Privacy Agreement

Introduction 

     This platform is a special platform designed for users to trade in digital assets and to provide related services (hereinafter referred to as "The Service" or "Services"). For the convenience of expression, the platform is jointly referred to as "we" or other first-person names in this Agreement, as long as the natural person or other subjects who land on the platform are users of the platform, the following use "you" or other second person, we and you are collectively known as "both parties", we or you are only called "one-party".

     We fully understand and respect the importance of your personal information to you, and we will take corresponding security measures to protect and protect your personal information as required by laws and regulations. In view of this, develop this Privacy Policy ("This Policy / this Privacy Policy") and remind you that:

      This policy applies to all of the products and services that we provide. If we have a separate privacy policy for the product or service provided by you, its separate privacy policy shall apply; if our product or service has no separate privacy policy, this policy shall apply.

      In particular, this policy does not apply to other services provided to you in the third direction, and the services provided to you shall apply to the privacy policy otherwise stated to you.

     Before using our products or services, you are sure to carefully read and thoroughly understand this policy, especially the terms marked in bold/bold underline, and you should focus on reading and start the use after confirming full understanding and consent. If you have any questions, comments or suggestions about this policy, you can contact us through the various contact information provided by our authorities. If you do not agree to any provision of this policy, you should immediately stop having access to this platform.

Definition

      Personal information: refers to all kinds of information recorded electronically or in other ways that can identify the identity of a specific natural person alone or in combination with other information or reflect the activities of a specific natural person.

      Personal sensitive information: refers to personal information including identity certificate number, personal biometric information, bank account number, property information, whereabouts track, transaction information, children under the age of 14 (including) information, etc. (we will significantly identify the specific personal sensitive information in bold in this Privacy Policy).

    Personal information deletion: refers to the behaviour of removing personal information in the system involved in realizing the function of daily business, so that it can not be retrieved and accessed.

       Children: refers to a minor under the age of 14.

Part II, the Privacy Policy

This Privacy Policy section will help you understand the following:

1. How do we collect and use your information
2. How do we use Cookie and similar technologies
3. How do we share, transfer, and publicly disclose your information
4. How do we protect your information
5. How do you manage your information
6. How do we deal with the information of minors

VII. How to update this privacy policy

VIII. How to contact us

I. How do we collect and use your information

    The personal information you need to collect and use when you need / may need to use with our products and/or services includes the following two types:

1. You must authorize the necessary information to collect and use, to provide you with our products and/or services. If you refuse to provide the appropriate information, you will not be able to use our products and/or services normally;
2. To achieve additional functions to provide you with our products and/or services, you may choose to authorize the information we collect and use. If you refuse to provide it, you will not be able to use the relevant additional functions or achieve the functions we intended, but will not affect your normal use of the basic functions of our products and/or services.

You understand and agree that the:

1. We are committed to building a wide variety of products and services to meet your needs. Because we have many kinds of products and services to provide you, and the specific product/service scope that different users choose to use, the basic/additional functions and types and scope of personal information collected and used will vary, the specific product / service function shall prevail;
2. In order to bring you a better product and service experience, we continue to strive to improve our technology, and then we may have to introduce new or optimized features from time to time, and we may need to collect, use new personal information, or change the purpose or way that personal information is used. In this regard, we will separately explain to you the collection purpose, scope and use method of the corresponding information by updating this policy, pop-up window and page prompts, and provide you with the way of independent choice and consent, and collect and use it after obtaining your express consent. In the process, if you have any questions, comments or suggestions, you can contact us through the various contact information provided by the platform, and we will answer for you as soon as possible.

     We will collect and use your personal information to implement the functions described in this policy:

(1) Help you to register and provide you with the services provided by the platform;

1. Registration service

    We provide you with basic membership services through this platform account. To register to become a member and use our membership services, you need to fill in and provide the following information when applying for registration:

(1) Identity information. This information can help us verify whether you are eligible to register as a member of the platform, including but not limited to your name, your residence address, other certificates issued by your country or government with your identity information, and all other information that can help us to verify your identity (hereinafter referred to as "Identity Information"). This identity information varies specifically depending on whether you are an individual or an institutional user, and the information we collect for users from different countries or regions may vary according to laws and regulations across jurisdictions. The following information and data serve as an indicative example:

Personal user: nationality, legal full name (including the name and local language name), ID number, email address, telephone number, social security number ("SSN"), passport number or any government-issued ID number, date of birth, identification (e. g. passport, driver's license or identification issued by the government).

