LFPayນະໂຍບາຍຄວາມເປັນສ່ວນຕົວ

LFPay Privacy Policy

Latest Revision Date: November 10, 2025

Effective Date: November 10, 2025

Introduction

This Privacy Policy applies to the payment products and services and their extended functions (hereinafter referred to as "LFPay Services") provided by Lao Fintech Technology Company Limited (hereinafter referred to as "we", "us", or "our"). If a specific product we provide has a separate privacy policy or terms, the privacy policy or terms of that product shall prevail; for matters not covered by that product's privacy policy or terms, this Privacy Policy shall apply.

Lao Fintech Technology Company Limited is registered in Vientiane, Lao People's Democratic Republic (Lao P.D.R.), with the office address at Ban Phone Tan, Xaysetha District, Vientiane, Lao P.D.R. The customer service telephone number is 02057612200, and the official website address is www.lfpay.la.

We have always attached great importance to protecting the personal information and privacy of our users (hereinafter referred to as "you"). We provide services to you in accordance with the provisions of this "LFPay Privacy Policy" (hereinafter referred to as this "Policy"). When you use LFPay Services, in order to fulfill legal obligations, or as necessary to provide services to you, or to provide you with quality services, continuously optimize user experience, and ensure the security of your account, we may process (including collect, store, use, provide, etc.) your personal information. Through this Policy, you can understand how we process your personal information, your various rights regarding the processing of personal information, and how you can exercise these rights.

This Policy will help you understand the following:

I. Your Rights

II. How We Collect Information

III. How We Use Cookies and Similar Technologies

IV. How We Store and Protect Information

V. How We Use Information

VI. How We Disclose Information to Third Parties

VII. Circumstances Where Processing Personal Information Does Not Require Your Consent

VIII. How We Protect the Rights of Minors

IX. How This Policy Is Updated

X. Contact Us

I. Your Rights

Based on payment methods such as wallet balance payment, quick bank card payment in LFPay wallet, and payment methods provided by cooperative institutions, we provide you with a variety of payment products and corresponding LFPay Services. You can use LFPay Services for consumption (such as making utility payments to public institutions, paying for goods or services to e-commerce service providers or offline merchants) or for transferring money to others, sending/receiving red envelope funds, repaying credit cards, etc.

During your use of LFPay Services, to facilitate your exercise of your rights regarding personal information such as access, copy, correction, supplementation, and deletion, we have provided corresponding operational settings in our product pages. You can refer to the guidance below for operation. Additionally, you can contact us using the contact methods described in Section X of this Policy and submit requests to exercise relevant rights.

1. Access and Copy Your Personal Information

(1) When using LFPay for payments, you can access your personal information by entering "Me - Personal Information"; you can also view your transaction records such as withdrawals, deposits, refunds, consumption, transfers, and red envelopes by entering "Me - Personal Account - My Balance - Transaction Details".

(2) For the security of your personal information, parts of your name, ID number, and bank account information may be displayed with asterisks "".

2. Correct and Supplement Personal Information

(1) When using LFPay, you can modify information such as document validity period, occupation category, address, and mobile phone number by entering "Me - Personal Information". If you find your information is inaccurate or incomplete, you can click to apply for correction or supplementation.

(2) If you find any errors in the personal information we have collected or stored about you, you can contact our online customer service or call the customer service hotline to request correction or supplementation.

3. Delete Your Personal Information

(1) When using LFPay, you can delete your transaction bill information one by one on the front-end page by entering "Me - Personal Account - My Balance - Transaction Details".

(2) After you or we assist you in deleting relevant information, due to statutory storage periods not expiring, or if deletion is technically difficult, we may not be able to immediately delete the corresponding information from the system. In such cases, we will cease processing your personal information except for storage and taking necessary security protection measures.

4. Stop Using Part of the Services and Functions

(1) Stop using bank card quick payment or withdrawal functions.

