop-up window. Major changes referred to in this Privacy Policy include but are not limited to the following:
(1) Major changes in our service model, such as the purpose of processing Personal Information, the types of Personal Information processed, and the ways in which Personal Information is used;
(2) Major changes in our ownership structure, organizational structure, etc., such as owner changes resulting from business adjustment, bankruptcy, merger, acquisition, etc.
(3) Changes in the main parties to which the Personal Information is shared, transferred or publicly disclosed;
(4) Major changes in your right to participate in the processing of Personal Information and the ways in which you exercise the right;
(5) Major changes in the contact information and complaint channels through which we deal with matters such as security of Personal Information;
(6) A high level of risk indicated by a report on assessment of impact on Personal Information security.
We will also keep the old versions of this Privacy Policy on file. If you need to refer to them, you may contact us through the contact information provided by the E Fund Platforms or this Privacy Policy.
Upon being published, the revisions to this Privacy Policy shall take effect and supersede the previous version of relevant content. You shall pay attention to changes in relevant announcements, prompt messages and agreements, rules and other relevant content from time to time. If this Policy is updated, we will notify you in one or more ways, such as publishing the update on the official website of E Fund, sending a push notification on the app, displaying a pop-up prompt, and sending an email/SMS message. In order for you to timely receive notifications, we recommend that you timely inform us when your contact information is updated. You understand and confirm that, if You do not agree to the updated content of the Privacy Policy, You shall immediately stop using the corresponding services and close the relevant accounts, and We will stop collecting your relevant Personal Information; if You continue to use the E Fund Services, it indicates that You have fully read, understood and accepted the updated Privacy Policy and are willing to be bound by the updated Privacy Policy.
Article 12 Contact Us
If You have any question, opinion or suggestion regarding this Privacy Policy, or You have any opinion or suggestion regarding related matters such as the collection, use, sharing, access, correction, deletion and withdrawal of your Personal Information when using the E Fund Services, or You encounter any problem when using the E Fund Services, You may contact Us through the following contact information:
Company name: E Fund Management Co., Ltd.
Address: 6/F, 188 Rongyue Avenue, Hengqin New Area, Zhuhai City, Guangdong Province
Customer service hotline: 400 881 8088
Contact for Personal Information protection: 400 881 8088
Contact for filing security complaints and reporting violations: 400 881 8088
Staff service hours: 8:30 - 22:00 from Monday to Sunday (except legal holidays)
Customer service email: efundservice@efunds.com.cn
In the event of any change in the foregoing contact information, the latest notice on the official website shall prevail. After receiving your request, We will give You effective feedback within 15 working days.
Article 13 Instructions on Emergency Handling
If the services of the online transaction platform are interrupted due to malfunctioning of the information technology system, You may submit an emergency report through the customer service hotline, or download the relevant form from the website and send it to our company’s staff as per the instructions on the form for assistance.
Article 14 Miscellaneous
In the event of any inconsistency or conflict between the terms of this Privacy Policy and the privacy protection and authorization terms of any service agreements used by the E Fund Platforms (including but not limited to the Service Agreement of E Fund Management Co., Ltd. on Online Trading of Open-ended Securities Investment Funds), the terms of this Privacy Policy shall prevail (unless it is stated that this Privacy Policy does not apply). In case of any inconsistency or conflict between the terms of this Privacy Policy and any of the legal provisions or regulatory requirements related to Personal Information, the relevant legal provisions or regulatory requirements shall prevail.
The privacy policy is also in Simplified Chinese, in case of any inconsistency or conflicts between this version and the Simplified Chinese Version, the Simplified Chinese version shall prevail.