Terms of Privacy
Preamble and Reminder
LedgerFi (hereinafter referred to asโ€œthe Companyโ€), is a company incorporated in Dubai that promotes LedgerPe card. This card is powered by Alchemy Pay, licensed by Paytend Bank and Mastercard, and backed by Cobo's wallet technology. (hereinafter referred to as โ€œthis Platformโ€ or โ€œthe Platformโ€), which is a Platform that is exclusively used by users to trade digital assets and provides them with relevant Services (hereinafter referred to as โ€œthe Servicesโ€). For the convenience of wording in this Agreement, the Company and the Website are collectively referred to as โ€œWeโ€ or other appropriate forms of the first-person pronouns. Any natural person or entity that logs into the Platform shall be a user thereof and are hereinafter referred to as โ€œYouโ€ or any other applicable forms of the second-person pronouns. Hereinafter You and us are collectively referred to as โ€œboth partiesโ€, and individually as โ€œa partyโ€.
We fully understand and respect the importance of Your personal information to You, and We will adopt corresponding appropriate safety protection measures to protect Your personal information in accordance with the requirements of the applicable laws and regulations. In view of this, this Privacy Policy (hereinafter referred to as โ€œthis Policy/this Privacy Policyโ€) is formulated and the following reminder is provided to You:
This Policy applies to all products and services We provide. If another privacy policy is specifically applicable to any product or service We provide to You, such privacy policy shall prevail; otherwise, this Privacy Policy shall prevail.
In particular, this Policy does not apply to services provided to You by any third party, and such services shall be subject to a privacy policy that is otherwise specified to You.
Before using our products or services, please read carefully and thoroughly understand this Policy, and pay special attention to the clauses that are in bold type or underlined and in bold type, make sure that You fully understand and agree to them before You start using our products or services. If You have any question, comment or suggestion in connection with any content of this Policy, You can contact us through any of the contact methods officially provided by us. If You do not agree with any term or condition in this Policy, You should promptly stop accessing this Platform.
Part I Definition
Personal information: various kinds of information recorded electronically or otherwise, which, alone or in combination with any other information, can identify the identity of a specific natural person or reflect the activities of a specific natural person.
Personal sensitive information: personal information, including Identity Card number, personal biometric information, bank account numbers, property information, tracks of whereabouts, transaction information, and information of children who are not older than fourteen(14) years old, inter alia. (We will prominently identify specific personal sensitive information in bold type in this Privacy Policy).
Deletion of personal information: the act of removing personal information from the systems involved in daily business functions to keep it in a state that cannot be retrieved or accessed.
Children: minors under the age of fourteen(14).
Part II Privacy Policy
This Section will help You understand the following:
1. How We collect and use Your information
2. How We use Cookie 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 deal with the information of minors
7. How this Privacy Policy is updated
8. How to contact us
I. 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 of information:
1. In order to enable the basic functions of the services/products We provide to You, You need to authorize us to collect and use Your information as may be necessary. If You refuse to provide such information, You will not be able to use our products and/or services normally;
2. In order to enable the auxiliary functions of the services/products We provide to You, You may choose to authorize us to collect and use Your information as is necessary. If You refuse to provide such information, You will not be able to use the corresponding auxiliary functions or cannot achieve the intended effects of such functions, which, however, will not affected Your normal access to the basic functions of our products and/or services;
You understand and agree:
1. We are committed to creating diversified products and services to meet Your needs. As We provide a wide variety of products and services to You, and the specific range of products/services that different users choose to use may vary from person to person, therefore, the corresponding basic/additional functions of such services and products, as well as the types and ranges of personal information collected and used hereunder may also vary subject to the specific product/service functions.
