【Introduction and Tips】

This platform is a platform dedicated to digital asset transactions and related services (hereinafter referred to as "the Service" or "Service"). For the convenience of expression, this platform is collectively referred to as "we" or other first-person names in this agreement. As long as the natural person or other subject who logs in to the platform is a user of this platform, "you" or other second-person names are used below. We and you are collectively referred to as "both parties", and we or you are individually referred to as "one party".

We fully understand and respect the importance of your personal information to you. We will take corresponding security protection measures in accordance with the requirements of laws and regulations to protect the security of your personal information. In view of this, this "Privacy Policy" (hereinafter referred to as "this Policy/this Privacy Policy") is formulated and reminds you:

This policy applies to all products and services we provide. If the product or service we provide to you has a separate privacy policy, the product or service shall be subject to its separate privacy policy; if our product or service does not have a separate privacy policy, this policy shall apply.

It should be noted that this policy does not apply to services provided to you by other third parties. The services provided to you by third parties shall be subject to the privacy policy they explain to you separately.

Before using our products or services, please be sure to read and thoroughly understand this policy, especially the terms marked in bold/bold underline. You should read them carefully and start using them only after you confirm that you fully understand and agree. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the various contact methods we provide officially. If you disagree with any of the terms in this policy, you should immediately stop accessing this platform.

Part I Definitions

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

Personal sensitive information: refers to personal information including identity document number, personal biometric information, bank account number, property information, whereabouts, transaction information, and information of children under 14 years old (inclusive) (we will mark specific personal sensitive information in bold in this privacy policy).

Personal information deletion: refers to the act of removing personal information in the system involved in realizing daily business functions so that it remains inaccessible.

Children: refers to minors under the age of fourteen.

Part II Privacy Policy

This privacy policy section will help you understand the following:

1. How we collect and use your information

2. How we use Cookies and similar technologies

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

4. How we protect your information

5. How you manage your information

6. How we handle information about minors

7. How to update this privacy policy

8. How to contact us

1. How we collect and use your information

When you use our products and/or services, we need/may need to collect and use your personal information, including the following two types:

1. In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;

2. In order to provide you with additional functions of our products and/or services, you can choose to authorize us to collect and use information. If you refuse to provide it, you will not be able to use the relevant additional functions normally or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services.

You understand and agree that:

1. We are committed to creating a variety of products and services to meet your needs. Because we provide you with a wide variety of products and services, and different users choose to use different specific product/service scopes, the basic/additional functions and the types and scope of personal information collected and used will be different accordingly. Please refer to the specific product/service functions;

2. In order to bring you a better product and service experience, we are continuously working to improve our technology. As a result, we may launch new or optimized functions from time to time, which may require the collection and use of new personal information or change the purpose or method of using personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this policy, pop-up windows, page prompts, etc., and provide you with a way to choose consent on your own, and collect and use it after obtaining your explicit consent. In this process, if you have any questions, comments or suggestions, you can contact us through the various contact methods provided by this platform, and we will answer you as soon as possible.

We will collect and use your personal information to achieve the following functions of this policy:

(I) Help you register and provide you with the services provided by this platform;

1. Registration service

We provide you with basic membership services through this platform account. To register as 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 this platform, including but not limited to your name, your residential address, other certificates issued by your country or government that prove your identity information, as well as the numbers involved and all other information that can help us verify your identity (hereinafter collectively referred to as "identity information"). This identity information varies depending on whether you are an individual user or an institutional user. According to the laws and regulations of different jurisdictions, the information we collect for users from different countries or regions may be different. The following information and data is used as an indicative example:

Individual users: nationality, full legal name (including former 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, proof of identity (such as passport, driver's license or government-issued ID).

Institutional users: company legal name (including legal name in local language), registration information, business telephone number, personal information of authorized representatives and authorized users, principal place of business, personal information of all beneficial owners), identification documents of shareholders/beneficial owners (passport or government-issued ID card), company structure, company establishment documents, board resolutions, declaration of source of funds, risk and compliance control instructions and other information or documents required by the platform.

(2) Service information. This information helps us contact you and smoothly provide you with different modes of digital asset trading services, including but not limited to your personal identity information, contact information, transaction information, and your debit card information and/or other account information (hereinafter collectively referred to as "service information"). At the same time, please understand that the services we provide to you are constantly updated and developed. If you choose to use other services not covered in the above description, based on the service, we need to collect additional information from you, we will explain the scope and purpose of information collection to you through page prompts, interactive processes, agreement agreements, pop-up prompts, etc., 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: After 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 the platform with your real name, ID number or passport number during the real-name authentication process.