When you are using quick bank card payment within LFPay, after entering LFPay, go to "Me - Personal Account - Bank Cards" -> select the bank card you want to unbind -> click the top right corner -> click "Unbind" -> enter payment password -> unbinding successful. After you unbind a bank card, you will no longer be able to use that card for quick payment or use that debit card for withdrawals.

(2) Refuse to receive marketing information.

If you do not wish us to send you financial marketing information as described in Section V(2) of this Policy, you can refuse or turn off this function by following our prompts. After turning it off, you will not receive financial marketing information from us.

(3) Turn off personalized services.

If you do not wish us to provide you with personalized services using automated decision-making as described in Section V(3) of this Policy, you can turn it off by following our prompts. After turning it off, you may still see product/activity information or advertisements on relevant service pages, but personalized services will not be provided to you via automated decision-making.

5. Cancel LFPay Account

(1) Cancel LFPay Account. You can enter LFPay "Me - Personal Account - Cancel Account", click "Account Cancellation". If your account meets the cancellation conditions indicated on the page, you can proceed to cancel your LFPay account.

(2) After cancellation, all information within your relevant account will be cleared. We will no longer process personal information related to that account, but we are still required to retain previous information for the period stipulated by regulatory requirements, and state authorities still have the right to lawfully query it during the legally prescribed retention period.

6. If the product pages or access paths related to the above guidance change, you can operate according to the updated product pages. If you are unable to perform operations such as accessing, copying, correcting, supplementing, transferring, deleting, turning off, withdrawing consent, or canceling your account regarding your personal information through the above methods, or if you need an explanation of personal information processing rules, you can contact us via the contact methods described in Section X of this Policy or through online customer service. We will respond to your request promptly and process it within the timeframe specified in Section X of this Policy.

7. For the security of your account and personal information, when you submit requests to us to exercise rights such as access, copy, correction, supplementation, deletion, transfer, or withdrawal of consent, we will verify your identity through various means. You may need to enter your payment password, use facial recognition, or provide materials such as your name, ID number, contact information, and specific request content before we can process your request. Specific methods are subject to the product pages.

II. How We Collect Information

During your use of LFPay Services, based on different situations and for the purposes of fulfilling legal obligations, providing services to you, and ensuring your account security, we will collect information you actively provide or information generated from using the services in the following ways:

1. Circumstances where information collection is required to fulfill statutory obligations for real-name system management and anti-money laundering.

(1) In accordance with laws, regulations, and regulatory requirements related to payment business, when you register an LFPay account or use LFPay Services, you need to actively provide your basic identity information (including name, nationality, gender, occupation, address, contact information, as well as the type, number, and validity period of your valid identification document). If you do not provide the aforementioned information, you will be unable to register a payment account or use LFPay Services. If you need to pass multi-factor identity verification, you should also provide your bound bank card information and the mobile phone number reserved with the bank. If you do not provide the aforementioned information, you will be unable to use LFPay Services that require multi-factor identity verification.

(2) In accordance with anti-money laundering laws, regulations, and regulatory requirements, when you register an LFPay account or use LFPay Services, you need to actively provide your basic identity information (including name, nationality, gender, occupation, home or work unit address, contact information, as well as the type, number, and validity period of your valid identification document). In specific circumstances stipulated by laws, regulations, or regulations, you may also need to provide a color photo or copy of your valid identification document for our verification and retention. According to laws, regulations, and regulatory requirements, you may also need to provide other auxiliary identity proof materials or re-provide your identity information. If you cannot or refuse to provide necessary information, resulting in our inability to fulfill anti-money laundering obligations, we may take restrictive measures or refuse to provide LFPay Services to you.

To verify the accuracy and completeness of the information you submit, we may cross-check the information you provide with external verification channels that lawfully store your information (including government databases, commercial bank information systems, and commercial databases) to verify the authenticity and accuracy of the information you provide.

2. Circumstances where information collection is required for you to use the payment services we provide.

To provide you with payment services and to fulfill relevant legal obligations, we need to directly collect your personal information, specifically as follows:

(1) To enable you to use balance payment services based on your payment account (including LFPay wallet balance), and to realize functions such as depositing/withdrawing from your payment account balance, consumption, transfers, red envelopes, and other extended functions based on the payment account, we will record your payment account balance information and transaction information. If you do not agree to the recording of the above information, you will be unable to use balance payment services.