2. In order to enable the auxiliary functions of the services/products We provide to You, You may choose to authorize us to collect and use Your information as is necessary. If You refuse to provide such information, You will not be able to use the corresponding auxiliary functions or cannot achieve the intended effects of such functions, which, however, will not affected Your normal access to the basic functions of our products and/or services; You understand and agree: 1. We are committed to creating diversified products and services to meet Your needs. As We provide a wide variety of products and services to You, and the specific range of products/services that different users choose to use may vary from person to person, therefore, the corresponding basic/additional functions of such services and products, as well as the types and ranges of personal information collected and used hereunder may also vary subject to the specific product/service functions. 2. In order to provide You with a better product and service experience, We are making continuous efforts to improve our technology. Subsequently, We may introduce new or optimized functions from time to time, and may need to collect and use new personal information or change the purpose or method of using such personal information. In this regard, We will separately explain to You the purpose, scope and usage of the corresponding information by updating this Policy, pop-up windows, page prompts, inter alia, and provide You with the means to choose and agree at Your discretion, and collect and use the corresponding information after obtaining Your express consent. During this process, if You have any questions, comments or suggestions, You can contact us through various contact methods provided by this Platform, and We will provide a reply to You as soon as possible.
We will collect and use Your personal information to realize the following functions under this Policy:
i. Help You register and provide You with the services offered by this Platform;
1. Registration Service
We provide You with basic membership services through Your account with the Platform. In order to register as a member and access our membership services, You need to fill in and provide the following information when applying for registration:
(1) Identity Information. Such information can help us verify whether You are eligible to be registered as a member of this Platform. Such information includes but is not limited to Your name, address of Your place of residence, and other certificates and corresponding numbers thereof that are issued by Your country or government to certify Your identity information, as well as all other information that can help us verify Your identity (hereinafter referred to as "Identity Information"). Such Identity Information may vary depending whether You are an individual user or institutional user. Furthermore, in accordance with the applicable laws and regulations of different jurisdictions, the information collected by the Platform from users may vary depending on the country or region that the users are from. The following information and data are intended to serve as an indicative example:
For an individual user: his/her nationality, full legal name (including former names, if any, as well as his/her name presented in the local language of such individual user), Identity Card number, email address, telephone number, social security number ("SSN"), passport number or any other government-issued identity card number, date of birth, proof of identity (e.g. passport, driver's license or other identity certificates issued by the government).
For an institutional user: its legal corporation name (including its legal corporation name in the local language of such user), registration information, business telephone number, personal information of the authorized representative, primary business premises, and personal information of all shareholders/beneficial owners thereof (passports or identity cards issued by the government), the corporate structure of the institutional user, documents relating to the formation of the institutional user, resolutions of the board of directors thereof, declaration of the source of funding thereof, risk and compliance control instructions and other information or documents as may be required by the Platform.
(2) Service information. Such information helps us to contact You and successfully provide You with different forms of digital asset trading services. Such information includes but is not limited to: Your personal Identity Information, contact information, transaction information, as well as Your debit card information and/or other account information (hereinafter collectively referred to as "Service Information"). Furthermore, let it be understood that the Services We provide to You are subject to constant update and development. If You choose to use any other service that is not covered by the above description, and therefore it is necessary for us to collect additional information of Yours based on such service, We will explain to You the scope and purpose of such information collection through notices on web pages, interactive processes, agreements, and pop-up prompts, among others, to obtain Your consent to such collection.
If You only need to use the browsing service, You do not need to register as a 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. During the process of such real-name authentication, You need to provide Your real name, identity card number or passport number to the Platform.
If You only need to use the browsing service, You do not need to register as a 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. During the process of such real-name authentication, You need to provide Your real name, identity card number or passport number to the Platform.
Advanced Certification: when Your transaction volume on this Platform exceeds a certain limit, the Platform will require You to undergo advanced certification, in order to ensure the safety of Your assets. You agree that in such advanced authentication process, in addition to providing the information required for the real name authentication, You will also undergo the advanced authentication procedures of "facial recognition", as is required by the Platform. Facial recognition will involve the collection of Your relevant video streams or face images by the Platform.
Account Information Display: if You already have an account with the Platform, We may display Your above-mentioned personal information in the services (for real-name authentication, only the outcome of such authentication will be displayed, i.e., whether You have passed such authentication or not) and the operations You perform in the products and services associated with Your account with the Platform, including centralized display of Your personal data and transaction orders through Your Platform account. We respect Your choices in connection with the set-up of Your account with the Platform
ii. Security Management Services and Service Information Push Services
When You use the services provided by this Platform or access this Platform, in order to ensure Your transaction security and the safe and stable operation of services, this Platform needs to automatically receive and record Your web browser information, Your device information, including the device identification information (the type and model of device through which You log into Your account), Your IP address and records on the web page You request to visit, Your location, network environment, device fingerprint information, service log information, software information, location information, inter alia.
