Mastercard NetsUnion – Privacy Policy


Effective Date: May 9, 2024

Mastercard NetsUnion Information Technology (Beijing) Co., Ltd. ("Mastercard NetsUnion" or "we") respects your privacy.

The types of Personal Information collected, the purpose for which it is collected, the other parties with whom it may be shared, and the measures taken to protect the security of the data are described in this General Privacy Notice. Additionally, it informs about your rights and choices regarding your Personal Information and provides and details on how to contact us about our privacy practices.

Please note that we also act on behalf of and under the instructions of financial institutions, merchants and other partners which act as data controllers, including processing payment transactions. Please refer to their respective privacy policies for more information regarding the processing of your Personal Information in these contexts.

Specific Privacy Statement may apply to some of our products and services. Please visit the webpage or application of the specific product or service to learn more about our privacy and information practices in relation to that product or service.

  1. Personal Information We May Collect

    "Personal Information" means all types of information relating to an identified or identifiable natural person that is recorded electronically or otherwise, excluding anonymized information. We may collect or process the following categories of Personal Information:

    • Transaction information, such as personal account number, the merchant's name and location, the date and the total amount of transaction, and other information provided by financial institutions or merchants when we act on their behalf.
    • Product and service information, such as registration and payment information when you request a product or service directly from us or participate in a marketing program, and information specifically for use in such programs.
    • Website, device and mobile app usage, and similar information collected via automated means, such as cookies and similar technologies.
    • Job applications and related information when you apply for a job with us.
    • Business contact information when you work for one of our business partners.
    • Identifying information such as name, e-mail address, physical address, telephone number and IP address.

    Learn more

    In this Privacy Policy, "Personal Information" means all types of information relating to an identified or identifiable natural person that is recorded electronically or otherwise, excluding anonymized information. We may collect different types of Personal Information in the situations described below. Usually, the information that we collect about you is not considered sensitive, but in limited circumstances, we may collect your Sensitive Personal Information. "Sensitive Personal Information" means Personal Information that, if disclosed or used unlawfully, could easily lead to the infringement of a natural person's human dignity or jeopardize the safety of his or her person or property. Examples of Sensitive Personal Information given under applicable laws include financial account information (also known and hereinafter referred to as personal account number). We will inform you of the categories of Sensitive Personal Information that we collect in specific situations described below or in the relevant program-specific privacy notice. By using our relevant products or services or participating in the specific program, you will be deemed as having consented to our collection and processing of your Sensitive Personal Information in accordance with this Privacy Policy (and the relevant program-specific privacy notice, if any).

    Personal Information We Collect from Financial Institutions, Merchants, and Other Partners in Connection with Mastercard NetsUnion's Products or Services

    As a processor of payment transactions and provider of related services, we obtain a limited amount of information in connection with your payment transactions such as the personal account number, the merchant's name and location, the date and the total amount of transaction. Among these, your personal account number may be regarded as Sensitive Personal Information; it is necessary for us to receive and process your personal account number in order to provide you with payment transactions and related services. However, we generally do not need or collect the cardholder's name or other contact information to process payment transactions.

    In addition, for certain products and services, your financial institutions, the merchants where you make a transaction or other partners may provide us with more information about you, or we may collect it directly from you to provide you with those products and services on their behalf, support their business or perform information processing activities on their behalf.

    In the above situations, we act on behalf of and under the instructions of financial institutions, merchants and other partners which act as data processors. Unless otherwise authorized by law, we will process your Personal Information to process payment transactions or for the purposes agreed by the financial institutions, merchants and other partners. Please refer to their respective privacy policies for more information regarding the processing of your Personal Information.

    We may collect or use Personal Information for fraud prevention and monitoring, risk management, dispute resolution and other related purposes. Such information may include the personal account number, merchant's name and location, date and total amount of the transactions, IP address, fraud score, location data, merchant details, items purchased and information about the dispute. Among these, your personal account number may be regarded as Sensitive Personal Information. It is necessary for us to receive and process your personal account number in order for the abovementioned purposes.