(2) To enable you to use bank card quick payment services, and to realize functions such as depositing/withdrawing to/from your payment account balance using a bank card, and consumption, transfers, red envelopes, and their extended functions based on a bank card, you need to bind your bank card to your payment account and provide information such as your name, bank card number, ID document number, and the mobile phone number reserved with the bank. We will provide this information to legal clearing institutions for verification by the issuing bank. If you do not provide the above information, you will be unable to use bank card quick payment services, but this will not affect your use of other functions we provide.

(3) To enable you to use the transfer service, you need to provide, as prompted on the product page, information such as the recipient's mobile phone number, partial name information, transfer amount, etc., or select the recipient and provide the recipient's partial name information and transfer amount; if you choose to use the function of transferring to another person's bank card, you need to provide the recipient's name, bank card number, bank name, and transfer amount. If you do not provide the above information, you will be unable to use the transfer service, but this will not affect your use of other functions we provide. At the same time, you can also fill in a transfer note; if you do not provide this information, it will not affect your use of the transfer service. Also, when you choose to use the paste function to fill in recipient information, we will read the clipboard content on your device to allow you to paste recipient information into the relevant page; you can also fill in the transfer note yourself; if you do not fill in a transfer note, it will also not affect your use of the transfer service.

(4) To enable you to use the red envelope service, you need to select the sending target and enter the red envelope amount as prompted on the product page; if you do not provide the above information, you will be unable to use the red envelope service, but this will not affect your use of other functions we provide. At the same time, you can also fill in red envelope greetings; if you do not provide this information, it will not affect your use of the red envelope service function.

(5) When you use the credit card repayment service, you need to provide the credit card number, name, and repayment amount for the credit card you want to repay. If you do not provide the above information, you will be unable to use the credit card repayment service, but this will not affect your use of other functions we provide.

(6) When you use utility payment services (including electricity, water, gas, landline, broadband, cable TV, oil card top-up, ETC application, etc.), you may need to provide your phone number, name, ID number, and other necessary payment information (such as payment unit, user number, fixed-line number, broadband number, oil card number, license plate number, engine number, frame number, etc.) based on the specific scenario you are using. If you do not provide this information, you will be unable to complete the corresponding utility payment, but this will not affect your use of other functions we provide. Additionally, to determine the specific types of utility payments available in your area, we may request access to your location permission and location information. You can click to agree to enable it according to the page prompt at that time. If you do not agree to enable this permission, you can manually select your city, which will not affect your subsequent use of our utility payment services.

(7) To fulfill relevant legal obligations and to provide you with payment and transaction query services, we need to record and manage transaction information. We need to directly collect, record, or collect through partners information related to your transactions, including transaction order number, information of the transaction parties (such as payer/payee name, nickname, remark name, avatar, merchant name, etc.), account information (including payer/payee payment account number, bank card number, issuing institution name, etc.), transaction amount, transaction time, product information, payment method, delivery information, etc. If you do not agree to the recording of transaction information, the transaction cannot be completed.

(8) If you use other service functions we provide that involve our collection of your personal information, we will explain the scope and purpose of information collection to you through separate agreements, product pages, etc., and obtain your consent, except where laws and regulations do not require individual consent. We will process and protect your information in accordance with this Policy or the relevant service agreement; if you choose not to provide it, it will not affect your use of other LFPay Services.

3. Information collected for your account, fund, payment security, and risk prevention.

(1) When you initiate a transaction using LFPay Services, to ensure the security of your account and funds, we need to perform transaction verification. Verification methods may include static passwords, one-time passwords, digital certificates, biometric information, etc. Depending on the transaction scenario and security risk, we may collect authentication information such as payment passwords, ID numbers (for digital certificate activation), SMS dynamic codes, etc., to verify your identity when you initiate a transaction. When you activate and use biometric-related payment services (such as facial recognition payment, palm print payment) in specific scenarios, we may also collect biometric information (such as facial information, palm information). You can understand specific rules through the relevant service agreement. If you have not activated biometric-related payment functions, you will be unable to use the above payment services, but this will not affect your use of other payment service functions.