Please note that device information alone cannot identify a specific natural person. If We use this kind of non-personal information in combination with other information to determine the identity of a specific natural person, or use it in combination with personal information, such non-personal information will be regarded as personal information during such combination. Unless otherwise authorized by You or required by any of the applicable laws and regulations, We will anonymize such information and remove all identification marks therein.
In order to provide You with more convenient and personalized information display and push services, We may extract Your preferred features based on Your device information and Your browsing and usage information on this Platform or the client thereof in the future, and generate indirect group profiling based on such features, for the purpose of displaying and pushing information and possible commercial advertisements. If You do not agree to receive information pushed to You in this way, or wish to withdraw Your consent to the collection of Your personal information, You can contact us in accordance with the contact information provided under this Policy.
We strive to ensure Your browsing experience. If You do not want to receive the commercial advertising We send to You, You can unsubscribe to such advertising or otherwise disable this function by sending us a short text message or in any other way We specify. Furthermore
Furthermore, We will also use the above-mentioned information of Yours to continuously improve and optimize the above functions.
iii. Keeping and Inquiry of Transaction Records
We collect data related to 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" section of the Platform, which include: cyber name of the transaction counter-party, time of order placement, order serial numbers, transaction information, type and quantity of digital assets involved, inter alia.
iv. Customer Service and Dispute Resolution
When You contact us or apply to us for in-sales and after-sales service or for dispute resolution, We need You to provide necessary personal information to verify Your membership, so as to ensure the security of Your account and the system.
In order to facilitate our contact with You, help You solve the problems as soon as possible or record the solutions and results of the problems, We may keep Your communication records and related content (including Your account information, order information, other information You provide to prove the relevant facts, or contact information You provide). If You make queries, lodge complaints or provide suggestions in connection with any specific order, We will use Your account information and order information.
As may be reasonably necessary for us to provide services and improve service quality, We may also use other information of Yours, including the relevant information You provide when You contact our customer service department, and the replies You provide to our questionnaire surveys.
v. Miscellaneous
1. If the information You provide involve any personal information of any other user, You must ensure that You have obtained legal authorization before providing such personal information to this Platform. If any personal information of any child is involved, You must obtain the consent of such child's guardian before You may release such information. Under the aforementioned circumstance, the guardian shall have the right to contact us in any of the ways specified under Article IX of this Policy to request for the correction or deletion of any content involving the personal information of such child.
2. If We use any information hereunder for any purpose not specified in this Policy, or use any information collected for any specific purpose for any purposes other than such specific purpose, or We take the initiative to obtain Your personal information from a third party, We will obtain Your prior consent.
If We obtain Your information indirectly from a third party, We will explicitly require such third party in writing to obtain Your prior consent in accordance with law before collecting any personal information of Yours, inform You of the content of Your information that such third party shares with us, and obtain Your explicit confirmation before providing us with any sensitive information of Yours; furthermore, we will require such third party to provide an undertaking as to the legality and compliance of the source of personal information such third party provides to us. If the third party violates any of the applicable laws, We will explicitly require such third party to bear the corresponding legal responsibilities; furthermore, We will strengthen the security of personal information (including by proper filing of sensitive information, encrypted storage of sensitive information, access control, inter alia). We will use no less than the same methods and measures used by us to protect the personal information of our users to protect such personal information indirectly obtained by us.
3. Exceptions to the Requirements for Authorization and Consent
You fully understand and agree that under any of the following circumstances Your authorization is not required for us to collect and use Your personal information, and We are not obliged to respond to Your requests for correction/modification, deletion and cancellation of your information, or your requests for the withdrawal of your consent or your requests to access your information:
(1) Where state security and/or national defense security are involved;
(2) Where public security, public health and/or major public interests are involved;
(3) Where judicial or administrative enforcement, e.g., criminal investigation, prosecution, trial and sentence enforcement, is involved;
(4) Where it is for the purpose of protecting Your or another personโ€™s life, property and/or any other important legal rights and interests, yet it is difficult to obtain the consent of Yours or such person, as the case may be;
(5) Where such information is Your personal information that You disclose to the public by Yourself;
(6) Where such information is Your personal information that is collected from legally disclosed information, such as legal news reports and government information disclosures, inter alia.
