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Privacy Policy

Huobi Pool ECO Exchange APP Privacy Policy

This Version Updated on: February 7, 2020

 

Effective Date of This Version: February 7, 2020

 

 

 

Huobi Pool ECO Exchange ((hereinafter referred to as "Our Company") is fully aware of the importance of personal information to You and will exert our best efforts to protect Your personal information. Our Company is committed to retaining Your trust in Our Company and will protect Your personal information in accordance with the following principles: the principle of parity of authority and responsibility, the principle of clear purposes, the principle of choice to consent, the principle of necessity, the principle of ensuring security, the principle of openness and transparency, among others. Furthermore, Our Company promises to adopt appropriate security measures to protect Your personal information in accordance with the law.

The Huobi Pool ECO Exchange APP Privacy Policy (hereinafter referred to as “this Privacy Policy”) is intended to help You understand the following:

1. How Our Company collects and uses Your information

2. How Our Company uses Cookie and similar technologies

3. How Our Company shares, transfers and publicly discloses Your information

4. How Our Company stores and protects Your personal information

5. How Our Company enables You to have the right to manage Your personal information

6. How Our Company deals with the information of minors

7. Application and updating of this Policy

8. How to contact Our Company

 

I. How Our Company collects and uses Your personal information

Personal information refers to 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 information includes names, mobile phone numbers, email addresses, types of certificate, certificate numbers, security tool (GA) information, personal biometric information, account assets, geographic location information, electronic device information (including device models, types of operating system, unique device identifications, login IP addresses, method, type and status of access to the Internet, Internet access quality information, etc.), operation log information, residential address, face image information, payment method information (bank card account number, WeChat account numbers, Alipay account numbers and/or other payment account numbers), payment transaction records, account information, transaction information, receipt addresses, etc.

Sensitive personal information refers to personal information whose disclosure, illegal supply or abuse may endanger personal and property safety, and easily lead to damage to personal reputation, physical and mental health or discrimination. It mainly includes: Your property information (account information, account assets, bank card account numbers, WeChat account information, Alipay account information, etc.); Your identity information (types and numbers of Your identity documents, residential address, face image information); network identification information (email address); other information (login IP addresses, geographic location information, transaction record), etc.

i. How to collect information

为向您提供APP服务并确保您的账号和服务安全，在您使用手机服务[1] 过程中，我司会收集您在使用服务过程中主动输入或因使用服务而产生的信息：

In order to provide You with APP services and ensure the security of Your account and services, when You use the mobile phone services, Our Company will collect the information You enter on Your own or that arises from Your use of the services:

1. When You download and activate the APP services by Yourself, Our Company will collect Your name, mobile phone number and email address in accordance with laws, regulations and regulatory requirements, in order to help You complete the APP registration. If You refuse to provide such information, You may be unable to activate the APP services.

2. when You use the functions or services of the APP, e.g., under any of the following situations, You may need to provide us with or authorize us to collect user information required for the corresponding services. If You refuse to provide information required for some of the functions or services, You may be unable to use some of the functions or services, which, however, does not affect Your normal use of other functions or services of the APP.

(1) when You log in to the APP, Our Company will verify the validity of the login mobile phone number, login password or gesture password. In the event that You forget Your password and therefore need to reset it, we need to verify Your identity information, including Your mobile phone number, name, type and number of Your identity document, security tool (GA) information. Our Company also collects Your device information for the purposes of hardware binding and login security reinforcement, such asp fingerprint and face recognition. If You do not provide the above information or do not agree to authorize us to access such information, You will not be able to log in or retrieve Your password, which, however, will not affect Your normal use of functions or services available to You without login.

For some brands or models of mobile phone terminals, You can choose the fingerprint/face identification-based authentication based on the local biometric characteristics of the device, and in this case, the information is processed by the mobile phone terminals. Our Company does not keep the biometric information of Your mobile phone terminal. You can activate or de-activate fingerprint/face recognition under the section “My-Security Center and Settings” of the APP.