(2) To enable you to use payment services securely, if your mobile phone and client software version support fingerprint verification, you can choose to activate the fingerprint payment function we provide. You need to input your fingerprint information on your device. Your fingerprint information is only stored on your device; we do not obtain it. When you use fingerprint verification, the extraction and verification of fingerprint feature information are completed on your device terminal. We only obtain the verification result completed by the terminal device. If you do not activate the fingerprint function, you will be unable to use fingerprint payment, but this will not affect your use of other verification methods such as entering a password.

(3) To enable you to use payment services securely, if your mobile phone and client software version support facial verification, you can choose to activate the facial recognition payment function we provide. You need to input your facial information on your device. Your facial information is only stored on your device; we do not obtain it. When you use facial verification, the extraction and verification of facial feature information are completed on your device terminal. We only obtain the verification result completed by the terminal device. If you do not activate the facial recognition function, you will be unable to use facial recognition payment, but this will not affect your use of other verification methods such as entering a password.

(4) To ensure the security of your account and funds, when you need to retrieve passwords, apply to freeze/unfreeze an account, request removal of transaction restrictions, request electronic receipts, etc., we may verify your identity. You need to provide us with some information that can verify your identity or transaction, such as name, document type, ID number, bank card number, mobile phone number reserved with the bank, copy of ID document, photo holding ID, contact information, proof of transaction occurrence, documents proving your legal rights to the payment account and account funds, etc. Specific requirements are subject to product page prompts or customer service requests. If you do not agree to provide such information, you will be unable to complete the relevant operation, but this will not affect your completion of other operations or use of other services we provide.

(5) To fulfill legal obligations such as anti-money laundering, anti-telecom network fraud, and risk management stipulated by laws and regulations, and to improve the security of your use of our services, better prevent transaction and fund risks, we may collect information related to the devices, system networks, risk information, and operational behaviors associated with your use of the services from you and merchants you transact with during your use of LFPay Services. This includes payment terminal information, unique device identifiers (such as MAC, IMEI, OAID, UUID, and other identifiers that can recognize the device), hardware device model, terminal system information, gyroscope sensor information, software installation information, software version information used, software language settings, Internet Protocol (IP) address, mobile network information (such as Wi-Fi information), device location information, region, network logs, internet usage habits, and records of your operational behaviors when using LFPay Services. If you do not agree to provide the above information, it may affect security verification of the transaction environment and transaction notifications. At the same time, to prevent viruses, Trojan horses, or other malicious programs or websites, we may collect information about running processes on your device applications and device parameter information to assess account security and transaction security.

4. Indirectly Collecting Information through Use of Third-Party Services

If you use our payment services through other channels, we may need to obtain your personal information from third parties. Matters not stipulated in this Policy will be disclosed to you before obtaining, indicating the source, type, and scope of use of the personal information. If the personal information processing activities required for our business operations exceed the scope agreed in the agreement or the authorization you originally gave to the third party, we will obtain your explicit consent before processing such personal information of yours, unless otherwise stipulated by laws and regulations. Furthermore, we will strictly comply with relevant laws and regulations and require third parties to ensure the legality of the information they provide.

5. Exclusion Clause for Third-Party Information Collection

If you enter third-party product pages through the products we provide, please note that third-party services are provided by third-party entities. For matters involving third parties directly collecting your personal information, it is recommended that you carefully review the third party's privacy policy or regulations.

III. How We Use Cookies and Similar Technologies

1. When you use LFPay Services, we may save your login status and assign one or more "Cookies" (a very small text file) to you. For example, when you visit information or services that require login, when you log in, we encrypt and store your login name in the Cookie file on your computer. Since it is irreversibly encrypted storage, even if others use your computer, they cannot recognize your login name. You do not need to do any extra work; all collection, saving, and encryption are done automatically by the system.

