uses client’s Personal Data (defined below) company provides access and utility
through our digital asset trading platform via software, API (application
program interface), technologies, products and/or functionalities (“Service”).
In the course of providing Service, to abide by the laws in the jurisdictions
that the company operates, and to improve services, company needs to collect
and maintain personal information about the client. As a rule, the company
never discloses any personal information about our customers to any
non-affiliated third parties, except as described below.
time by posting the amended version on this site including the effective date
of the amended version.
- Company communicates any material changes to
- Virtual Financial Asset
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
- Centralized or decentralized,
- Closed or open-source, and:
- Used as
a medium of exchange and/or store of value.
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.
of Personal Data
- Company collects, processes, and stores
Personal Data collected from you via client’s use of the Service or where client
has given consent.
- This Personal Data may include contact details,
copies of identification documentation provided by client or derived from publicly
accessible databases, government identification number as well as information
relating to devices or internet service
(such as an IP address and a MAC number).Company collects information provided during the onboarding process, which
may be a completed, incomplete, or abandoned process.
- Company collects, uses, stores, and transfers
Personal Data, which may include the following:
- Operating within the European Economic Area
- Company collects, stores, and processes personal information in accordance with the Best
Practices of the Data Collection in the EU.
- Types of client
defined in APPENDIX A.
- Collection and
Storing of Data Outside the EU
- As outlined above, company may collect Personal
Data from customers located in the EEA. To facilitate the services company
provides to customers located in the EEA, company requests explicit consent for
the transfer of Personal Data from the EEA to outside of the area. If client is
an individual located in the EEA and declines to consent to such transfer, client
will no longer be able to use company services.
- Client will have the ability to withdraw your
digital assets; however, all other functionalities will be disabled.
- Company uses Personal Data to communicate with the
client and to administer, deliver, improve, and personalize the Service. Company
might also generate generic data out of any Personal Data collected and use it
for company purposes.
- Company may also use such data to communicate
with you in relation to other products or services offered by company and/or
its partners. Company does not share
Personal Data with third parties (other than partners in connection with
their services) except where client have given consent and further detailed
- Company may share Client Personal Data with third parties:
- If company deems that sharing it is necessary
to enforce the Terms of Service；
- To comply with government agencies, including
regulators, law enforcement and/or justice departments；
- To third parties who provide services to the
company (such as administration or technical services)；
connection with the sale or transfer of our business or any part thereof.
- Additionally, company has 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
- The data that company collects from the client
may be transferred to, and stored at, a destination outside of the EU.
- It may also be processed by staff operating
outside of the EU who work for the company or for one of company suppliers. By
submitting client personal data, client agrees to this transfer, storing or
processing, except customers located in the EEA, as detailed above.
- All information you provide to us is stored on company
and/or third party cloud servers.
Access and Correction of Personal Data
- Client has the right to obtain a copy of
Personal Data upon request and ascertain whether the information company holds
about client is accurate and up-to-date.
- If any of the Personal Data is inaccurate, client
may request to update the information. Client may also request to delete
Personal Data, with exception that the company may refuse client deletion
request in certain circumstances, such as compliance with law or legal
purposes. For data access, correction, or deletion requests, please
- In response to data access, correction, or
deletion request, company will verify the requesting party’s identity to ensure
that he or she is legally entitled to make such request. While company aims to
respond to these requests free of charge, company reserve the right to charge client
a reasonable fee should the request be repetitive or onerous.
- Company may communicate company news,
promotions, and information relating to our products and services provided. Company
may share Personal Data with third parties to help with
marketing and promotional projects, or sending marketing communications.
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 [email protected]
- For product related communications, such as
policy/terms updates and operational notifications, client will not be able to
opt out of receiving such information.
Company endeavors to protect clients from
unauthorized access, alteration, disclosure, or destruction of Personal Data that
the company collects and stores. Company take various measures to ensure
information security, including encryption of the communications with SSL;
required two-factor authentication for all sessions; periodic review of our
Personal Data collection, storage, and processing practices; and restricted
access to client’s Personal Data on a need-to-know bases for our employees and
vendors who are subject to strict contractual confidentiality obligations.
Contacting Company about Privacy Concerns
sending an email to the following address [email protected] with
the subject “PRIVACY REQUEST”.
website and, when appropriate, company will notify client by email.