Institutional users: company legal name (including legal name of local language), registration information, business telephone number, authorized representative and authorized user personal information, main place of business, personal information of all beneficial owners), shareholder / beneficial owner identity documents (passport or government-issued id card), company architecture, relevant documents, board resolution, source of funds, risk and compliance control instructions and other information or documents required by the platform.

(2) Service information. This information helps us to contact you and successfully provide you with different modes of digital asset transaction services, including, but not limited to, your personally identifiable information, contact information, transaction information, and your debit card information and/or other account information (hereinafter referred to as the "Service Information"). At the same time, please understand that the services we provide to you are constantly updated and evolving. If you choose to use other services not covered in the above instructions, if we need to collect your additional information, we will explain to you the scope and purpose of information collected through page prompts, interaction process, agreement agreements, pop-up prompts, and obtain your consent.

If you only need to use the browsing service, you do not need to register as our member and provide the above information.

2. Other registration services

      Real-name authentication: When you register and log in, you need to enter the "Personal Center" to complete the real-name authentication in the identity authentication. You need to provide your real name, ID number or passport number to the platform during the process of using the real-name authentication.

     Advanced Certification: When your transaction volume in this platform exceeds a certain limit, the platform will require your advanced certification in order to maintain the security of your assets.In addition to real-name authentication information, you recognize the platform for your "face recognition" advanced recognition, face recognition will involve the collection of your related video streams or face images.

   Account information display: if you have the platform account, we may show your personal information in the service (real-name authentication only shows authentication whether the results), as well as you in the platform account related products and services, including through the platform account centralized display your personal data, transaction orders. We will respect the choices you make about the platform account setup.

(2) Security management services and service information push services

     When you use the services provided by the platform or access the platform, the platform, to ensure the safe and stable operation of your services, we need to automatically receive and record your Web browser information, your login account (IDFA, operating system, model, equipment model, equipment manufacturer, system version, Android ID, IMEI and MAC address, etc.), IP address and records on the pages you request to access, area, network environment, device fingerprint information, service log information, software information, location information, etc.

   Note that separate equipment information is information that cannot identify the identity of a specific natural person. If we combine this kind of non-personal information with other information to identify a specific natural person identity, or use it with personal information, during the combined use, this kind of non-personal information will be regarded as personal information, in addition to your authorization or laws and regulations, we will be anonymization, identification.

   In order to provide you with more convenient, more in line with your personalized needs of information display and push services, we may future according to your device information and your platform or client browsing information, extract your preference characteristics and based on characteristics label output indirect crowd portrait, for display, push information and possible commercial advertising. If you do not agree to receive such push information or withdraw your consent to collect personal information, you may contact us in accordance with the contact information provided in this policy.

   We strive to secure your browsing experience. If you do not want to accept the commercial advertisement that we send to you, you can unsubscribe or close by sending SMS prompts to reply to the unsubscribe or any other way that we provide.

     In addition, we will also use your above information in order to constantly improve and optimize the above features.

(3) Transaction record storage and inquiry service

    The data we collect on your exchanges on this platform includes but is not limited to transactions. If you need to query your order transaction record, you can query your personal transaction details in the platform "Order Management", including the counterparty's nickname, order time, order number, transaction information, the type and quantity of digital assets, etc.

(4) Customer service and dispute handling

   When you contact us or apply for after-sale and dispute handling, to secure your account and system, we need you to provide the necessary personal information to verify your membership.

   To facilitate the solutions and results of contacting you, and help you solve or record related problems as soon as possible, we may keep your correspondence records and related content (including account information, order information, other information you provide to prove relevant facts, or contact information you leave), and use your account information and order information if you consult, complain or advise on the specific order.

     Other information you may use to provide service and a reasonable need to improve service quality, including the relevant information you provide when you contact customer service, and the questionnaire response information sent to us when you participate in the questionnaire.

