Dear Users,
(“CoinW” or “we”) respects and protects the privacy of Users (“you” or “Users”). CoinW will collect and use your Personal Information, generated from your use of CoinW, in accordance with this Privacy Policy (“Policy”).
CoinW recommends that you shall carefully read and understand the whole contents of this Policy before your use of the product (“CoinW Exchange”). Additionally, significant information including the Disclaimer is in bold form in this Policy. Definitions of key words in this Policy are consistent with those in the CoinW Terms of Service of CoinW Exchange.
CoinW reserves the right to update this Policy online from time to time, and the new policy will immediately replace the older one once posted. In particular, if you do not accept the revised policies, please immediately stop your use of CoinW Exchange. Your continuous use of CoinW Exchange will be regarded as your acceptance of the revised policy. Furthermore, the revised policies will take into effect immediately upon being posted on CoinW Exchange.
You acknowledge and accept that this Policy and other relevant rules apply to CoinW and the DApps owned by CoinW on CoinW Exchange.
- Information We Collect
We collect your information in order to provide the services you requested on CoinW Exchange, and we highly value the protection for your privacy. We strictly abide by the principle of “lawful, justifiable and necessary” during our collection of your information. You acknowledge that, if you do not provide us with necessary information, your user experiences on CoinW Exchange may be influenced.
1.1 We may collect your Personal Information, including but not limited to your mobile device information, operation records, transaction records and account addresses.
1.2 In order to satisfy your needs for specific services, we may collect your name, bank card number, telephone number, email address etc.
1.3 You confirm that your Account Password, Private Key, Mnemonic Words, Keystore on CoinW are not stored or synchronized on CoinW Exchange’ servers. CoinW Exchange does not offer the service to restore your Account Password, Private Key, Mnemonic Words or Keystore.
1.4 Apart from the foregoing provisions, when you are using specific function of CoinW, we may give you special notification to ask for more Personal Information. Your objection to provide more information will be regarded as your choice not to use this specific function of CoinW Exchange.
1.5 After you link to the third-party-developed DApps from CoinW Exchange, your Personal Information will be collected and held by the third-party-developed DApps instead of being collected or held by CoinW Exchange.
1.6 To the extent permitted by laws and regulations, CoinW Exchange may collect and use following Personal Information without your prior consent or authorization:
- information related to national security and national defense;
- information related to public security, public health, significant public interests;
- information related to criminal investigation, prosecution, trial and enforcement;
- the Personal Information collected is publicized by yourself;
- the Personal Information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
- the Personal Information is necessary to maintain the security and compliance of services, such as to detect or to solve the malfunction of products and services;
- other circumstances prescribed by laws and regulations.
1.7 We collect information in the following ways:
- Information you give us. For example, you fill in your name, telephone number, or bank card number in “My Account” column or you provide your email address when submitting feedbacks, or you give extra information to us when you use our specific services.
- we collect information during your use of CoinW Exchange, including your mobile devices information and your operation records on CoinW Exchange etc.
- we copy all or part of your transaction records on blockchain. However, Users shall refer to the blockchain system for the latest transaction records.
- How We Use Your Information
2.1 We may associate you with your account by the unique serial number of your mobile device.
2.2 We may promptly push important notifications to you, such as software update, update of Terms of Service and this Policy.
2.3 We offer you the “Touch ID” option in the “Settings” column of CoinW Exchange to provide you with a convenient and safe way to manage your digital Tokens.
2.4 We deal with your feedbacks by using the Account Address and the mobile device information provided by you.
2.5 We may collect your Personal Information to conduct our internal audit, data analysis and research etc. to enhance our services.
2.6 According to CoinW Terms of Service and other rules of CoinW, CoinW will manage and handle the use behaviors of Users through Users’ information.
2.7 We may use your information in accordance with laws, regulations and to cooperate with regulatory authorities.
- How You Control Your Own Information
You are entitled to control your Personal Information provided to CoinW Exchange:
3.1 You may add or delete Tokens, transfer and collect Tokens using the “Assets” column.
3.2 You understand that you may handle the following operations in the “Profile” column on CoinW Exchange:
- in the “Profile” column, you do not have to provide your name, telephone number, bank card number information. But if you wish to use specific services, you may need to provide the foregoing information;
- in the “Feedback” column, you may submit any questions or suggestions for CoinW Exchange at any time. We are glad to communicate with you to improve our services.
3.4 When we collect information from you for a specific purpose, we will ask for your consent in advance to which you are entitled to refuse. However, you understand that when you refuse to give such consent, you also give up the choice to use specific services provided by CoinW Exchange.
3.5 You acknowledge that since blockchain is an open source system, your transaction records are automatically public and transparent in the whole blockchain.
3.6 You understand that after you link to the third-party-developed DApps from CoinW, the CoinW Terms of Service and CoinW Privacy Policy will no longer apply. You are encouraged to carefully review its privacy policies and related terms of service before you start to use the third-party-developed DApps.
3.7 You are entitled to ask us to update, revise, and delete your relevant information.
3.8 We reserve the right to collect your information without your prior authorization or consent according to the Article 6 of Section 1 of this Policy.
- Information We may Share or Transfer
4.1 The Personal Information collected and generated by CoinW during its operation within the territory of PRC EU and UK (GDPR) shall be stored within the territory of PRC EU and UK (GDPR) . If we need to transfer your Personal Information abroad, we shall obtain your prior consent and conduct the cross-border data transfer in accordance with PRC EU and UK (GDPR) laws, regulations and policies and undertake the confidentiality obligations to protect your Personal Information.