    Personal Information We Collect When We Provide Products and Services Directly to You

    We may offer products and services directly to you, such as marketing programs and rewards programs. In order to take advantage of one or more of the products and services, you may submit information directly to us in the following ways: (i) during interactions on our websites, applications, etc., (ii) when responding to marketing newsletters or other communications, (iii) when signing up for a product or service, or (iv) when participating in an offer, program, or promotion. We may also obtain your Personal Information from the following sources: through your use of our products or services, from companies that use or facilitate our products or services, from publicly available sources, or from third party partners. Your financial institution, merchant or other business partner may also transfer your Personal Information to us.

    Programs vary, so where applicable, please refer to the relevant program-specific privacy statement to learn more about how that particular program uses your Personal Information.

    Personal Information We Collect from Your Interaction with Mastercard NetsUnion's Ads, Websites, Apps or Other Digital Assets

    We, our service providers and partners may collect certain information about you via automated means such as cookies and web beacons when you interact with our ads, mobile apps, or visit our websites, pages or other digital assets. The information we collect in this manner may include: IP address, browser type, operating system, mobile device identifier, geographical area, referring URLs and information on interaction with or actions taken during the interaction with our digital assets. A "cookie" is a text file placed on a computer's hard drive by a web server. A "web beacon," also known as an Internet tag, pixel tag or clear GIF, is a technology that helps us identify when content has been accessed or visited.

    We use this information to improve our online products and services by assessing how many users access or use our online products and services, which content, products and features of our online products and services most interest our visitors, what types of offers our customers like to see and how our online products and services perform from a technical point of view. For instance, we may use third-party web analytics services on our websites and mobile apps, such as those of Adobe Omniture. The analytics service providers use technologies such as cookies and web beacons to help us analyze how visitors use our websites and apps.

    We, our service providers and partners may collect certain information about you via automated means such as social media tools, widgets or plug-ins to connect you to your social media accounts. These features may allow you to sign in through your social media account, share a link or post directly to your social media account. When you visit a website that contains such tools or plugins, the social media or other service provider may learn of your visit. However, your interactions with these tools are governed by the privacy policies of the corresponding social media platforms. As we do not control these third-parties' data handling practices, we recommend that you review their privacy policies, terms of use, and license agreements (if any). For further details, please consult Section 7 ("Features and Links to Other Websites") of this Privacy Policy.

    Where required under applicable law, we obtain your consent prior to using the above automated means, and prior to sending you marketing communications, tailored content and ads.

    Please see the "Your Rights and Choices" section of this Privacy Policy to learn about your choices.

    Personal Information We Obtain When You Apply for a Job with Us

    If you are applying for a job at Mastercard NetsUnion, we may collect certain Personal Information from your job applications on our career website, such as your contact information (including name, postal address, email address and phone number), job history, curriculum vitae, contact details of your referees and any other Personal Information you choose to submit along with your application.

    Personal Information We Collect in the Context of Our Business Relationship with Financial Institution, Merchant or Other Entity Partnering with Mastercard NetsUnion

    We may collect Personal Information from individuals working for one of our business partners (including financial institutions, merchants, customers, suppliers, vendors and other partners), including name, job title, department and name of organization, business email and postal addresses, business telephone number, answers to security questions, security passwords and other credentials. Among these, answers to security questions, security passwords and other login credentials may be regarded as Sensitive Personal Information, and we need such information to authenticate and establish business relationships. We may use this information to provide products and services directly to financial institutions, corporate clients, merchants, customers and partners, to manage our business relationships and financial reporting, for franchise development and integrity management, for marketing and to comply with applicable law, as well as for accounting, auditing and billing purposes. The above-mentioned financial institutions, corporate clients, merchants, customers and partners should meet the requirements of applicable laws when processing Sensitive Personal Information and transfer Personal Information cross borders, including obtaining your separate consent. We will process the above Personal Information within the scope you agree to.