2. Cookie files are saved on your computer's hard drive or the device terminal's flash memory and can only be read by the server that set them. You can delete them at any time using a browser or operating system software with built-in Cookie clearing functionality.

3. To provide you with more convenient, fast, and smooth services, we use Cookie and other technologies to provide you with the following services:

(1) Remember your account. For example, Cookies may help you avoid the step of repeatedly entering your account to use LFPay Services.

(2) Analyze your use of LFPay Services. For example, we can understand the specific purposes for which you use LFPay Services or which web pages or services are most popular with you through Cookies and similar technologies.

(3) You can also choose "Do Not Use Cookies" through your browser settings. However, if you choose to do so, it may affect your use of LFPay Services, or you may not enjoy more secure, fast, and smooth services, but it will not affect your normal use of other services we provide.

(4) Cookie technology may also be used by LFPay's third-party advertising partners. The collection and use of such information by these third parties through Cookies are not subject to this Policy but are subject to the third party's privacy policy. We recommend that you carefully read and decide for yourself whether to be subject to the third party's privacy policy before using services provided by third parties through Cookies.

IV. How We Store and Protect Information

1. In accordance with relevant laws and regulations, we store your personal information collected within the territory of the Lao P.D.R. within the Lao P.D.R. and keep such information strictly confidential according to the law.

2. We will store your personal information based on the necessity of your use of LFPay Services and within the time limits stipulated by laws, regulations, or regulatory requirements. For example, we will retain your identity information, transaction information, etc., for the period stipulated by laws, regulations, or regulatory requirements such as the Payment Systems Law, Consumer Protection Law, Anti-Money Laundering and Counter-Terrorist Financing Law, etc. After exceeding the period stipulated by laws, regulations, or regulatory requirements, we will delete or anonymize your personal information as required by laws and regulations.

3. To ensure the security of your information, we will take reasonably necessary measures within the existing technical level to protect your information, adopting physical protection, security technology, management systems, and other measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration, including de-identification, encrypted data transmission, firewalls and encrypted storage, physical access control, and information access authorization control. For this purpose, we have set up security procedures to protect your information from being accessed and stolen by unauthorized persons. All personal information is encrypted and stored in internal systems strictly protected by firewalls.

4. To ensure the security of your information, we have established specialized management systems, procedures, and organizations to safeguard information security. For example, we strictly limit the scope of personnel who can access information, require them to comply with confidentiality obligations, and conduct audits.

5. When you use LFPay Services, please properly keep your LFPay account and its password safe. We identify you through your account and its password. Once you disclose your LFPay account and its password, you may lose your information and may face adverse legal consequences. If you find that your LFPay account and its password have been or may be disclosed for any reason, please contact us immediately so that we can take timely measures to prevent or reduce related losses.

6. In the event of a personal information breach or other security incident, we will activate emergency plans to prevent the expansion of the security incident and promptly inform you of the above security incident via push notifications, phone calls, announcements, etc. If we are unable to contact you using the above methods, we will publish relevant warning information on the LFPay official website. Please pay close attention to the LFPay official website.

7. If you actively cancel your LFPay account and terminate the use of LFPay Services, we will stop processing your personal information, unless otherwise stipulated by laws, regulations, or regulatory authorities. If our product or service ceases operation, we will also stop processing your personal information in a timely manner. At the same time, we will notify you of the cessation of operation by delivering notices individually or through an announcement on the LFPay official website, and we will delete or anonymize your stored personal information, unless otherwise stipulated by laws and regulations.