Advanced authentication: When your transaction amount on this platform exceeds a certain limit, the platform will require you to undergo advanced authentication in order to maintain the security of your assets. In addition to the real-name authentication information, you acknowledge that the platform will perform advanced "face recognition" authentication on you during the authentication process. Face recognition involves the platform's collection of relevant facial images of you.

Account information display: If you already have an account on this platform, we may display your above personal information in the service (real-name authentication only displays the result of whether the authentication is passed), as well as the operations you perform in the products and services associated with the platform account, including the centralized display of your personal information and transaction orders through this platform account. We will respect your choices for platform account settings.

(II) Security management service and service information push service

When you use the services provided by this platform or visit this platform, in order to ensure the security of your transactions and the safe and stable operation of the services, this platform needs to automatically receive and record your web browser information, the device information you use to log in to your account (IDFA, operating system, device model, device manufacturer, system version, Android ID, IMEI and MAC address, etc.), the IP address and records on the web page you requested to access, the region, network environment, device fingerprint information, service log information, software information, location information, etc.

Please note that device information alone is information that cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be regarded as personal information during the combined use period. Unless you authorize us or laws and regulations provide otherwise, we will anonymize and de-identify such information.

In order to provide you with more convenient information display and push services that better meet your personalized needs, we may extract your preference characteristics based on your device information and your browsing and use information of this platform or client in the future, and produce indirect population portraits based on characteristic tags for display, push information and possible commercial advertisements. If you do not agree to receive such push information or withdraw your consent to collect personal information, you can contact us according to the contact information provided in this policy.

We strive to protect your browsing experience. If you do not want to accept the commercial advertisements we send you, you can unsubscribe or close them through SMS prompts or other methods we provide.

In addition, we will also use your above information to continuously improve and optimize the above functions.

(III) Transaction record storage and query service

We collect relevant data on your transactions on this platform, including but not limited to transaction records. If you need to query your order transaction records, you can query your personal transaction details in the "Order Management" of the platform, including: counterparty nickname, order time, order number, transaction information, digital asset type and quantity, etc.

(IV) Customer Service and Dispute Resolution

When you contact us or apply for after-sales service or dispute resolution during sales, in order to protect the security of your account and system, we need you to provide necessary personal information to verify your membership.

In order to facilitate contact with you, help you solve problems as soon as possible, or record the solutions and results of related problems, we may save your communication records and related content (including account information, order information, other information you provide to prove relevant facts, or contact information you leave). If you consult, complain or provide suggestions for specific orders, we will use your account information and order information.

In order to provide services and improve service quality, we may also use your other information, including the relevant information you provide when you contact customer service, and the questionnaire response information you send to us when you participate in the questionnaire survey.

(V) Others

1. If the information you provide contains the personal information of other users, you must ensure that you have obtained legal authorization before providing this personal information to this platform. If it involves children's personal information, you need to obtain the consent of the corresponding child's guardian before publishing. In the above circumstances, the guardian has the right to contact us through the means of Article 9 of this Policy to request correction or deletion of content involving children's personal information.

2. If we use the information for other purposes not specified in this Policy, or use the information collected for specific purposes for other purposes, or we actively obtain your personal information from a third party, we will obtain your consent in advance.

If we obtain your information indirectly from a third party, we will clearly require the third party to collect personal information in writing before collection after obtaining your consent in accordance with the law, and inform you of the shared information content, and sensitive information must be clearly confirmed by you before it is provided to us for use, and require the third party to make a commitment to the legality and compliance of the source of personal information. If the third party violates the rules, we will clearly require the other party to bear the corresponding legal liability; at the same time, we will strengthen the security of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control, etc.). We will use protection means and measures no less than those for our own user personal information to protect indirectly obtained personal information.

3. Exceptions to obtaining authorization and consent

You fully understand and agree that we do not need your authorization and consent to collect and use your personal information in the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, or information request:

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

(2) Related to public security, public health, and major public interests;

(3) Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;

(4) For the purpose of safeguarding your or other individuals’ major legitimate rights and interests such as life and property, but it is difficult to obtain the consent of the person concerned;

(5) Personal information that you disclose to the public on your own;

(6) Personal information collected from legally disclosed information, such as legal news reports, government information disclosure, and other channels.