When You run and use the APP, Our Company will identify You and authenticate Your identity. Based on our security control unit’s verification of visitors in accordance with the  security policy, Your access to important terminals will be detected, Your geographic location information, electronic device information (including the model, operating system, unique device identifier, login IP address, mode, type and status of internet access, internet access quality data, etc., of Your device), and operation log information will be recorded; furthermore, and our services to You will be improved through data analysis.

 (2) when You use the real name authentication function, Our Company will collect Your identity card (passport), residential address and face image information if Your use of our services entails identity authentication. In the event that You fail to provide any of the above information, Our Company will not be able to provide You with products or services that can only be accessible after identity authentication or face-recognition-based authentication.

(3) when You use the OTC transaction function, Our Company will collect Your payment method information (bank card account number, WeChat, Alipay and/or other payment account number), identity information (name, mobile phone number, type and number of identity certificate), receipt, payment and transaction records. All the above information shall be sensitive personal information. Your refusal to provide such information will only make it impossible for You to use the above function, and will not affect Your normal use of other functions of the APP. Our Company will also collect Your transaction information to form a payee list to simplify Your transfer operation, and You may choose not to automatically save Your payees as frequent payees or remove payees from the payee list. In order to verify whether the account is usable, Our Company will also need to verify Your mobile phone number, email account, GA and other information. In addition, Our Company will collect Your mobile phone number, equipment information, account information, transaction information and asset information, so as to send You timely notices of changes in the fund in the account funds and related transactions. If You do not provide the above information, You will not be able to receive such notices in a timely manner.

(4) when You use the currency deposit and withdrawal function, Our Company will collect user’s currency withdrawal addresses and Your relevant deposit records, for Your future reference. You can also save the frequently used currency withdrawal addresses, so as to streamline Your deposit and withdrawal operations. In order to verify that each currency withdrawal is actually operated by you, Our Company also needs to verify Your mobile phone number, email address, GA information and other information. In addition, Our Company will collect Your mobile phone number, equipment information, account information, transaction information and asset information, in order to send You with timely notice of changes in the fund under Your account and related transactions. If You fail to provide the above information, You will not be able to timely receive such notices.

(5) when You use the currency-currency transaction function, Our Company will collect all Your digital asset information and financial flow to facilitate Your inquiry and transaction. Our Company will also collect Your entrustment order information to facilitate Your inquiry and in-depth presentation of market trends, and Our Company will also collect Your actual transaction information to form real-time transaction information, K-line information and in-depth information on market trends, after processing relevant data, so that You can access the market information on a real time basis. In addition, Our Company will also collect Your mobile phone number, equipment information, account information, transaction information and asset information, in order to send with You timely notices on changes in the fund under Your account and related transactions. If You fail to provide the above information, You will not be able to receive timely notices.

3. For the following functions, You can choose whether or not to authorize Our Company to use Your personal information or authority:

(1) Camera: used for recognizing QR codes, face recognition-based authentication, scanning.

(2) Photo album: used for identifying QR codes, face-recognition-based authentication, taking photos of currency withdrawal, identifying currency withdrawal address, online customer service, and sharing.

(3) Microphone: used for face recognition.

(4) Fingerprint/face hardware: used for login through fingerprint recognition and face recognition login.

(5) Geographic location: used for the functions of transaction risk control, data statistical analysis and online customer service.

(6) Network communication, which is used to communicate with the server.

(7) Storage rights: used for the selecting information on market trends, online customer service, login registration, log collection, cache.

(8) Siri: used for Siri activation function.

The above functions may make it necessary for You grant Our Company with access to turn on Your camera, telephone, SMS, notification and Siri in Your device, for the purposes of collecting and using the information involved in these functions. Please note that when You activate access to those functions, it shall be deemed that You authorize us to collect and use such information to enable the above-mentioned functions. If You cancel such authorization, Our Company shall cease to collect and use Your information, and in this case, Our Company will not be able to provide You with the functions corresponding to such authorization.

If we intend to collect or use Your information under any situation other than those listed above, we will seek Your prior consent and fully inform You of the purpose, manner and scope of such collection and use of Your information.

ii. How the information will be used

1. The information will be used for the purpose of providing You with our products or services as well as for improving such products or services.