V. How We Use Information

(1) Based on legal and regulatory provisions, regulatory requirements, and agreement stipulations, we will use your personal information in the following circumstances and will take adequate information security measures to ensure the security of personal information during use:

1. For the collection purposes stated above and to provide you with LFPay Services.

2. For purposes related to services and stipulated by laws and regulations, such as identity verification, customer service, anti-money laundering customer due diligence, anti-money laundering beneficial ownership identification, security protection, risk warnings, transaction monitoring, preventing or prohibiting illegal activities, archiving, and backup. According to laws and regulations and regulatory requirements such as the Anti-Money Laundering and Counter-Terrorist Financing Law and Payment Systems Law, if you open multiple payment accounts with LFPay, we will take effective measures to establish correlations between the payment accounts and manage them uniformly per customer; to enhance your service experience, and subject to necessary verification of your identity, we may use identity information you have previously provided during your use of our services to avoid you having to resubmit it; meanwhile, based on corresponding risk management mechanisms and procedures, we will implement effective risk management measures on the business you request to handle, such as limiting transaction quantity, type, or amount, strengthening transaction monitoring, etc.

3. Used for data analysis, application research, comprehensive statistics, and operational decision-making after taking security measures such as de-identification or anonymization.

4. Used to resolve disputes related to you.

(2) To improve the user experience of our products and services, we may use the collected information for marketing, user experience improvement, or market research purposes. If you agree to our use of the collected information for the aforementioned purposes, you may receive a better user experience, or receive marketing information that may interest you, or participate in our market research activities. If you do not agree to our use of your information to send you marketing information, you can contact customer service to understand the specific situation and unsubscribe; if you do not agree to our use of your information for marketing, user experience improvement, or market research purposes, you can also call our customer service hotline or adjust/unsubscribe according to our prompts. If you choose to unsubscribe, we will not continue to use the collected information to send you marketing information, and you can still use the products and services we provide according to the agreement.

(3) To meet users' personalized service needs, we may also use the collected information to display product information or commercial marketing information on relevant pages through automated decision-making. If you do not wish to have product information or commercial marketing information displayed based on your personal characteristics, you can contact customer service for details and to turn it off, or follow the prompts on the product page to turn it off. The aforementioned automated decision-making refers to activities where computer programs automatically analyze and evaluate an individual's behavioral habits, interests, preferences, etc., and make decisions.

(4) If we intend to use your personal information for purposes not specified in the agreement or this Policy, or beyond the scope directly or reasonably related to the purposes stated at the time of collection, we will seek your consent again in accordance with legal requirements, such as through click-to-confirm agreements or click-to-confirm actions in specific scenarios, before using your personal information again, unless laws and regulations stipulate that individual consent is not required.

VI. How We Disclose Information to Third Parties

(1) Disclosure to Third Parties

We keep your personal information strictly confidential. For the purpose of providing services to you, or fulfilling legal obligations, or with your consent, under any of the following circumstances, we will share your information with third parties. Third parties include our affiliated companies, cooperative financial institutions, state authorities, and our partners (hereinafter referred to as "third parties"). Before sharing information with third parties, we will conduct assessments in accordance with legal requirements, and ensure the security of your personal information by signing legal documents with third parties, requiring them to take necessary security measures or possess corresponding data security capabilities (such as possessing cybersecurity level protection certificates, completing relevant information security standard certifications, etc.), and require them to process your personal information lawfully and compliantly. At the same time, where your consent is required, we will inform you as required and seek your consent through methods such as click-to-confirm agreements or click-to-confirm actions in specific scenarios. Specific circumstances are as follows:

1. For you to use certain services or product functions, we need third-party assistance or cooperate with third-party products to provide services. Only when necessary information is provided to third parties can the corresponding services be provided to you.

2. To comply with laws and regulations and to process your bank card transactions and provide you with bank card quick payment services, we will provide your name, ID number, ID type, card number information, and transaction information to the issuing bank through clearing institutions. Transaction information includes transaction type, transaction order number, merchant name providing goods or services, names and accounts of payer/payee, transaction date, transaction time, transaction amount, terminal information, etc. If you do not agree to our provision of such information to clearing institutions and issuing banks, you will be unable to use our payment services. Additionally, to facilitate the smoother completion of your transactions, we may provide relevant transaction information to the issuing bank of your bound bank card through clearing institutions to determine whether the transaction can be completed.

