Privacy Policy

2024.04 Version

This Privacy Policy (hereinafter referred to as “the Policy”) is provided by Quilter International Enterprise Co., Ltd. (hereinafter referred to as “Quilter” or “the Company”). The Policy is used to regulate the personal data collected, processed, and used on the Company’s website (hereinafter referred to as “the Website”) and the users (hereinafter referred to as “users” or “you”) of the mobile device application (hereinafter referred to as the “QCASH app”) created by the Company to provide remittance services for migrant workers.

By browsing the Website and starting to use the QCASH app provided by the Company, you will be deemed to have fully read, understood, and agreed to the contents of the Policy. In the case where the Policy is modified, added, or updated, if you continue to use the Website and QCASH app after the effective day, you will be deemed to have understood and agreed to the modification, addition, or update of the Policy.

The Company will actively protect your personal data in accordance with the “Personal Data Protection Act” and relevant laws and regulations of the Republic of China and will clearly inform you of the following matters in accordance with Article 8 of the “Personal Data Protection Act”.

Users may also choose not to provide your personal data to the Company. However, this choice may result in the Company being unable to continue to provide you with the services of the Website and QCASH app. Please understand.

A. Scope

The Policy covers the processing and use of personal data collected by the Company when you use the Website and QCASH app. The Policy does not apply to related websites other than the Website and QCASH app, nor does it apply to people who are not entrusted by or involved in the management of the Website or QCASH app.