2. During the time when Our Company provides services to you, You authorize us to collect and use Your information on an ongoing basis. When You cancel Your subscription for the services, Our Company will stop collecting Your personal information, provided that Our Company will continue using Your personal information, which has been collected by us by then, for the purpose of business data archiving, auditing, regulatory assistance, compliance with anti-money laundering regulation and sanctions.

3. For the purpose of enhancing Your product or service experience, or guarding against risks, Our Company will summarize, statistically analyze and process information relating to Your use of the services, provided that the information will not involve any identification information of Yours.

4. In order to keep You informed of the use of our products or services or to provide You with further information on our services, Our Company will send You with notices of service status and commercial information about related products or services.

5. Other purposes as are authorized by You and permitted by law.

iii. Exceptions to the Requirements for Authorization and Consent

In accordance with relevant laws and regulations, regulatory requirements and national standards, Our Company may collect and use Your relevant personal information under the following circumstances without Your authorization:

1. where state security and/or national defense security are involved;

2. where public security, public health and/or major public interests are directly involved;

3. Where criminal investigation, prosecution, trial and judgement enforcement are directly involved;

4. Where it is for the purpose of protecting Your or another person’s life, property and/or any other important legal rights and interests, yet it is difficult to obtain the consent of Yours, 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 the information is necessary by any agreement or any other written document that You require to be signed and performed;

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, 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.


II. How our companies uses Cookie and similar technologies

i. Cookies

To ensure the normal operation of the services hereunder, Our Company will store small data files called Cookie into Your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. Through cookies, websites can store data about Your preferences. We will not use cookies for any purpose other than those stated in this Policy. You can either manage or delete the cookies according to Your preferences. You can remove all cookies stored in Your computer. Most web browsers have the function of blocking cookies. However, if You activate this function, You will need to change Your user settings every time You visit our website.


III. How Our Company shares, transfers and discloses Your personal information

i. sharing and transfer

1. Except with Your express consent or authorization, Our Company will not share or transfer Your personal information to any other company, organization or individual.

2. Where it is necessary for us to share or transfer Your personal information externally for business purposes, Our Company will inform You of the purposes of such sharing or transfer of Your personal information, the type of data recipient, and obtain Your authorization and consent. In the event that any sensitive information is involved, Our Company will also inform You of the type of such sensitive information, the identity of the data recipient and data security capabilities, and obtain Your express authorization and consent.

3. Please understand that Our Company may share Your personal information externally in accordance with applicable laws and regulations, or in accordance with the mandatory requirements of the competent government authorities.

4. According to applicable laws and regulations as well as general business practices, if Your personal information transfer is involved in any merger, acquisition, asset transfer and any other similar transaction, Our Company will require that any new company or organization that comes into Your personal information through such merger, acquisition, transfer or transaction to continue being bound by this Privacy Policy. Otherwise, Our Company will require such company or organization to seek authorization from you.

5. To the extent required or permitted by law, it may be necessary for us to provide Your personal information to a third party, so as to protect the interests, property or safety of Our Company or any customer thereof or the public.

6. Your personal information may be shared among our operation organizations and subsidiaries. Our Company will only share Your personal information on an “as necessary” basis, and such sharing is subject to the stated purposes under this Policy. If the purposes for which Your personal information is processed hereunder are changed, we will seek Your authorization anew. The scope within which Your personal information is shared is subject to the specific business situation. For example, when Our Company submits statistical information to a competent financial regulatory authority as is required, Your personal identity information and account information may be shared among our operation units and subsidiaries.