3. To process your payment collection and disbursement, we may provide your information to your transaction counterparty. For example, when a third party uses LFPay Services to transfer money to your LFPay account, they may provide your mobile phone number and name associated with your LFPay account. We will provide part of your registration information to the third party so they can confirm if the recipient information is correct. When you make payments to payees, domestic or international merchants, through the services we provide, we will send necessary information such as user identification information and transaction information to the payee, cooperative institutions (including clearing institutions, acquiring institutions), and merchants to help you complete the transaction; to prevent transaction risks, we may also send necessary risk information to transaction-related cooperative institutions and merchants. If you do not agree to our provision of such information, you will be unable to use our payment services.

4. When you use LFPay Services through a third party, where necessary to provide services to you, we may also share some necessary information about you with the third party. If you do not agree to provide such information, you may be unable to use the services provided by the third party. For example, when you purchase goods or services through a third-party platform and pay via LFPay Services, we will provide and send relevant payment information to the third party to help you complete the transaction.

5. When you log into third-party websites using your LFPay account, to enable you to conveniently and quickly use services related to the third-party website, we may, based on your explicit authorization, provide part of your personal information to the third party. Such third-party websites are governed by their own privacy protection rules. Therefore, before providing your personal information to a third party, it is recommended that you carefully review the third-party website's personal information processing rules.

6. We may cooperate with third parties to hold joint marketing activities and share some necessary information generated during the joint marketing activities with the third party to enable your participation, allow our partner to contact you promptly, and distribute prizes. We will clearly inform you through agreements, activity rules, etc., on the activity page what personal information needs to be provided to the third party.

7. If you are complained against by others or you initiate a complaint (such as transaction denial, etc.), we will provide complaint-related information such as your identity information and transaction information to consumer rights protection departments, cooperative banks, clearing institutions, industry self-regulatory organizations, and regulatory authorities involved in complaint handling, for resolving complaint disputes, unless expressly prohibited by laws and regulations.

8. To comply with laws and regulations, maintain a good financial order, prevent telecom network fraud and other fraudulent activities, reduce credit risk, and maintain the safe and stable operation of the services provided, we may exchange necessary risk information with entities operating finance-related organizations (such as commercial banks, clearing institutions, payment institutions, industry self-regulatory organizations, etc.).

9. To prevent fraud risks, ensure transaction security, and protect your personal and property safety from infringement, in specific transaction scenarios, we will provide you with services such as order status reminders and transaction progress confirmation. When you use such services, we will use user identification information and order information (including order number, order amount, order time, order status, etc.) related to your transaction.

10. To facilitate your use of credit card quick payment services and properly arrange your repayment plan, you agree that LFPay will encrypt and transmit your credit card number to your credit card issuing bank, and agree that your credit card issuing bank authorizes LFPay to display to you information such as eligibility, interest rates, promotional activities, etc., corresponding to credit card installment repayments. Matters related to your credit card installments are independently evaluated and approved by your credit card issuing bank; LFPay is not involved. Your credit card installment information is subject to the information ultimately confirmed by your issuing bank.

11. When state administrative organs or judicial authorities require us to provide your identity information, account information, transaction information, and other payment information in accordance with laws, regulations, and regulatory requirements, we will cooperate and provide such information in accordance with the requirements of the state administrative organs or judicial authorities.

12. Disclosure of your personal information to third parties based on other agreements between you and us regarding information sharing or based on your separate consent obtained in specific scenarios.

(2) Entrusted Processing

To improve the quality and efficiency of information processing, within the scope permitted by laws and regulations, we may entrust capable cooperative institutions to process information on our behalf. We solemnly promise that we will comply with relevant regulations on entrusted processing in laws and regulations, fully review and evaluate the ability of such cooperative institutions to protect personal information, require cooperative institutions to strictly comply with confidentiality obligations through written agreements, audits, etc., take technical measures to de-identify entrusted information, and prohibit them from using such information for purposes beyond those stipulated by laws and regulations and agreed upon by both parties, as well as unauthorized purposes. When the entrustment relationship is terminated, we will require the cooperative institution to no longer retain the relevant information.