  2. How We May Use Your Personal Information

    We May Use Your Personal Information to:

    • Process your payment transactions.
    • Protect against and prevent fraud, and other legal or information security risks.
    • Operate, evaluate and improve our business.
    • Process your job application.
    • Serve other purposes for which we provide specific notice at the time of collection, and as otherwise authorized or required by law such as to meet the regulatory requirements under applicable laws.

    Where required under applicable law, we will only use your Personal Information with your consent, and as necessary to provide you with products and services or to comply with a legal obligation.

    Learn more

    We may use Personal Information we obtain about you for the purposes set below. We will only process your Personal Information with your consent and/or when we have a legal basis for processing as listed below:

    Processing ActivityLegal Basis for Processing
    • Processing Your Payment Transactions (including authorization, clearing, chargebacks and other related dispute resolution activities).

    In most cases, we process your payment transactions on behalf of your financial institutions, merchants and other partners which act as personal data processors. When we act on their behalf, personal data processors are responsible for ensuring a legal basis for the processing of your Personal Information. Please refer to their respective privacy policies for more information regarding the processing of your Personal Information in these contexts.

    In some limited cases (e.g., chargebacks), we may process your payment transactions as a processor, provided that:

    • You consented to the use of your Personal Information; or
    • The processing is necessary for entering into, or performance of a contract which you are a party to; or
    • The processing is necessary for compliance with a legal obligation or other regulatory obligations.
    • Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure and franchise quality with respect to the integrity and security of our payments network.

    When we process Personal Information for fraud prevention, we may act as a processor or on behalf of a processor. When we act as a processor, we rely on one of the following legal grounds:

    • You consented to the use of your Personal Information; or
    • The processing is necessary for compliance with a legal obligation or other regulatory obligations.
    • Manage our customer, supplier and vendor relationships, (which may include business contact information).
    • You consented to the use of your Personal Information; or
    • The processing is necessary for entering into, or performance of a contract which you are a party to.
    • Operate, evaluate and improve our business (including developing new products and services); analyze our products, services, websites, mobile apps and any other digital assets in order to facilitate their functionality;
    • You consented to the use of your Personal Information; or
    • The processing is necessary for entering into, or performance of a contract which you are a party to.
    • Perform due diligence reviews, accounting, auditing, billing, reconciliation and collection activities.
    • The processing is necessary for compliance with a legal obligation or other regulatory obligations; or
    • The processing is necessary for entering into, or performance of a contract which you are a party to.
    • Evaluate your interest in employment and contact you regarding possible employment with Mastercard NetsUnion.
    • You consented to the use of your Personal Information; or
    • the processing is necessary for entering into, or performance of a contract which you are a party to.
    • Establish, exercise and defend legal rights when necessary.
    • The processing is necessary for entering into, or performance of a contract which you are a party to; or
    • The processing is necessary for compliance with a legal obligation or other regulatory obligations; or
    • We, or a third party, may use your Personal Information for the purposes of enforcing the Terms of Use and establishing, exercising and defending legal rights.
    • As may be required by applicable laws and regulations, including for compliance with Know Your Customers, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Mastercard NetsUnion.
    • The processing is necessary for compliance with a legal obligation or other regulatory obligations;
    • We, or a third party, are legally entitled to use your Personal Information for the purposes of responding to a judicial process, law enforcement or governmental agency.
    • Comply with industry standards and our policies.
    • You consented to the use of your Personal Information; or
    • The processing is necessary for compliance with a legal obligation or other regulatory obligations.
    • For other purposes for which we provide specific notice at the time of collection.
    Please consult the Specific Privacy Statement at the time of the collection.

    We will not subject you to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, unless you explicitly consented to the processing, the processing is necessary for entering into, or performance of a contract between you and Mastercard NetsUnion, or when we are legally required to use your Personal Information in this way, for example to prevent fraud.