7. In order to provide You with more sophisticated and high-quality products and services, some of our services will be provided by our partners. Our Company may share some of Your personal information with our partners, for the purpose of providing You with better customer services and user experience. Our Company will only share Your personal information for legal, legitimate, necessary, specific and clear purposes, and will only share Your personal information that is necessary for providing the services hereunder. Furthermore, Our Company will conclude a strict confidentiality agreement with our partners, requiring them to deal with Your personal information in strict accordance with our instructions, this Policy and any other relevant confidentiality and security measures. Our Company will ensure that our partners have no right to use Your personal information shared hereunder for any purpose other than those hereunder. If You reject our sharing with our partners of Your personal information collected by Our Company for the purposes of providing the services hereunder, You may be unable to access such services provided by Our Company.

ii. Public disclosure

1. We will not publicly disclose Your personal information. Where it is necessary for us to disclose Your personal information, Our Company will inform You of the purposes of such disclosure and the type of information to be disclosed; where any sensitive information is involved, we will also inform You of the content of such sensitive information and obtain Your express prior consent.

2. Please understand that Our Company may publicly disclose Your personal information under the mandatory requirements of any applicable law, legal proceedings, litigation or government authority.

iii. Exceptions to the requirements for authorization and consent

 

In accordance with relevant laws and regulations, regulatory requirements and national standards, Our Company may share, transfer and publicly disclose user information without Your prior authorization under the following circumstances:

1. where state security and/or national defense security are involved;

2. where public security, public health and/or major public interests are directly involved;

3. Where criminal investigation, prosecution, trial and judgement enforcement are directly involved;

4. Where it is for the purpose of protecting Your or another person’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.

 

IV. How Our Company stores and protects Your personal information

i. Storage

Our Company only retains Your personal information within the minimum period required by applicable laws and regulations, and within the minimum time limit necessary to achieve the purposes of this Policy; when the data retention period expires, Our Company will delete or anonymize Your information. For example:

Mobile phone number: when You need to use the APP services, Our Company needs to keep Your mobile phone number all the time to ensure that You use the service normally. When You cancel Your APP account, Our Company will delete the corresponding information;

ii Protection

1. Our Company has adopted security measures in line with industry standards to protect Your personal information from unauthorized access, public disclosure, use, modification, damage or loss. Our Company will adopt all reasonable and feasible measures to protect Your personal information. For example, Our Company will use encryption technology to ensure the confidentiality of Your data; Our Company will use trusted protection mechanisms to prevent malicious attacks on Your data; Our Company will deploy access control mechanisms to ensure that only authorized personnel can access Your personal information; and Our Company will provide security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

2. If operation of all or part of the APP businesses provided by Our Company terminates, we will, through public announcement or otherwise, inform You of our products or services affected by such termination, and stop the collection of Your personal information related to such products or services, so as to protect the security of Your personal information. If all or part of the APP business is interrupted due to any technical failure, cyber attacks, natural disaster or accident, human factor or any other reason, Our Company will take emergency response measures and restore the affected services as soon as possible.

3. Our Company will adopt all reasonable and feasible measures to ensure that irrelevant personal information will not be collected.

4. Please understand that due to the limitations of technical capabilities and potential malicious attacks, there may be unexpected situations that Our Company cannot reasonably foresee, prevent, avoid and control. Given the fact the Internet is not an absolutely secure environment, please use sophisticated passwords and security tools to help us ensure the security of Your account.

5. In the event of any personal information security incident, Our Company will inform You of the incident in a timely manner by email, post, telephone, push notifications, etc., or by issuing an announcement in a reasonable and effective manner in accordance with the requirements of laws and regulations. Furthermore, Our Company will also report to the competent authority on our handling of personal information security incidents in accordance with regulatory requirements.

 

V. How Our Company enables You to have the right to manage Your personal information

According to the relevant laws, regulations and regulatory requirements of the People's Republic of China, Our Company ensures that You can exercise the following rights in connection with Your personal information:

i. To access, correct and update Your personal information

You have the right to access, correct and update Your personal information through our APP, unless any of the applicable laws and regulations requires otherwise. It is Your responsibility to update Your personal information in a timely manner. We will verify Your identity before You may modify Your personal information.

1. You can change Your mobile phone number and email address through the section "My-My Personal Information" of the APP.

