Privacy Policy

Last Update: 02/29/2024 @ 08:45:00 AM (UTC)

Purpose and Basis

In order to provide the services of the Platform to Users, We need to collect some of your personal information when you register with the Platform, log in to the Platform and/or use the services offered by the Platform. This Privacy Policy, in combination with Platform's other applicable policies, set out the rules as to the use and protection of the collected information in order to prevent misuse.

Designation

For the convenience of wording in this agreement (the Agreement), the Platform is referred to as we, us or our. Users of and other visitors to the Platform are referred to as you, your or User. We and you are collectively referred to as both parties and as a/one party individually.

Definition and Interpretation

The following terms or expressions shall have the meanings ascribed to them below, unless any other term or condition hereunder provides otherwise:

1. Personal Information: all information that is recorded electronically or otherwise and can be used, whether independently or in combination with any other information, to identify any particular natural person or reflect the pattern of behaviour of a particular natural person, including, but not limited to, sensitive personal information.
2. Sensitive Personal Information: including but not limited to identity card and other proof of identity documents details, personal biometric information, bank account details, registered address, whereabouts, transaction information, etc.
3. Deletion of personal information: the deletion of personal information from any system involved in carrying out routine business functions so that such personal information cannot be accessed or retrieved.

Scope of Application

This Agreement shall apply to all Users trading on the website (the Platform). Users shall comply with the terms and conditions of this Agreement, subject to and as permitted by any and all laws relating to the protection of personal information and data in the country or region where they are based.

Invocation

Any code or statutory decree or administrative regulation referred to in this Agreement shall refer to the latest amended version thereof, regardless of whether such amendment is made before or after the signing of this Agreement.

Headings

The headings used in this Agreement are for convenience only and shall not be used for the purpose of interpreting the terms and conditions of this Agreement. References herein to any statement, term, condition, annex, schedule shall refer to statements, terms, conditions, annexes and schedules hereunder.

Use of the term include

The term include used herein shall, under any and all circumstances always have the meaning of “include but not limited to”, unless this Agreement specifies otherwise.

User Consent and Authorization

The Users acknowledge and understand that, at the point of logging into the Platform, the User will be deemed to have expressed to us their acceptance, consent, undertaking and confirmation of the following, regardless of whether the User has completed their registration on the Platform:

1. that the User agrees, on a voluntary basis, to disclose personal information to us;
2. the User will abide by all the terms and conditions of this Agreement;
3. the User agrees and authorises the Platform to collect the User’s personal information when the User registers with the Platform, logs into the Platform and/or uses the Platform services;
4. the User agrees to all the terms and conditions of this Agreement and agrees to accept any amendment that may subsequently be made to the Privacy Policy;
5. the User agrees that any of our branch companies, subsidiary companies, or employees will contact the User in connection with any product and service that may be of interest to the User (unless the User has indicated that he or she does not wish to receive such information).

Information Collected

The Users agree that the Platform may use cookies to track the User’s actions in connection with their use of the Platform and may collect and record all information left by Users, including but not limited to their IP address, geographical location and other data.

Personal data which we may collect include:

• Personal Identification Information: Full name, date of birth, nationality, gender, ethnicity, signature, facial data, utility bills, photographs, phone number, precise location, home address, and/or email.
• Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
• Virtual Identity: Account/ Password, Nickname.
• Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.
• Financial Information: Bank account information, payment card primary account number (PAN), account assets, transaction history, trading data, and/or tax identification.
• Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
• Message Content: Feedback, Email, SMS, App Rating, Comments.
• Application Activity: Browsers and tap records, search history, installed apps, running apps, crash logs、user-generated content, favorites, mouse movement, scroll position, key events, and touch events.
• Device Information: Carrier, brand, software version, model name, manufacturer, system language, OS Version、Locale、Fingerprint、Build ID、Baseband Version、SIM Country、SIM Serial Number、Battery Status、network, OAID, IMEI, GUID, MAC address, Android ID, SSID, Advertising ID and gyroscope/accelerometer data.
• Employment Information: Office location, job title, and/or description of role.
• Correspondence: Survey responses, information provided to our support team or user research team.
• Audio, electronic, visual and similar information, such as call and video recordings.

We will collect your personal data in accordance with the legislative purpose of the DPA. We may also collect and store certain information automatically when you visit the Site. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.

Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

For example, we may automatically receive and record the following information on our server logs:

1. How you came to and use the Services;
2. Device type and unique device identification numbers;
3. Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
4. How your device interacts with our Sites/APP and Services, including pages accessed and links clicked;
5. Broad geographic location (e.g. country or city-level location); and Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

We may also use identifiers to recognize you when you access our Sites/APP via an external link, such as a link appearing on a third-party site.

Information Disclosure to Third Parties

The Platform does not sell, trade, or otherwise transfer information or allow any other party to collect or use any information from our Platform. However, this does not involve the following parties and does not include the following information: the Platform's affiliates, trusted third parties who help the Platform operate the Platform's websites, manage the Platform's business or provide services to Users, provided that these parties agree to keep such information confidential. If the Platform discloses information to the above-mentioned parties, such information disclosure shall in accordance with any applicable laws, regulations, rules or by any order of any court or other competent authorities, or necessary for executing the strategy of the Platform and ensuring the proper functioning of the Platform, or as may be necessary for the related parties to provide services, or for the protection of the rights, property or safety of us or other persons. Any such information disclosure will not be used by any of the above-mentioned parties for marketing, advertising or any other purpose that has not been agreed on by all the parties concerned.

For Example, (a) We may use AppsFlyer to measure the advertising performance, detect and prevent fraudulent activity on your account in real time. Information shared with AppsFlyer is treated by AppsFlyer in accordance with its Privacy Policy, available at https://www.appsflyer.com/legal/services-privacy-policy/ . (b)We may use Sentry to monitor the anomalies of the Platform. Information shared with Sentry is treated by Sentry in accordance with its Privacy Policy, available at https://sentry.io/privacy/ .

Protection of Personal Data

The Platform adopts appropriate physical, electronic, management and technical measures to protect and safeguard the security of the User's personal data. The Platform will, to the greatest extent possible, ensure that any personal data collected through the Platform shall be free from being subject to nuisance by any third party unrelated to us. The security measures that the Platform may take include but are not limited to:

1. Physical measures: records of User's personal information will be stored in an appropriately secure location.
2. Electronic measures: computer data containing User's personal information will be stored in computer systems and storage medias that are subject to strict login restrictions.
3. Management measures: only staff members duly authorized by the Platform may access the User's personal data and such staff members shall comply with the Platform's internal code concerning personal data confidentiality.
4. Technical measures: encryption techniques such as Secure Socket Layer Encryption may be used to transmit User's personal data.
5. Other measures: the Platform's network servers are protected by a proper firewall.

Deletion of personal information

Once your personal account is deleted, you will no longer be able to log in to or use the platform. Your personal data will be retained by the platform for 1 year in order to satisfy any subsequent review of your account by financial institutions or criminal investigations by relevant authorities. If no such review or investigations occurs within this year, the platform will completely delete all your personal data.

Reporting of Flaws

If any User becomes aware of any security flaw in the Platform, the User should contact the Platform through the service email promptly so that the Platform can take appropriate measures to address any such flaw as soon as possible.

Exemption

Despite the above-mentioned technical and security measures, the Platform cannot guarantee that the information transmitted via the Internet is absolutely safe, so the Platform does not provide any guarantees with respect to the security of the personal information that the Users provide to the Platform; and the Platform may not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to the Users’ personal information.

Amendment of this Agreement

The Platform reserves the right to modify this Agreement at any time. The Platform will inform the Users of the amendments made to the Privacy Policy by releasing updates thereof, publishing the effective date of new versions thereof and highlighting the amendments thereto. Sometimes, but not always, the Platform may issue a notice to Users to inform them of any amendments made to the Privacy Policy. Users shall regularly review the Privacy Policy and focus on amendments thereto, if any; and if the Users do not agree to any such amendments, the Users shall promptly stop accessing this Website. Whenever an updated version of this Privacy Policy is released, the User’s continued access to and use of this Website shall demonstrate the User’s agreement to the updated version of the Privacy Policy.

Publication of Announcements

The Platform publishes announcements and information exclusively via the use of valid and up-to-date contact information provided to this Website or by posting announcements on the Platform. Therefore, the Platform shall not be held liable for any loss arising from any User’s trust in any information that is obtained in any manner other than the above-mentioned means.

Communication with Us

Any User comments or feedback should be sent to our support team email address that you can also see at the website footer (at the bottom of every pages). This is the only valid and official email address through which the Platform communicates with Users. If an User uses any other means of communication to contact the Platform, the Platform shall not be obliged to reply and the Platform will not be held liable in any manner whatsoever.