[Privacy Policy Updates]
Latest Update Time: 2022-12-05 (UTC+9)

This Privacy Policy explains how and its Affiliates (“ ”) collect, use, share, and protect user information obtained through the website ( ), or our mobile applications, or any other related services provided by . The terms “we,” “us,” and “our” refer to and its affiliates. When we ask for certain personal information from users it is because we are required by law to collect this information or it is relevant for specified purposes. Any non-required information you provide to us is done so voluntarily. You decided whether to provide us with these non-required information; you may not be able to access or utilize all of our Services if you choose not to.

By using this site and related Application Programming Interfaces (API) or mobile applications, you agree to the policies and practices of our Privacy Policy, so please read this document carefully.

This Privacy Policy explains what data we collect, how we use and store such data, and how we share such data. If you do not wish to have your Personal Data (as defined below) used in the manner described in this Privacy Policy, you may not use the site or any of the services, software, APIs, technologies, products and/or features offered by the site (the "Services").

 

1. DEFINITIONS

Virtual Financial Asset

As used herein, "Virtual Financial Asset" also called "convertible virtual currency", "cryptocurrency" or "digital goods", such as bitcoin or ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.

Personal Data

As used herein, “Personal Data” means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.

 

2. WHAT PERSONAL DATA WE COLLECT

collects, processes, and stores Personal Data collected from you via your use of the Service or where you have given your consent. This Personal Data may include contact details, copies of identification documentation provided by you or derived from publicly accessible databases, your government identification number as well as information relating to your device or internet service (such as an IP address and a MAC number).

Operating within certain regulated jurisdictions around the world, collects, stores and processes your personal data in accordance with the various regulations to which we are subject, and we aim for the highest standards of compliance and adherence to all such data privacy requirements. The following provisions in this Privacy Policy are an amalgamation of these regulations to which our group as a whole is subject, and serves as a single policy point to govern our data collection, storage and processing activities. As these regulations are amended from time to time, we are also required to ensure that our data practices are up to date by amending the provisions herein.

We collect the information you provide during the onboarding process, which may be a completed, incomplete, or abandoned process. We also collect personal data when you communicate with us through customer support, subscribe to marketing messages or contact us by phone, email or other communication channels. We collect, use, store, and transfer your Personal Data, which may include the following:

Individual customers:

• Email address
• Mobile phone number
• Full legal name (including former name, and names in local language)
• Nationality
• Passport number, or any government issued ID number
• Date of birth (“DOB”)
• Proof of identity (e.g., passport, driver’s license, or government-issued ID)
• Residential address
• Proof of legal existence
• Additional Personal Data or documentation at the discretion of our Compliance Team
• IP address
• Device ID

Corporate customers:

• Corporate legal name (including the legal name in local language)
• Incorporation/registration Information
• Full legal name of all beneficial owners, directors, and legal representatives
• Address (principal place of business and/or other physical locations)
• Proof of legal existence
• Description of the business
• Percentage of ownership for Individual/corporate owners
• Contact information of owners, principals, and executive management (as applicable)
• Proof of identity (e.g., passport, driver’s license, or government-issued ID) for significant individual beneficial owner of the institutional customer entity
• Personal Data for each entity’s significant beneficial owner of the institutional customer entity (see the “Individual Customer” section above for details on what Personal Data we collect for individuals)
• Source of wealth
• Amount of fiat money injected
• Amount of bitcoin or other digital assets projected to be injected

 

3. COLLECTION AND TRANSFER OF DATA OUTSIDE OF YOUR JURISDICTION

As we may collect Personal Data from customers located from different jurisdictions, and most of these jurisdictions will require consent for the transfer of such Personal Data from your jurisdiction to outside of the area, your explicit consent is required and hereby assumed by way of your use and/or continued use of the Services. If you decline to consent to such transfer, you will no longer be able to use ’s platform and/or our Services. You will have the ability to withdraw your digital assets; however, all other functionalities will be disabled.

 

4. HOW WE USE YOUR PERSONAL DATA

uses Personal Data to communicate with you and to administer, deliver, improve, and personalize the Service. might also generate generic data out of any Personal Data we collect and use it for our own purposes. We may also use such data to communicate with you in relation to other products or services offered by and/or its partners. We do not share your Personal Data with third parties (other than partners in connection with their services to ) except where you have given your consent and further detailed below.

We may share your Personal Data with third parties:

(a) if we think that sharing it is necessary to enforce the Terms of Service;
(b) to comply with government agencies, including regulators, law enforcement and/or justice departments;
(c) to third parties who provide services to (such as administration or technical services);
(d) in connection with the sale or transfer of our business or any part thereof.