4.2 CoinW Exchange will not share with or transfer your Personal Information to any third party without your prior consent, except for the following circumstances:
- you have expressly provided your prior consent or authorization;
- the collected Personal Information is publicized by yourself;
- the Personal Information is collected from public information which was legally disclosed, such as news (lawfully reported), government information disclosure and other channels;
- we may share your Personal Information with our affiliates only when necessary and to the extent permitted by this Policy;
- in order to abide by applicable laws, regulations, legal procedures, and administrative or judiciary authorities;
- in the case of mergers and acquisitions, if transfer of Personal Information is involved, CoinW may require the receivers of Personal Information to be continuously bound by this Policy.
- How We Protect Your Information
5.1 If CoinW terminates operation, CoinW will stop the collection of your Personal Information in time, post the announcement on CoinW Exchange and delete or anonymize your Personal Information held by us within a reasonable period.
5.2 To protect your Personal Information, CoinW may adopt data security techniques, improve internal compliance levels, provide security training for our staff, and set security authority for access to relevant data to protect your Personal Information. And CoinW will use the variety of security technologies and related management systems to minimize the risks of your information from being leaked, damage, misuse, unauthorized access, unauthorized disclosure, and change. In addition, CoinW will take other measures which are reasonably necessary to protect your information. For example, in the development environment, using the identifying information for statistical analysis; when issuing external research report, the information contained in the report will be de-identified. CoinW stores de-identified information separately from information that can be used to recover identified individuals, ensuring that individuals are not re-identified in subsequent processing of de-identified information.
5.3CoinW has established the Personal Information Protection Responsibility Department to conduct personal information security impact assessments for the collection, use, sharing, commissioning of personal information, etc. At the same time, CoinW has established the relevant internal controls system, adopted minimum authorization principles for staffs who may have access to your information, systematically monitoring the handling of your information, and continuously training and improving the awareness of the relevant laws and regulations and privacy safety guidelines.
5.4 We will send you messages about information security in the “Notifications” column and update articles concerning the use of account and information protection in the “Support” column on CoinW for your reference.
Be sure to keep your account password, private key, mnemonic words, Keystore and other identity elements on your CoinW Exchange. When you use the Services, CoinW Exchange will identify you through your login information and other identity elements. Once you disclose the information, you may suffer losses, which is not good for you. If you find that your login information and/or other identity elements may or have been leaked, please contact us immediately so that we can take appropriate action to avoid or mitigate the loss.
- Protection for the Minors
The following special provisions apply to minors who are under the age of 18 years old:
6.1 The minors shall not use CoinW without the guidance from their parents or guardians.
6.2 The parents and guardians of the minors shall provide guidance to the minors on using CoinW after they read this Policy, CoinW Terms of Service and other relevant rules.
6.3 CoinW will ensure the confidentiality and security of the minors’ Personal Information in accordance with PRC EU and UK (GDPR) laws and regulations.
- Disclaimer
7.1 After you link to the third-party-developed DApps from CoinW, the privacy policies of the third-party-developed DApps will apply. The collection and use of your Personal Information by the third-party-developed DApps will be controlled neither by CoinW, nor by this Policy. CoinW is unable to guarantee that the third-party-developed DApps will definitely take Personal Information protection measures as required by CoinW.
7.2 You shall carefully select and use the third-party-developed DApps and protect your Personal Information. CoinW shall not be held liable for the privacy protection obligation of any third-party-developed DApps.
7.3 YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, COINW WILL ADOPT MEASURES AS REASONABLE AS POSSIBLE TO PROTECT YOUR PERSONAL INFORMATION UNDER CURRENT TECHNIQUES ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS, TO AVOID THE DISCLOSURE, TAMPERING OR DAMAGE OF INFORMATION. SINCE COINW TRANSFERS DATA WIRELESSLY, COINW MAKES NO GUARANTEE ON THE PRIVACY AND SECURITY OF WIRELESS INTERNET DATA TRANSFERRING.
- Miscellaneous
8.1 If you are a User outside of PRC EU and UK (GDPR) , you shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of CoinW.
8.2 During your use of CoinW services, if you come across any problems related to your Personal Information use, you may contact us through the submission of your feedbacks on CoinW.
8.3 You may access this Policy and other service rules of CoinW on CoinW Exchange. We encourage you to check the Terms of Service and Privacy Policy of CoinW each time you log onto CoinW Exchange.
8.4 This English version and other translated version of this Policy are provided for the convenience of Users, and are not intended to revise the original Chinese version of this Policy. If there is any discrepancy between the Chinese version and non-Chinese version of this Policy, the Chinese version shall prevail.
8.5 This Policy shall become effective on Aug.11, 2022.
As for any issues not covered in this Policy, you shall comply with the announcements and relevant rules as updated by CoinW from time to time.
Please understand that the services that CoinW Exchange provides to you are constantly updated and developed. If you choose to use other services that are not covered in the previous instructions, CoinW Exchange will separately explain to you the scope and purpose of the information collection based on the page prompts, interaction process, and agreement, and get your consent. CoinW will use, store, and provide and protect your information in accordance with this policy and the corresponding user agreement; if you choose not to provide the above information, you may not be able to use one or some of the Services, which will not affect your use of CoinW Exchange Other services provided. In addition, the third party entities may provide services to you through CoinW. Exchange When you enter the service page operated by a third party entity, please note that the related services provided to you are from the third party, which involving third-party entities to collect personal information from you. We recommended that you carefully review the privacy policy or contract with the third-party entity.
CoinW Co., Ltd.