B. Relevant regulations on the collection, processing, utilization, and international transfer of personal data
  1. The Company will provide users with small-amount foreign exchange services for foreign migrant workers through the QCASH app. In order to provide better services, the Company will collect, process, and utilize your personal data depending on the nature of the services provided. The Company will process and use your personal data within the scope of that specific purpose; the Company will not use your personal data for other purposes without your written consent.
  2. The length of time the Company retains users’ personal data will depend on the prescribed retention period (the longest period shall apply) of the specific contract or relevant laws (such as the “Regulations Governing Small Amount Remittance Services for Foreign Migrant Workers”, the “Money Laundering Control Act”, and the “Counter-Terrorism Financing Act”).
  3. The areas where the Company uses users’ personal data are the Republic of China, all areas provided by the Website and QCASH app, and areas where the Company regards it necessary to use your personal data based on business judgment in the future.
  4. Based on the Company’s policy of confirming customer identity, the Company will obtain your personally identifiable information through legal means, such as third-party services or internet searches.
C. Specific purposes of collection, processing, utilization, and international transfer of personal data
  1. Provide various business, accounts, or services between you and the Company (including but not limited to the product and service, the Website, and QCASH app);
  2. Market, promote, and provide our products or services to you;
  3. Collect, process, utilize, and transfer internationally personal data in accordance with the laws of the Republic of China and the national laws and regulations of the Company’s group members (including laws, administrative orders, letters from competent authorities), the needs of financial or money laundering and terrorism prevention supervision, legal obligations, contracts or quasi-contracts, or other legal relationships, etc.;
  4. The Company’s business registration items, businesses stipulated in the articles of association, or other items permitted by laws and regulations;
  5. The purpose of the Company’s business, operational management, or the management of its affiliated groups (including but not limited to management and services of the users and customers, marketing, provision of information and communication services, database management, information security and management, e-commerce services, administrative research, customer background, investigation, statistics and research analysis, auxiliary and logistical support, risk control, cross-selling, implementation of money laundering prevention and counter-terrorism operations, and cooperation with related investigations, etc.);
  6. Confirm the identity of the customer; the above-mentioned specific purposes are: 036 (Deposits and Remittances), 040 (Marketing, including financial cross-selling business), 063 (Collection, Processing and Use of Personal Data by Non-Governmental Agencies as Defined by Law), 069 (Contract, Quasi-Contract or Other Legal Relationship Matters), 090 (Consumer, Customer Management and Service), 094 (Property Management), 135 (Information/Communication Services), 136 (Information/Communication and Database Management), 137 (Information and Communication Security and Management), 148 (Online shopping and Other Electronic Commerce Services), 154 (Credit Investigation), 157 (Investigation, Statistics and Research Analysis), 181 (Other Business Operation in accordance with the Business Registration or the Articles of Association), and other provisions in accordance with the “Personal Data Protection Act” of the Republic of China or other applicable laws (including but not limited to the “specific purpose and the classification of personal information of the Personal Information Protection Act”), and any other specific purpose for you to exercise relevant rights and obligations, comply with laws, exercise legal obligations, detect and prevent illegal activities, etc. under the legal relationships established by your use of this product and service (including the User Terms of Service of the QCASH app, the Policy, other contracts, statements, consents, and other related documents).
D. Data Protection
  1. The purposes of the personal data collected by the Company include but are not limited to: membership management, cross-selling, financial supervision and inspection, survey statistics and research analysis.
  2. The Company will strictly protect users’ personal data. Internal personnel must obtain reasonable authorization under appropriate circumstances to use such data and retain relevant usage records.
  3. In the case where the Company entrusts other parties to provide services due to business needs, the Company shall also strictly require those parties to comply with confidentiality obligations.
E. Data Sharing and Disclosure
  1. The Company will never provide, exchange, rent, or sell any users’ personal data to other individuals, groups, private enterprises, or public agencies, unless a legal basis or contractual obligation is presented.
  2. For the purpose of your use and improvement of this product and service, without infringing upon your rights and violating relevant laws and regulations, the Company may provide, share, or transmit your personal data to third parties under the following circumstances:
    1. In order to provide this product and service, the Company shares or transfers your personal data with third parties when needed, including but not limited to the product’s affiliated companies assisting in certain business operations such as payment collection, marketing, customer identity confirmations, and technology services, or any other service providers determined by the product after reasonable judgment (i.e. not limited to affiliated companies).If you register or access this product and service, you are deemed to agree to share personal data with the above objects;
    2. In response to requests from administrative, judicial, and similar procedures, the Company may disclose personal data;
    3. In order to prevent personal injury or property damage, to report suspected illegal activities, etc., the Company reasonably believes that the disclosure of personal data is necessary;
    4. In the case where the Company intends to sell to, or merge with, a third party, and the Company and/or the business of this product and service are purchased, acquired, or merged with a third party, the Company may share, transmit, or disclose your personal data with such third party. The Company may also transfer or transmit such personal data when a company merger, division, dissolution, etc. is involved;
    5. In accordance with laws and orders;
    6. Based on public interest;
    7. The disclosure of the users’ personal data is necessary to identify, contact, or take legal action due to the fact that the users have violated the terms, or the users may damage or hinder the rights of the Website and other users, or cause harm to anyone.
  3. There may be links or services provided by third parties on the Website, QCASH app, and any services provided by the Company. Such a third-party website or service is not within the scope of the Company’s operation and management, and the Policy does not apply thereof. The Company also does not bear any legal responsibility for the collection, processing, and utilization of personal data by these third-party organizations. Users must read the privacy policy, service agreement, and terms on the third- party’s platform in detail when browsing its website or using the services.
F. Categories of Personal Data
  1. The Company collects, processes, and uses your personal information, including but not limited to: name, resident certificate number, passport number, nationality, gender, date of birth, place of birth, residence address, mobile phone number, email address , government-issued identity documents photo, passport photo, selfies of you and the aforementioned identity documents, bank account information, relevant bills, sources of funds, property, income, income, assets, and investments, specific data for accessing the Website (such as: IP address, browser information, login information, operating system and platform, time zone settings, browsing information, geographical location), etc.
  2. According to the “specific purpose and the classification of personal information of the Personal Information Protection Act”, the above legal categories of data include:
    1. Identification: C001 Identifying Individuals, C002 Identifying Financial Information, C003 Identifying Government Information,
    2. Characteristic: C011 Personal Description,
    3. Family: C021 Family,
    4. Social Condition: C031 Residence and facilities, C032 Property, C033 Immigration, C038 Occupation, C041 Courts, Public Prosecutor’s Office or Other Adjudicative Bodies or Proceedings,
    5. Employment: C061 Current Employment Status,
    6. Financial Detail: C081 Income, Earnings, Assets and Investments, C083 Credit Ratings,
    7. Business Information: C101 Data Subject’s Business Activities, C102 Agreements or Contracts,
    8. Health and Other: C116 Data Relating to Criminal Suspect,
    9. Other Kinds of Data and Information: C131 Retrieval of Written Documents, C132 Unclassified Data.
G. Rights and Approaches for Users
  1. Users may exercise the following rights in accordance with Articles 3 and 11 of the “Personal Data Protection Act”, except for the circumstances specified in Paragraph 2 of this Article:
    1. Inquire, request to view, or copy, but the Company may charge necessary costs and fees from the users in accordance with Article 14 of the “Personal Data Protection Act”.
    2. Request to supplement or correct personal data. However, users shall explain in accordance with Article 19 of the “Enforcement Rules of the Personal Data Protection Act”.
    3. Request to cease collecting, processing, or using personal data in the event of a dispute regarding the accuracy of the personal data, unless the processing or use is either necessary for the performance of an official or business duty, or has been agreed to by the users in writing, and the dispute has been recorded.
    4. Request to delete personal data when the specific purpose of data collection no longer exists, or upon expiration of the relevant time period, unless the processing or use is either necessary for the performance of an official or business duty or has been agreed to by the users in writing.
  2. In the case of the proviso in the preceding paragraph, in accordance with Article 10 of the “Personal Data Protection Act”, the Company will not be able to answer inquiries, provide viewing, or provide copies to users in the following circumstances:
    1. where national security, diplomatic or military secrets, overall economic interests or other material national interests may be harmed;
    2. where a government agency may be prevented from performing its statutory duties; or
    3. where the vital interests of the data collectors or any third parties may be adversely affected.
H. Governing Law and Court

The governing law of the Policy is the laws of the Republic of China and will be interpreted in accordance with the laws of the Republic of China (including but not limited to the validity, interpretation, performance, and enforcement of the Policy, or any disputes or controversies arising out of or related to the Policy). Any disputes, controversies, inconsistencies, claims arising out of or related to the Policy, or issues regarding the violation, termination, or invalidity of the Policy, shall be settled by the Taiwan Taipei District Court as the exclusive jurisdiction court of first instance.

I. Modifications to Policy and Contact Quilter
  1. In response to changes in laws, business needs, technological development, etc., the Company will revise the Policy from time to time without further notice to you. You can read it on the Website and QCASH app at any time to protect your rights and interests.
  2. The Policy is written in Chinese. If there are any versions in other languages and if there is any inconsistency in the content, the Chinese version shall prevail.
  3. If having any questions about the Policy or need to exercise the relevant rights above, you shall contact the Company through the channels published on the Website. The Company will respond as soon as possible after confirming your identity.