    If you provide us with any information or material relating to another individual, you must make sure that the sharing with us and our further use as described to you from time to time is in line with applicable laws, so you should duly inform that individual about the processing of her/his Personal Information and obtain her/his consent, as may be necessary under applicable laws.

  3. How We Share Your Personal Information

    We May Share Personal Information with:

    • As we operate as part of Mastercard-branded bankcard clearing business, we may share Personal Information with Mastercard's group of affiliated companies as listed in the Section 5 "Cross-borderTransfer of Personal Data".
    • Service providers acting on our behalf, such as NetsUnion Clearing Corporation on Chinese Mainland (contact address at Building 7, No. 1 Yuetan South Road, Xicheng District, Beijing, the PRC, 100045; contact e-mail: contact@nucc.com) or other affiliates and entities within NetUnion's group of companies.
    • Other participants in the payment ecosystem, include financial institutions and merchants.
    • Third parties for fraud monitoring and prevention purposes, or other purposes required by law.
    • Third parties whose feature you use in connection with our products and services or with your consent.
    • Other entities as required under applicable law or in the event of a sale or transfer of our business or assets.

    By using our relevant products or services or participating in a specific program, you will be deemed as having consented to our sharing of your Personal Information with recipients whose identities or categories are described above in accordance with this Privacy Policy (and the relevant program-specific privacy notice, if any).

    Learn more

    We do not disclose Personal Information we collect about you, except as described in this Privacy Policy, as disclosed to you at the time of data collection or as described in our program-specific privacy notice. We do not sell Personal Information we collect about you.

    We transfer Personal Information globally to certain Mastercard’s groups of affiliated companies in ways consistent with the terms of this Privacy Policy or as we otherwise disclose at the time the data is collected.

    We may also share your Personal Information:

    • With financial institutions and other entities that issue bank cards or merchants to process payment transactions and perform other activities that you request.
    • With entities partnering or assisting Mastercard NetsUnion in providing its products and services, including fraud prevention and monitoring and third-party identification services, ensuring transaction security and payment processing system security.
    • When we act as a service provider for third parties and provide them with Personal Information processing services.
    • With service providers performing services on our behalf for the purposes described in this Privacy Policy (or in the applicable program-specific privacy notice). We require these service providers by contract to only process Personal Information in accordance with our instructions and as necessary to perform services on our behalf or to comply with applicable law. We also require them to safeguard the security and confidentiality of the Personal Information they process on our behalf by implementing appropriate technical and organizational security measures and confidentiality obligations binding employees accessing Personal Information.
    • With third parties whose features (e.g. third-party cache, widgets, plug-ins) are integrated in our products and services. For further details, please consult Section 7 (Features and Links to Other websites) of this Privacy Policy.
    • With other third parties with your consent.
    • As required under applicable law or legal process, or when we believe disclosure is necessary to protect individuals' vital interests, or to enforce our Terms of Use, to prevent Mastercard NetsUnion against harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
    • In the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use Personal Information you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Information with any inquiries concerning the processing of that information.

    Before transferring or sharing any Personal Information, including access to Personal Information, we require that appropriate privacy and Personal Information security protections be included in our agreements with third parties. We implement a comprehensive third-party risk management program and conduct appropriate due diligence to implement that program.

    When required to do so by applicable laws and regulations, we will inform you of matters relating to the provision of your Personal Information by us to third parties, including the name of the recipient of the Personal Information, contact information, the purpose of the processing, the manner of the processing, and the type of Personal Information. If it involves cross-border transfer of Personal Information to overseas third parties, we will inform you of the manner and procedures, etc., for exercising the relevant rights to the overseas Personal Information recipients, and provide your Personal Information to the overseas third parties when you have made other agreements with us on information sharing or when we have obtained your individual consent in specific scenarios, as detailed in Article 5 of this Policy.