(5) Other

1. If the information you provide contains the personal information of other users, you need to ensure that you have obtained the legal authorization before providing this personal information to the platform. If the child's personal information is involved, you need to obtain the consent of the corresponding child guardian before the release. Under the aforementioned circumstances, the guardian has the right to contact us through Article 9 of this policy to correct or delete the content involving the child's personal information.
2. If we use the information for other purposes not specified in this policy or use information collected for a specific purpose for other purposes, or we actively obtain your personal information from a third party, you will obtain your consent.

     If we indirectly obtain your information from a third party, we will explicitly require the third party to collect personal information after obtaining your consent, and inform you of the shared information shall be required to ensure the legality and compliance of the third party, and will strengthen personal information (including sensitive information reporting, sensitive information encryption storage, access control, etc.). We will use the same protection means and measures no less than us to protect our personal information for indirectly obtained personal information.

3. Exceptions to authorized consent

    You fully understand and agree that we do not require your authorized consent to collect and use your personal information, and we may not respond to your requests for correction/modification, deletion, write out, withdraw consent, or request information if:

(1) Related to national security and national defense security;

(2) Related to public safety, public health or major public interests;

(3) Related to judicial or administrative law enforcement such as crime investigation, prosecution, trial and judgment execution;

(4) To protect the major legitimate rights and interests of you or other individuals, but it is difficult to get my consent;

(5) The personal information that you will disclose to the public by yourself;

(6) Collect personal information from the legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

(7) As necessary to sign and perform relevant agreements or other written documents with you;

(8) Those necessary to maintain the safe and stable operation of the products and/or services provided, such as the discovery and disposal of faults of the products and/or services;

(9) Required for legal news reporting;

(10) When academic research institutions carry out statistical or academic research institutes in the public interest and provide external academic research or described results, they shall deidentify the personal information contained in the results;

(11) Other circumstances as stipulated by laws and regulations.

     Be aware that your consent requires technical and other necessary measures to process personal information so that data recipients cannot re-identify specific individuals and cannot recover, or we may deidentify research, statistical analysis and prediction to improve the content and layout of the platform, provide product or service support for business decisions, and improve our products and services (including using anonymous data for machine learning or model algorithm training).

4. If we stop operating the products or services of the platform, we will stop the activity of continuing collecting your personal information in time, inform you of the notice of stopping the operation in one by one service or announcement, and delete or anonymize the personal information we hold related to the closed business.

2. How do we use Cookie

    If your browser or browser add-on Cookie allows, you can modify its acceptance or reject our Cookie. For more details, see the AboutCookies.org。But if you do so, in some cases it may affect your secure access to our platform, and you may need to change the user settings every time you visit our platform. You understand and agree that the:

1. When you visit our platform, we use Google Stats to record our results and check the effect of online advertising. A cookie is a small amount of data sent to your browser and stored on your computer's hard drive. A cookie can only be sent to your computer's hard drive when you use your computer on our platform.
2. Cookies are often used to record visitors' habits and preferences when browsing through various projects on our platform. The information collected by Cookies is anonymous collective statistics and does not contain personal data.
3. Cookies cannot be used to obtain the data on your hard disk, your email address, and your private data, which enables the platform or service provider system to recognize your browser and capture and remember the information. Most browsers are preset to accept the Cookies. You can choose to set your browser to not accept cookies, or notify you as soon as Cookies is installed. However, if set to ban Cookies, you may not be able to start or use some features of our platform.

3. How do we share, transfer, and publicly disclose your information

(1) Sharing

   We will not share your personal information with companies, organizations, and individuals other than the platform service providers, except where:

1. Sharing under legal circumstances: We may share your personal information in accordance according to the provisions of laws and regulations, litigation and dispute resolution needs, or according to the requirements of administrative and judicial organs.
2. Share with clear consent: After obtaining your clear consent, we will share your personal information with other parties.
3. Share under your active choice: We will share the necessary information related to the transaction with the counterparty of the digital assets according to your choice, so as to realize your transaction and after-sales service needs.
4. Share with Authorized Partners: Our related parties, trusted third parties who help us operate our platform, conduct business, or provide services to you, provided they agree to keep the information confidential; when we believe the information disclosed is appropriate, regulations, or from the law or the rights, property or security of us or others.