(7) Where it is required by any agreement or any other written document signed with You;
(8) Where it is necessary for maintaining the safe and stable operation of the products and/or services provided hereunder, such as uncovering and handling errors and faults in the products and/or services hereunder;
(9) Where it is necessary for legal news reporting;
(10) Where it is necessary for any public-interests-based statistical survey or academic research by any academic research institute, and when the results of such research or survey are provided externally, the personal information contained in such results shall be neutralized; and
(11) Other circumstances stipulated by any of the applicable laws and regulations.
Please be aware that in accordance with the applicable laws, if We adopt technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore such personal information to its status prior to our processing, or We may conduct unmarked research, statistical analysis and prediction on the collected information to improve the content and layout of this Platform, to provide product or service support for business decisions, and to improve our products and services (including using anonymous data for machine learning or model algorithm training), then the use of such processed information shall not be subject to a separate notice to You or Your consent.
4. If We stop operating the products or services of this Platform, We will stop collecting Your personal information in a timely manner, notify You of such termination of operation either through a special one-on-one notice to You or a general public announcement, and we will delete or anonymize the personal information that We hold in connection with such terminated business.
II. How We Use Cookies
If Your browser or browserโ€™s add-on service permits, You can change the setting of Your browser so as to modify its degree of cookie acceptance or so that Your browser rejects Our cookies. For more details, please refer to AboutCookies.org. However, if You make such changes, it may affect Your safe access to our Platform under certain circumstances, and in this case, 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 will use Google Stats via cookies to record our performance and check the effect of online advertising. Cookies are small amounts of data sent to Your browser and stored on Your computer hard drive. Cookies can only be sent to Your computer hard disk when You use Your computer to access our Platform.
2. Cookies are often used to record the habits and preferences of visitors when they visit various items on our Platform. The data collected via cookies are anonymous collective statistics and do not contain personal data.
3. Cookies cannot be used to obtain data on Your hard disk, Your email address, or Your personal data; instead, they enable the Platform or service providerโ€™s system to recognize Your browser and capture and remember information. Most browsers are preset to accept cookies. You can choose to set Your browser to refuse to accept cookies, or to notify You as soon as cookies are installed. However, if Your browser is preset to prohibit cookies, You may be unable to start or use some features of our Platform.
III. How We share, transfer and publicly disclose Your information
(1) Sharing
We will not share Your personal information with any company, organization and individual other than service providers of this Platform, except for under any of the following circumstances:
1. Sharing under statutory circumstances: we may share Your personal information externally in accordance with applicable laws and regulations, or as may be necessary for litigation and dispute resolution requirements, or as is required by administrative and judicial authorities.
2. Sharing with explicit consent: after obtaining Your explicit consent, We will share Your personal information with other parties.
3. Sharing subject to Your voluntary choice: We will, in accordance with Your choice, share with the transaction counter-party of the digital assets the necessary information related to the transaction in Your order information, so as to meet Your transactions related to transaction and after-sales services.
4. Sharing with authorized partners: we will share information with our affiliated parties and trusted third parties that help us operate our Platform, carry out business or provide services to You, as long as these parties agree to keep the information strictly confidential; We will share information when We believe that such disclosure of information is appropriate, in compliance with laws, regulations, rules and regulations or orders from courts of law or other competent authorities, implements our Platform strategy, is required for the normal operation of the Platform, is required for related parties to provide services or protect our or any other personโ€™s rights, property or safety.
ii. Transfer
We will not transfer Your personal information to any company, organization or individual except for under any of the following circumstances:
1. Transfer subject to explicit consent: After obtaining Your explicit consent, We will transfer Your personal information to another party;
2. In the event of the merger, acquisition or bankruptcy liquidation of the Platform, or any other situation involving merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved therein, We will require the new company or organization holding Your personal information originally held by us to continue abiding by this Policy; otherwise We will require such company or organization or individuals involved to seek Your authorization and consent.
iii. Public Disclosure
We will only publicly disclose Your personal information under the following circumstances:
1. We may publicly disclose Your personal information with Your explicit consent or based on Your voluntary choice;
2. If We determine that You have violated any of the applicable laws and regulations or seriously violated any of the relevant agreement or rules of the Platform, or in order to protect the personal and property safety of users of the Platform or the public from infringement, We may disclose Your personal information in accordance with the applicable laws and regulations or with Your consent, including relevant violations and measures already taken against You by the Platform.