Additionally, we have implemented international standards to prevent money laundering, terrorist financing and circumventing trade and economic sanctions and will implement final Virtual Financial Asset rules and regulations when effective, which will likely require us to undertake due diligence on our customers. This may include the use of third-party data and service providers which we will cross-reference with your personal information.
To realize the [Share] function, we use MobTech's [ShareSDK] product. The privacy policy terms of this product can be found at: http://www.mob.com/about/policy

 

5. HOW WE STORE YOUR PERSONAL DATA

We aim to protect users and from unauthorized access, alteration, disclosure, or destruction of the personal data that we collect and store. We take various measures to ensure information security. We store your data securely in fault-tolerant secure storage which is encrypted with industry standards, and take multiple security measures to ensure that user data will not be lost, abused, or altered, including but not limited to:

5.1 Physical Measures. Materials containing your personal information will be stored in a locked place. Your personal information will only be stored in the physical form under special circumstances.
5.2 Electronic Measures. Computer data containing your personal information will be stored in the computer systems and storage media that are subject to strict login restrictions.
5.3 Management Measures. Only authorized employees are permitted to come into contact with your personal information and such employees must comply with our internal confidentiality rules for personal data. We have also imposed strict physical access controls to buildings and files. In addition, we continuously train staff on relevant laws and regulations and privacy security guidelines, and security awareness, and regularly organize emergency response training and emergency drills for relevant internal personnel to master their job responsibilities and emergency response strategies and protocols.
5.4 Other Measures. Our web server is protected by various "firewalls".
Please note that it is impossible to guarantee 100% security of information. As such, we request that you understand the responsibility to independently take safety precautions to protect your own personal information.
Here are some safety steps that you need to know about.
5.5 Use a strong user identification, password, and PIN to access accounts that others do not know or cannot easily guess ("User Credentials"). The user credentials must meet the requirements we specified when you create them. You should keep your user credentials safe and private and do not share your user credentials with anyone.
5.6 Anti-virus, anti-spyware and firewall software are recommended to be installed on personal computers and mobile devices.
5.7 The operating system, anti-virus and firewall products should be updated regularly and updated to the latest security patches or versions.
5.8 File and printer sharing in the computer should be deleted, especially when they are connected to the Internet.
5.9 Back up your critical data regularly.
5.10 Consider using encryption technology to protect highly sensitive or confidential information.
5.11 After completing each online session using the platform, log out completely and clear the browser cache.
5.12 Do not install software or run programs from unknown sources.
5.13 Delete spam emails or chain letters.
5.14 Do not open email attachments from strangers.
5.15 Do not disclose personal, financial, or credit card information to little-known or suspicious websites.
5.16 Do not use untrusted computers or equipment.
5.17 Do not use public or Internet cafe computers to access online services or conduct financial transactions.

If you suspect that your personal information, especially account and/or password information, has been compromised, please lock your account immediately and contact our customer support team. Unless otherwise stipulated by law or the Terms of Use, you agree that we have the right but not the obligation to retain all the collected personal information for the duration of your Account for 5 more years after the account is closed. You agree that we shall not be liable for any information leakage and other losses not caused by our intention or gross negligence, including but not limited to hacker attack, power interruption, or unavoidable technical failure, to the maximum extent permitted by law.

 

6. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL DATA

You have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold 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 to delete your Personal Data, with exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, please contact support@ .com with the subject “DATA INQUIRY”.

In response to data access, correction, or deletion request, please note that, for your own protection as well as ours, we shall only be able to do so with the proper and verified authorization of the data owner himself or herself. Therefore, before taking any action, we will take all steps as considered necessary in our absolute discretion to carry out said verification of the requester’s identity (including but not limited to a telephone call-back or email response from the data owner’s email address on file, or such procedures as we may in our discretion require) so as to ensure the legitimacy of the request. Due to possible complexities and cross-border time differences, we are unable to commit to a timeline within which such requests can be fulfilled, and hereby disclaims any liability for any loss or damage howsoever suffered as a result of a data access, correction or deletion request not being attended to by us on a timely basis. Also, while we aim to respond to data requests without charge, we hereby reserve the right to charge a reasonable fee should the request prove to be onerous, repetitive, or require additional resources to be complied with.

 

7. MARKETING

We may communicate company news, promotions, and information relating to our products and services provided by . We may share Personal Data with third parties to help us with our marketing and promotional projects, or send marketing communications. By using , you accept this Privacy Policy and you agree to receive such marketing communications.

Customers can opt out from these marketing communications at any moment. If you do not want to receive these communications, please send an email to support@ .com.

For product related communications, such as policy/terms updates and operational notifications, you will not be able to opt out of receiving such information.

 

8. COOKIE USAGE

While you access , we may use the industry practice of placing a small amount of data that will be saved by your browser (Cookies). This information can be placed on your computer or other devices used to visit . This information helps us recognize you as a customer and collect information about your use of to better customize our services and better your experience. We may also use the information collected to ensure compliance with our compliance program (BSA and AML program), and to ensure your account security has not been compromised by detecting irregular or suspicious account activities.

Most browsers are setup to accept cookies automatically. Some Cookies expire when you finalize the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of services or your user experience.

 

9. CONTACTING ABOUT PRIVACY QUESTIONS OR CONCERNS

If you have any questions about this Privacy Policy or the use of your Personal Data, please contact us by sending an email to the following address support@ .com with the subject “PRIVACY REQUEST”.

For users in European Economic Area, you have the right to request that unresolved issues regarding the collection, use or disclosure of your personal information comply with the requirements of the applicable regulatory authority in your jurisdiction.

 

10. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, when appropriate, we will notify you by notification and official website. Please revisit regularly for any changes and updates. As mentioned in this Privacy Policy above, your use and/or continued use of the Services constitutes your implicit agreement to the terms herein as well as the amendments, changes or updates that will be made on a continuing basis. It is your responsibility to check this Privacy Policy for such amendments and shall not be legally or financially liable for the consequences of your failure to do so.

 

11. LANGUAGE OF USE

This Privacy Policy may be published in different languages. In case of any discrepancy, please refer to the English version.