(7) Necessary in accordance with the signing and performance of relevant agreements or other written documents with you;

(8) Necessary for maintaining the safe and stable operation of the products and/or services provided, such as discovering and handling product and/or service failures;

(9) Necessary for legitimate news reporting;

(10) Necessary for academic research institutions to conduct statistical or academic research based on the public interest, and when providing the results of academic research or descriptions to the outside world, the personal information contained in the results shall be de-identified;

(11) Other circumstances stipulated by laws and regulations.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore it, or we may conduct de-identified research, statistical analysis and prediction on the collected information to improve the content and layout of this 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), then the use of such processed data does not require separate notification to you and your consent.

4. If we stop operating the products or services of this platform, we will promptly stop collecting your personal information, notify you of the cessation of operations by delivery or announcement, and delete or anonymize the personal information we hold related to the closed business.

2. How we use cookies
If your browser or browser add-on service allows, you can modify the degree of acceptance of cookies or reject our cookies. For more information, please see AboutCookies.org. However, if

If you do this, in some cases it may affect your secure access to our platform, and you may need to change your user settings every time you visit our platform. You understand and agree that:

1. When you visit our platform, we use Google Stats to record our performance and verify the effectiveness of online advertising through cookies. Cookies are small amounts of data sent to your browser and stored on your computer's hard drive. Cookies can only be sent to your computer's hard drive when you use your computer to access our platform.

2. Cookies are often used to record the habits and preferences of visitors when browsing various items on our platform. The information collected by cookies is anonymous collective statistics and does not contain personal information.

3. Cookies cannot be used to obtain data on your hard drive, your email address, and your private data. It allows the platform or service provider system to recognize your browser and capture and remember information. Most browsers are preset to accept cookies. You can choose to set your browser not to accept cookies, or notify you if cookies are installed. However, if you set it to prohibit cookies, you may not be able to activate or use certain features of our platform.

III. How we share, transfer, and publicly disclose your information

(I) Sharing

We will not share your personal information with companies, organizations, and individuals other than the service providers of this platform, except in the following circumstances:

1. Sharing under legal circumstances: We may share your personal information externally in accordance with the provisions of laws and regulations, litigation, dispute resolution, or in accordance with the requirements of administrative and judicial authorities in accordance with the law.

2. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

3. Sharing with your active choice: We will share the necessary transaction-related information in your order information with the counterparty of the digital asset transaction according to your choice to meet your transaction and after-sales service needs.

4. Sharing with authorized partners: Our affiliates, trusted third parties who help us operate our platform, conduct business, or provide services to you, as long as these parties agree to keep this information confidential; when we believe that the disclosed information is appropriate, in compliance with laws, regulations, rules and regulations or from the orders of the court or other competent authorities, to implement our platform strategy, required for the normal operation of the platform, required for the affiliate to provide services, or to protect the rights, property or safety of us or others.

(II) Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

1. Transfer with explicit consent: We will transfer your personal information to other parties with your explicit consent;

2. In the event of a merger, acquisition or bankruptcy liquidation on this platform, or other circumstances involving merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this policy, otherwise we will require the company, organization or individual to re-ask for your authorization and consent.

(III) Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

1. We may publicly disclose your personal information with your explicit consent or based on your active choice;

2. If we determine that you have violated laws and regulations or seriously violated the relevant agreements and rules of this platform, or to protect the personal and property safety of users of this platform or the public from infringement, we may disclose your personal information in accordance with laws and regulations or with your consent, including relevant violations and measures taken by this platform against you.

(IV) Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information

In the following circumstances, sharing, transferring, or publicly disclosing your personal information does not require your prior authorization and consent:

1. Related to national security and national defense security;

2. Related to public security, public health, or major public interests;

3. Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;

4. For the purpose of safeguarding your or other individuals’ major legitimate rights and interests such as life and property, but it is difficult to obtain the consent of the individual;

5. Personal information that you disclose to the public on your own;

6. Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure, and other channels.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore it, the sharing, transfer, and public disclosure of such processed data does not require additional notification to you and your consent.

IV. How we protect your information

1. We implement appropriate physical, electronic, management, and technical measures to protect and safeguard the security of your personal information. We strive to ensure that any personal data collected through our platform is free from any interference from any third party unrelated to us. The security measures we take include but are not limited to:

(1) Physical measures: Records containing your personal data will be stored in a locked place.

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

(3) Management measures: We have set up relevant departments to protect user information and have established relevant internal control systems. We adopt a strict authorization principle for staff who may have access to your information. Only staff authorized by us can access your personal data. These staff need to abide by our internal rules on confidentiality of personal data. In addition, we continue to train staff on relevant laws and regulations, privacy security guidelines and security awareness, and regularly organize internal relevant personnel to conduct emergency response training and emergency drills so that they can master job responsibilities and emergency response strategies and procedures.