iv. Exceptions to the requirements for Your prior authorization and consent for the sharing, transfer or public disclosure of your personal information
Under the following circumstances, the sharing, transfer or public disclosure of Your personal information is not subject to Your prior authorization and consent:
(1) where state security and/or national defense security are involved;
(2) where public security, public health and/or major public interests are involved;
(3) Where judicial or administrative enforcement, e.g., criminal investigation, prosecution, trial and sentence enforcement, is involved;
(4) Where it is for the purpose of protecting Your or another personโ€™s life, property and/or any other important legal rights and interests, yet it is difficult to obtain the consent of Yours or such person, as the case may be;
(5) Where such information is Your personal information that You disclose to the public by Yourself; and
(6) Where such information is Your personal information that is collected from legally disclosed information, such as legal news reports and government information disclosures, inter alia.
Please be aware that in accordance with the applicable laws, if We adopt technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore such personal information to its status prior to our processing, then the sharing, transfer or public disclosure of such personal data so processed shall not be subject to notification to You or consent by You.
IV. How We protect Your information
1. We implement proper physical, electronic, management and technical measures to protect and safeguard Your personal data. We will exert our best efforts to ensure that any personal data collected through our Platform are free from any nuisance caused by any third party unrelated to us. The safety measures We adopt include but are not limited to:
(1) Physical measures: Records containing Your personal data will be stored in a properly locked place.
(2) Electronic measures: Computer data containing Your personal information will be stored in computer systems and storage media that are subject to strict log-in restriction.
(3) Management measures: We have set up an internal safety defense department to protect the users' information, established relevant internal control systems, and adopted the principle of strict authorization for our employees who may come into contact with Your information; therefore, only properly 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. Furthermore, we provide sustained training to our staff on relevant laws and regulations, privacy and safety guidelines, enhance publicity and education on safety awareness, and organize our relevant internal personnel to carry out emergency response training and emergency drills on a regular basis, so as to enable them to fully understand their job duties and emergency response strategies and procedures.
(4) Technical Measures: encryption technology such as Secure Socket Layer Encryption may be adopted to transfer Your personal data.
(5) Security Measures: In order to ensure Your information security, we are committed to using various currently available general security technologies and supporting management systems to minimize the risks that Your information may be disclosed, damaged, misused, accessed without authorization, disclosed without authorization or altered. For example, the Secure Socket Layer (SSL) software is used for encrypted transmission, encrypted information storage and strict restriction of data center access. When transmitting and storing sensitive personal information (including personal biometric information), we will adopt security measures such as encryption, authority control, removal of identification marks, and de-sensitization, inter alia.
(6) Other measures: We regularly review our personal data collection, storage and processing procedures; furthermore, we limit the access of our employees and suppliers to Your data in accordance with the principle of โ€œas necessaryโ€, and our employees and suppliers must abide by strict contractual confidentiality obligations.
2. If You become aware of any security vulnerability of our Platform, please contact us promptly so that We can adopt appropriate actions as soon as possible.
3. Despite the above-mentioned technical and security measures, We cannot guarantee the absolute safety of data transmission on the Internet, so We cannot absolutely guarantee that the personal data You provide to us through our Platform are safe at all times. We will not regularly update and make public security risks and personal information security impact assessment reports, inter alia, which You can obtain through announcements made by this Platform.
V. How You manage Your information
You can access and manage Your information in any of the following ways:
i. Query, correct and delete Your information
You have the right to obtain a copy of Your personal data upon Your request, and to determine whether the information we have about You is accurate and up-to-date. If any of Your personal data is not accurate, You can request to update Your information. You can also request for the deletion of Your personal data, provided, however, we may reject Your deletion request in some cases, e.g., where such rejection is required by law or for other legal purposes. For data access, correction or deletion requests, please contact us according to the contact information under Article VIII hereof.