(2) Transfer

     We will not transfer your personal information to any company, organization, or individual, except if:

1. Transfer under clear consent: After obtaining your clear consent, we will transfer your personal information to other parties;
2. In case of merger, acquisition or bankruptcy liquidation on this platform, or other situations involving merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require new companies and organizations that hold your personal information to continue to be subject to this policy, otherwise we will require the company, organizations and individuals to seek your authorization again.

(3) Public disclosure

      We will publicly disclose your personal information only if:

1. With your express consent or based on your active choice, we may publicly disclose your personal information;
2. If we determine that you violate laws and regulations or have serious violations of the relevant agreements and rules of the platform, or to protect the personal and property safety of the platform users or the public from infringement, we may disclose our personal information about you in accordance with laws and regulations or with your consent, including relevant violations and the measures that the platform has taken to you.

(4) Exceptions to prior authorization for sharing, transfer or public disclosure of personal information

No prior authorized consent is required to share, transfer, or publicly make disclosure of your personal information under:

1. Related to national security and national defense security;
2. Related to public safety, public health, and major public interests;
3. Related to judicial or administrative law enforcement such as crime investigation, prosecution, trial and judgment execution;
4. To protect the major legitimate rights and interests of your life or other individuals, but it is difficult to obtain personal consent;
5. The personal information that you will disclose to the public by yourself;
6. Collect personal information from the legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

      Please be aware that, under the applicable law, if we take technical and other necessary measures to process personal information so that the data recipient cannot reidentify specific individuals and cannot recover, the sharing, transfer and public disclosure of such processed data requires further notice to you and your consent.

4. How do we protect your information

1. We implement proper physical, electronic, management, and technical measures to protect and secure your personal data. We do our best to ensure that any personal information collected through our platform is protected from any third party unrelated to us. The safety measures we take include, but are not limited to:

         (1) Physical measures: The records of your personal data will be stored in a locked place.

     (2) Electronic measures: Computer data with your personal data will be stored on computer systems and storage media subject to strict login restrictions.

        (3) Management measures: we have set up relevant departments to protect user information, and established a relevant internal control system to adopt strict authorization principles for the staff who may have access to your information. Only our authorized staff can have access to your personal data, who need to abide by our internal code of personal data confidentiality. In addition, we continue to strengthen the publicity of relevant laws and regulations and privacy safety standards and safety awareness, and regularly organize internal relevant personnel to conduct emergency response training and emergency drills, so that they can master the job responsibilities and emergency response strategies and procedures

       (4) Technical measures: An encryption technology such as Secure Socket Layer Encryption may be used to deliver your personal data.

      (5) Security Measures: In order to ensure your information security, we are committed to using various current general security technologies and supporting management systems to minimize the risk of disclosure, damage, misuse, unauthorized access, unauthorized disclosure and change of your information. For example, through the network security layer software (SSL) encryption transmission, information encryption storage, strictly limit access to the database. When transmitting and storing personal sensitive information (including personal biometric information), we will use security measures such as encryption, permission control, demidentification and desensitization.

    (6) Other measures: Regularly review our personal data collection, storage and processing processes; and restrict the access of our employees and suppliers to your data on necessary principles, and our employees and suppliers adhere to strict contractual confidentiality obligations.

2. If you know of any security vulnerabilities in our platform, please contact us immediately, so that we can take appropriate action as soon as possible.
3. Despite the implementation of the above technical and security measures, we cannot guarantee the absolute safety of the information transmission on the Internet, so we cannot absolutely guarantee that the personal information that you provide to us through our platform is safe at all times. We will update and disclose the security risks, personal information security impact assessment report and other related contents from time to time, which you can obtain through the announcement on this platform.

5. How do you manage your information

You can access and manage your information by:

(I) Query, correct, and delete your information

   You are entitled to obtain a copy of your personal information upon request and to determine whether the information we have about you is accurate and up-to-date. If any of your personal data is inaccurate, you may request to update your information. You may also request that your personal data be deleted, but we may reject your deletion requests in some cases, such as for legal requirements or other legal purposes. For data access, correction, or delete requests, you can contact us through the contact information in Article 8.