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

(5) Security measures: To protect the security of your information, we are committed to using various current common security technologies and supporting management systems to minimize the risk of your information being leaked, damaged, misused, unauthorized access, unauthorized disclosure and altered. For example: encrypted transmission through network security layer software (SSL), encrypted information storage, and strict restrictions on access to data centers. When transmitting and storing personal sensitive information (including personal biometric information), we will adopt security measures such as encryption, permission control, de-identification, and desensitization.

(6) Other measures: Regularly review our personal data collection, storage and processing processes; and limit our employees and suppliers’ access to your data according to the principle of necessity, and our employees and suppliers are required to comply with strict contractual confidentiality obligations. .

2. If you are aware of any security vulnerabilities on our platform, please contact us immediately so that we can take appropriate action as soon as possible.

3. Despite the implementation of the above-mentioned technical and security measures, we cannot guarantee the absolute security of data transmission on the Internet, so we cannot absolutely guarantee that the personal data you provide to us through our platform is safe at all times. We will update and disclose security risks, personal information security impact assessment reports and other related content from time to time, and you can obtain them through the announcement of this platform.

V. How you manage your information

You can access and manage your information in the following ways:

(I) Query, correct and delete your information

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

In response to data access, correction or deletion requests, we will verify the identity of the requesting party to ensure that he/she is legally entitled to make such a request. Although we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee if your request is repetitive or onerous.

(II) Change the scope of your authorization and consent

Each business function requires some basic personal information to be completed (see "Part I" of this Privacy Policy). In addition, you can contact us through the contact information in Article 8 to give or withdraw your authorization consent.

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

(III) Cancel your account

You can contact us through the contact information in Article 8 to apply for cancellation of your account; after you actively cancel your account, we will stop providing you with products or services, delete your personal information in accordance with the requirements of applicable laws, or anonymize it.

(IV) Respond to your above request

For security reasons, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing 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.

In principle, we do not charge fees for your reasonable requests, but we will charge a certain fee for repeated requests that exceed reasonable limits. We may reject requests that are not directly related to your identity, are repeated without reason, or require too many technical means (for example, the development of new systems or fundamental changes to current practices), pose risks to the legitimate rights and interests of others, or are impractical.

In the following circumstances, we will not be able to respond to your request in accordance with laws and regulations:

1. Related to national security and national defense security;

2. Related to public safety, public health, and major public interests;

3. Related to criminal investigation, prosecution, trial, and execution of judgments;

4. There is sufficient evidence that the subject of personal information has subjective malice or abuses rights;

5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

6. Involving commercial secrets.

VI. How we handle information about minors

This platform is open to children. If we find or suspect that a user is under the age of 14, we will ask the user to close his or her 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 of anyone under the age of 14 using our services, please notify us so that we can take action to prevent them from obtaining our products or services.

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

If you are a minor, it is recommended that your parents or guardians read this policy and use our services or provide us with your information with the consent of your parents or guardians. For the collection of your information with the consent of your parents or guardians, we will only use or disclose this information when permitted by law, with the explicit consent of your parents or guardians, or when necessary to protect your rights and interests. If your guardian does not agree with your use of our services or provision of information to us in accordance with this policy, please immediately terminate the use of our services and notify us in a timely manner 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 minors you are protecting, please contact us through the contact information published in this policy.

VII. How to update this privacy policy

Our privacy policy may change.

Without your explicit consent, we will not restrict your rights under this privacy policy. We will publish any changes to the privacy policy on official channels. If you do not agree to the revised content, you should stop accessing this platform immediately. When the updated version of the Privacy Policy is released, your continued access to this platform will show and indicate that you agree to the updated content and agree to abide by the updated Privacy Policy.

For major changes, we will also provide more prominent notifications (including notifications through public announcements on this platform and even pop-up prompts to you).

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

1. Major changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way personal information is used, etc.;

2. Major changes in our control rights, etc. Such as changes in information controllers caused by mergers and acquisitions;

3. Changes in the main objects of personal information sharing, transfer or public disclosure;

4. Major changes in your rights to participate in personal information processing and the way they are exercised;

5. Changes in our responsible departments, contact methods and complaint channels for handling personal information security;

6. Personal information security impact assessment reports indicate high risks.

VIII. How to contact us

1. If you have any requests or comments, you can contact us by email, which is the only valid and official email for us to communicate with you, so we are not responsible for any actions or omissions you make if you do not use valid contact information.

+2. We only publish announcements and information or post announcements on this platform through valid contact information, so we are not responsible for any losses caused by your trust in information not obtained through the above methods.

3. If you have any questions about our privacy policy, please feel free to contact us.