(3) Transfer

In the event of merger, division, dissolution, acquisition, asset transfer, asset reorganization, bankruptcy liquidation, etc., if it involves transferring your personal information to a third party, we will inform you of the name or title and contact information of the recipient, and require the new company or organization holding your personal information to continue to be bound by this Policy.

(4) Public Disclosure

We will not publicly disclose your personal information. If public disclosure is necessary, we will inform you of the purpose of disclosure, the type of information to be disclosed, and possible sensitive information involved, and seek your separate consent, unless otherwise stipulated by laws and regulations.

VII. Circumstances Where Processing Personal Information Does Not Require Your Consent

According to relevant laws and regulations, processing your personal information does not require your consent under any of the following circumstances:

1. It is necessary for the conclusion or performance of a contract between you and us;

2. It is necessary for us to perform statutory duties or statutory obligations;

3. It is necessary to respond to public health emergencies, or in emergency situations to protect the life, health, and property safety of you or other natural persons;

4. It is for the public interest in implementing news reporting, public opinion supervision, and other acts, and processing your personal information within a reasonable scope;

5. Processing your personal information that you have made public yourself or that has been lawfully made public by others, within a reasonable scope;

6. Other circumstances stipulated by laws and regulations where your consent is not required.

VIII. How We Protect the Rights of Minors

1. We attach great importance to the protection of minors' personal information. According to relevant laws and regulations, if you are a minor under the age of 18, it is recommended that your parent or guardian carefully read this Policy and submit your personal information after obtaining the consent of your parent or guardian. It is also recommended that you use our services under the guidance of your parent or guardian. If your parent or guardian does not agree to your submission of your personal information or your use of LFPay Services, please immediately stop submitting information or using our services, and notify us as soon as possible so that we can take effective measures.

2. If you are a minor under the age of 18, for the collection of your information with the consent of your parent or guardian, we will only use such information when permitted by laws and regulations and with the explicit consent of your parent or guardian.

3. If you are the parent or guardian of a minor, please contact us using the contact methods described in Section X of this Policy if you have any questions regarding the personal information of the minor under your guardianship.

4. We have also specifically formulated the "LFPay Children's Privacy Protection Statement" to protect children's personal information. Before children activate and use our payment services, children and their guardians should also carefully read the "LFPay Children's Privacy Protection Statement."

IX. How This Policy Is Updated

1. When this Policy undergoes significant changes, we will update this Policy in a timely manner and notify you promptly through any of the following methods. If re-obtaining your consent is required by law, we will seek your consent again.

(1) Pop-up reminder when you log into the relevant client software or use LFPay Services;

(2) Pop-up reminder when you update the client software version;

(3) Push short message notifications, emails, etc., to you when you use LFPay Services;

(4) Announcement on the LFPay official website.

2. Significant changes to this Policy include any of the following circumstances:

(1) Major changes to the service models we provide, such as changes in the purpose of processing personal information, the types of personal information processed, the ways personal information is used, etc.;

(2) Major changes in our entity, such as business adjustments, bankruptcy, mergers and acquisitions causing changes in ownership, etc.;

(3) Changes in the main recipients to whom personal information is disclosed or publicly disclosed;

(4) Changes in the retention period or destruction deadline of personal information;

(5) Major changes in the paths and methods for you to exercise your rights regarding personal information;

(6) Changes in the department responsible for personal information protection, contact methods, and complaint channels;

(7) When a personal information protection impact assessment indicates a high risk.

X. Contact Us

If you have any questions about this Policy, or any related complaints or suggestions, please call us at 02057612200. You can also send your questions to LFT@lfpay.la or mail them to the following address: Financial Legal & Compliance Department, Lao Fintech Technology Company Limited, Vientiane, Lao P.D.R. (Attn: Receiver). We will review the issues involved as soon as possible and, after verifying your identity, handle them promptly and reply within a maximum of fifteen (15) days or within the period stipulated by laws and regulations.

Lao Fintech Technology Company Limited