In response to application for access to or correction or deletion of data, we will verify the identity of the applicant to ensure that such applicant is legally entitled to make such application. Although our goal is to respond to such application on a gratuitous basis, we reserve the right to charge You a reasonable fee if Your request is repeated or onerous.
ii. Changing the scope of Your authorization
The fulfillment of each business function is subject to certain basic personal information (see Part I of this Privacy Policy). Furthermore, You can contact us through the contact information under Article VIII to grant or withdraw Your authorization.
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 existing personal information processing based on Your authorization.
iii. Cancellation of Your account
You can contact us through the contact information under Article VIII hereof to apply for cancellation of Your account. After You voluntarily cancel Your account, We will stop providing You with products or services, and delete Your personal information or anonymize it in accordance with the requirements of applicable laws.
iv. Respond to Your above requests
To ensure safety, 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 reply within fifteen(15) days. If You are not satisfied with our reply, You can also initiate a complaint through the contact information provided by us.
In principle, We do not charge any fee on Your reasonable requests, provided, however, We may charge a certain fee on Your repeated requests or requests that exceed reasonable limits, based on the actual circumstances. We may reject requests involving information that is not directly related to Your identity, unjustified repeated information, or requests that require too many technical means (e.g. to develop new systems or fundamentally change existing practices), requests that pose risks to any other person's legitimate rights and interests, or are unrealistic.
Under the following circumstances, We will not be able to respond to Your request in accordance with applicable laws and regulations:
1. where state security and/or national defense security are involved;
2. where public security, public health and/or major public interests are involved;
3. Where judicial or administrative enforcement, e.g., criminal investigation, prosecution, trial and sentence enforcement, is involved;
4. Where there is sufficient evidence proving that the owner of such personal information has subjective malice or abuse of power;
5. Where response to Your request would cause serious damage to the legitimate rights and interests of You or any other individual or organization;
6. Where any trade secret is involved.
VI. How We deal with the information of minors
This Platform is not open to children. If We find or suspect that the user is under 14 years old, 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 anyone under the age of 14 uses our services, please inform us so that We can take action to prevent them from obtaining our products or services.
If we find out or suspect that a user is less than fourteen (14) years old, we will ask the user to close his/her account and will not allow the user to continue using the products and services of the Platform. We will delete the relevant information of such users as soon as possible. If You know that any person who is under the age of fourteen (14) uses our services, please notify us so that we can adopt actions to prevent such user from accessing our products or services.
For minors who have reached the age of fourteen(14) but are less than eighteen(18) years old, We expect their parents or guardians to guide such minors in using our services. We will protect the confidentiality and security of such minors' information in accordance with relevant state 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 subject to the consent of Your parents or guardian. If we collect Your information with the consent of Your parents or guardians, we will only use or disclose such information when it is permitted by law, expressly approved by Your parents or guardian or is necessary for protecting Your rights and interests. If Your parents or guardian disagrees with Your use of our services or Your providing us with information in accordance with this Policy, please stop using our services promptly and inform us in time so that we can take corresponding measures.
If You are the parent or guardian of a minor, please contact us through the contact information hereunder when You have any questions in connection with our processing of the information of the minor of whom You are a parent or guardian.
VII. How this Privacy Policy is updated
Our Privacy Policy is subject to changes.
Without Your explicit consent, We will not restrict Your rights under this Privacy Policy. We will publish any and all changes to this Privacy Policy via official channels. If You do not agree with any such change, You should stop accessing this Platform promptly. After an updated version of this Privacy Policy is released, Your continued visit to this Platform shall be deemed as showing and indicating that You agree with such update and agree to abide by the updated version of this Privacy Policy.
For any major change made hereto, We will also issue more prominent notices (including notices made in the form of public announcements made through this Platform and even pop-up prompts to You).
Major changes referred to in this Policy include but are not limited to:
1. Significant changes in our service mode. For example, the purpose of processing personal information, the types of personal information processed, the ways in which personal information is used, inter alia.
2. Significant changes in our control. Such as changes in information controllers caused by any merger and acquisition, inter alia;
3. Any change in the major person(s) which personal information hereunder is shared with, transferred or publicly disclosed to;
4. Significant changes in Your right to participate in personal information processing and the way You exercise such right;
5. Changes in our department responsible for personal information security, or changes in the contact information of such department, or the ways in which complaints hereunder are lodged; and
6. The security impact assessment report for personal information hows that there is a high degree of risks.