    In response to data access, to correct or delete requests, we will verify the identity of the requesting party to ensure that he/she is legally entitled to make such requests. While our goal is to respond to these requests for free, we reserve the right to charge you a reasonable fee when your request is repeated or onerous.

(2) Change the scope of your authorized consent

     Each business function requires some basic personal information to complete (see Part I of this Privacy Policy).In addition, you may contact us to give or recover your authorized consent through the contact information provided in Article 8.

   When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect prior personal information processing based on your authorization.

(3) Cancel your account

    You can contact us through the contact information in Article 8; after you voluntarily cancel the account, we will stop providing your products or services, delete your personal information, or anonymize it as required by applicable law.

(4) Responding to your above request

     To be secure, you may need to provide a written request, or otherwise prove your identity.We may ask you to verify your identity before you process your request.

We will respond within 15 days. If you are not satisfied, you can also file a complaint through the contact information we provide.

     We do not charge in principle for your reasonable request but will charge for multiple repeated and beyond reasonable requests at our discretion. We may reject requests for information that is not directly related to your identity, unprovoked duplication, or requiring excessive technical means (e. g., developing new systems or fundamentally changing existing practices), or poses risks to the legitimate rights or interests of others.

We will not be able to respond to your request if:

1. Related to national security and national defence security;
2. Related to public safety, public health, and major public interests;
3. Related to the criminal investigation, prosecution, trial and execution of the judgment;
4. There is sufficient evidence of subjective malice or abuse of personal information subject rights;
5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
6. Related to trade secrets.

6. How do we deal with the information of minors

     The platform is not available to children, and if we find or suspect that the user is under 14, we will ask the user to close his account and will not allow the user to continue to use the platform products or services. We will delete the relevant information as soon as possible. If you know that any person under 14 is using our services, please inform us so that we can take action to prevent them from accessing our products or services.

     For minors who are over 14 but not over 18, we expect our parents or guardians to guide the minors in the use of our services. We will protect the confidentiality and security of minors' information in accordance with relevant laws and regulations.

    If you are underage, it is recommended that your parents or guardian read this policy and use our services or provide us with your information with the consent of your parents or guardian. Where your information is collected with the consent of the parent or guardian, we will only use or publicly disclose this information if necessary as permitted by law, the express consent of the parent or guardian, or the protection of your rights. If your guardian does not agree that you will use our services in accordance with this policy or provide us with information, please terminate the use of our services immediately and notify us promptly so that we can take appropriate measures.

   If you are the parent or guardian of a minor, when you have questions about the information processing of the minor in your custody, please contact us through the contact information published in this policy.

VII. How to update this Privacy policy

Our privacy policy may change.

     We will not limit your rights under this Privacy Policy without your express consent. We will post any changes to our privacy policy on our official channels. If you do not agree to the revision, you should stop having immediate access to the platform. When an updated version of the Privacy Policy is released, you continue to access the platform to display and indicate that you agree to the update and agree to comply with the Privacy Policy.

    We will also provide more significant notifications for major changes (including that we will even provide pop-up tips to you through this platform).

Major changes referred to in this policy include, but are not limited to:

1. Our service model has changed significantly. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information;
2. We have undergone major changes in our control rights. Such as the change of information controller caused by merger and reorganization;
3. The main objects of personal information sharing, transfer or public disclosure change;
4. Your rights to participate in personal information processing and their exercise methods have changed significantly;
5. We are responsible for handling the changes in the responsible departments, contact information and complaint channels for personal information security;
6. The personal information security impact assessment report indicates a high risk.

VIII. How to contact us

1. If you have any requests or opinions, you can email us at, this is the only valid and official email that we communicate with you, so we are not liable for your lack of valid contact information and for any act or omission.
2. We only publish announcements and information through the effective contact information on the platform or post announcements on the platform, so we are not liable for any loss due to your trust in the information not obtained through the above means.
3. If you have any questions about our privacy policy, please feel free to contact us.