  4. Your Rights and Choices

    We take your concerns about your Personal Information very seriously and protect your rights in relation to your Personal Information. Your rights include:

    Access to and Correction of Your Personal Information

    You have the right to access and correct your Personal Information at any time, except as provided by law or regulation. You may contact us at any time and we will respond to your request in the manner and within the time period set out in this Privacy Policy.

    Deletion of Your Personal Information

    You may delete your Personal Information by contacting us in the manner set out in this Privacy Policy. You may request the deletion of your Personal Information from us in the following circumstances:

    • If our handling of Personal Information violates laws and regulations;
    • If we collect or use your Personal Information without your consent;
    • If our handling of Personal Information seriously violates our agreement with you.

    If we decide to respond to your request for deletion, we will also notify, to the extent possible, the entities that obtained your Personal Information from us and ask them to delete it in a timely manner, unless otherwise required by law or regulation, or these entities have received independent authorization from you.

    Changing the Scope of Your Authorized Consent or Withdrawing Your Authorization

    You may change the scope of your consent or withdraw your consent by contacting us in the manner set forth in this Privacy Policy. You have the right to object to certain collection or use of your Personal Information, including the use of cookies and similar technologies, the use of your Personal Information for marketing purposes, and automated decision-making with respect to your Personal Information.

    Please understand that each business function requires some basic Personal Information to be completed. When you withdraw your consent or authorization, we will not be able to continue to provide you with the services for which you withdrew your 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 the processing of Personal Information previously carried out on the basis of your authorization.

    Copying, Transferring your Personal Information

    You have the right to obtain a copy of your Personal Information. If you would like a copy of the Personal Information we have collected about you, you can contact us in the manner set out in this Privacy Policy. We will provide you with a copy of your Personal Information upon request, subject to compliance with relevant laws and where technically feasible.

    If you need to transfer your Personal Information collected and stored by us, we will provide you with a transfer route in accordance with the requirements of laws and regulations.

    Others

    • You have the right to ask us to explain our rules regarding the processing of Personal Information.
    • You have the right to lodge a complaint with a supervisory authority where applicable.

    Learn more

    You can exercise your rights by submitting a request as described in the "How to Contact Us" section below.

    You have certain rights regarding the Personal Information we maintain about you and certain choices about what Personal Information we collect from you, how we use it, and how we communicate with you.

    You may opt out of certain processing of your Personal Information by emailing privacy@mastercardnucc.com.

    To update your preferences, ask us to remove your information from our mailing lists or submit a request to exercise your rights under applicable law, contact us as specified in the "How to Contact Us" section below.

    If we fail to meet your expectations in processing your Personal Information or you wish to complain about our privacy practices, please tell us because it gives us an opportunity to fix the problem. Please provide full details of the issue to assist us in responding to your request. We attempt to review and respond to all complaints within a reasonable time and as required under applicable law.

  5. Cross-border Transfer of Personal Information

    As part of Mastercard-branded card clearing business and as Mastercard is a global company, we may transfer your Personal Information outside of Chinese Mainland for legitimate purposes such as customer profiling, risk/fraud prevention, dispute resolution, etc. As disclosed in Section 3 "How We May Share Your Personal Information", we may transfer your Personal Information to Mastercard Asia/Pacific Pte. Limited in Singapore (whose contact address is 3 Fraser Street, DUO Tower, #17-21/28, Singapore 189352) ("Mastercard Asia/Pacific"), which may further transfer your Personal Information to, for example, Mastercard Technologies, LLC in the United States (whose contact address is 2200 MasterCard Boulevard, 63368-7263 O'Fallon, MO United States) and Mastercard International Incorporated in the United States (whose contact address is 2000 Purchase Street Purchase, NY 10577, United States).

    When required by applicable laws and regulations involving cross-border data transfers, we will inform you of the overseas transfer of Personal Information and obtain your separate consent.

  6. How We Protect Your Personal Information

    We maintain appropriate security safeguards to protect your Personal Information and only retain it for a limited minimum period of time necessary to achieve the purposes for which was collected.

    Learn More

    The security of your Personal Information is important to Mastercard NetsUnion. We are committed to protecting the information we collect. We maintain reasonable administrative, technical and physical safeguards designed to protect the Personal Information you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We use SSL encryption on websites from which we transfer certain Personal Information. We may use enhanced measures that are proportionate with the risks associated to protect the security of Sensitive Personal Information.

    We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

  7. Features and Links to Other Websites

    Our websites may include links to other third-party websites, social media tools, widgets or plug-ins, permitting sharing web Content including IP address, with third parties and social media providers. These social media providers may learn of your visit even if you are not logged in to your social media account or if you do not have an account with them. To the extent any linked websites or features you visit or use are not owned or controlled by Mastercard NetsUnion, we suggest that you review their own privacy notices or policies.

    Learn More

    Our websites may provide links to other websites for your convenience and information. Our website may also contain certain features for which we partner with other entities. These entities may learn of your visit regardless of whether you use these features. These websites and features, which may include social networking and geo-location tools, operate independently from Mastercard NetsUnion, and are clearly identified as such. To the extent any linked websites or features you visit or use are not owned or controlled by Mastercard NetsUnion, we suggest that you review the privacy practices of the websites.

    Mastercard NetsUnion offers you the possibility to share, link to, or mention things on social media about Mastercard NetsUnion's products and services. For example, you can "like" or "push" an offer through your Weibo or WeChat account. When you visit a website with a social media button, your browser establishes a direct connection to that social media provider, and data concerning your visit, including IP address, is transferred to the social media provider. If you have an account with the social media provider, the provider may link your visit to your account, even if you are not logged into this account.

    You may also choose to use certain features on our websites that are provided by other entities that are not otherwise affiliated with Mastercard NetsUnion. These features, including geo-location tools, are operated by third parties and are clearly identified as such. Social media providers such as Weibo and WeChat, and these other third parties, are independent of Mastercard NetsUnion and do not necessarily share the same policy as Mastercard NetsUnion regarding the protection of privacy. Please view their privacy statements if you decide to use their services and consult your social media account settings if you want to deactivate certain features.

  8. Children's Privacy

    Mastercard NetsUnion's products and services are not directed to, or intended for, children under the age of 14.

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    Mastercard NetUnion's products and services are not directed to, or intended for, children under the age of 14. However, Mastercard NetsUnion may collect Personal Information about children under 14 directly from the parent or guardian with that person's explicit consent.

  9. Updates to This Privacy Policy

    This Privacy Policy may be updated periodically to reflect changes in our privacy practices.

    Learn More

    This Privacy Policy may be updated periodically to reflect changes in our Personal Information practices. We will post a notice on relevant websites to notify you of any significant or material changes to our Privacy Policy prior to them being effective and indicate at the top of the Privacy Policy when it was most recently updated. Your continued use of our website, our products and services or participation of our specific program after we update our Privacy Policy signifies your consent to such updated Privacy Policy.

  10. How to Contact Us

    You can contact us and our Personal Information Protection Officer by sending an email or calling us directly.

    Learn More

    If you have any questions, comments or dissatisfaction with this Privacy Policy and our privacy practices, or would like to update your privacy preferences, or would like to exercise your rights and choices with respect to your Personal Information, please contact us by sending an e-mail or postal mail to the address below, or you may call us directly during business hours on weekdays, and we will verify and process your rights request within fifteen (15) working days of receipt.

    Personal Information protection officer e-mail: privacy@mastercardnucc.com

    Address: Room 111, No. 101, Building 3, No. A29, Beisanhuan Middle Road, Xicheng District, Beijing, China Mastercard NetsUnion Information Technology (Beijing) Co., Ltd.

    Customer Service Hotline: (+86) 400-890-7888 (please follow the tone)

    For enquiries about your Mastercard card and your purchase, you should contact your financial institution or merchant. More information about how to contact them can be found on their respective websites.