2. You can set Your login password, configure Your security tool and manage Your device binding through the "My-Security Center and Settings" function of the APP.

ii. Delete Your personal information

Under any of the following circumstances, You may apply to Our Company to delete Your personal information:

1. If Our Company's handling of personal information violates any of the applicable laws and regulations;

2. If Our Company collects and uses Your personal information without Your consent;

3. If Our Company's handling of personal information violates our agreement with you;

4. If You cancel Your account;

5. If Our Company ceases to provide You with products or services.

If Our Company decide to respond to Your application for deletion, Our Company will also notify the entities that have obtained Your personal information from us and require them to delete such personal information of Yours in a timely manner, unless any of the applicable laws and regulations requires otherwise, or unless these entities are independently authorized by you. When You delete Your information from our services, it is possible that Our Company cannot immediately delete the corresponding information from our backup system, but Our Company will delete it when the backup is updated.

iii. Change the scope of Your authorization

Each business function of the APP cannot be enabled unless some basic personal information is provided. For the collection and use of additional personal information, You may grant or revoke Your authorization at any time by activating or de-activating accesses to location service, contacts, telephone calls, etc., depending on the specific brand and model of Your mobile phone. You can do this by clicking on "Revoke the Consent Agreement" under the section of "My-Privacy Policy" of the APP.

 Please note that when You cancel Your subscription to our APP services independently, You will be regarded as having withdrawn Your consent to the Privacy Policy of our APP services. When You withdraw Your consent, Our Company will stop processing the corresponding personal information of Yours. However, Your decision to withdraw Your consent will not affect the processing of personal information that has been carried out by then based on Your authorization.

iv. Account cancellation by owner of personal information

If You are a registered user of our APP, You can choose to cancel the APP account You register.

Your cancellation of Your APP account is irreversible, and upon such cancellation, we will stop collecting Your personal information through the APP client and will delete all information about Your APP account, unless any of the applicable laws and regulations or regulatory authorities requires otherwise in connection with the storage term of personal information hereunder.

If You are not a registered APP user of Our Company, You can choose to uninstall or stop using the APP client, to prevent us from obtaining Your personal information.

Please note that when you, as a registered user of our APP, only delete the APP from Your mobile devices, Our Company will not cancel Your APP account, and all the information relating to Your APP account will not be deleted. You still need to cancel Your APP account to achieve the above-mentioned purposes.

v. Response to Your above requests

To ensure security, it may be necessary for You to provide a written request or otherwise prove Your identity. Our Company may require You to verify Your identity before processing Your request. Please understand that Our Company may reject certain requests that are repeated for no reason, that require an excessive amount of technological resources, pose risks to the legitimate rights and interests of others, or that are highly unrealistic. Notwithstanding the above provision, Our Company may, in accordance with the requirements of laws and regulations, be unable to respond to Your requests under any of the following circumstances:

1. where state security and/or national defense security are involved;

2. where public security, public health and/or major public interests are directly involved;

3. where criminal investigation, prosecution, trial and judgement enforcement are directly involved;

4. Where there is sufficient evidence proving subjective malice or abuse of power on Your part;

5. Where responding to Your request will result in any serious damage to the legitimate rights and interests of Yours or any other individual or organization;

6. Where any trade secret of Our Company is involved;

7. Where it is necessary for compliance with anti-money laundering requirements and sanctions.

 

VI. How Our Company deals with information of minors

 

Minors are not allowed to create their own user accounts without the consent of their guardians. If You are a minor, Your guardian should read this Privacy Policy es hereunder carefully and do not access our services or provide us with information until and unless You have obtained the consent of Your guardian. Our Company will use and provide the information to the public only when it is permitted by the applicable laws, regulations and regulatory requirements or as is necessary for protecting minors.

 

VII. Application and updating of this Policy

1. Our Company reserves the right to update or modify this Policy from time to time. Without Your express consent, Our Company will not reduce Your rights under this Policy. Our Company will notify You by reasonable means, such as push notifications, pop-up windows, official website announcements, etc., so that You can keep Yourself updated on any and all changes made to this Policy (including changes in business functions, changes in the purposes of use, changes in the contact information of the person in charge of personal information protection, etc.).

2. For any major change, depending on the specific circumstances, Our Company may also provide a more significant notice explaining the details of such change to this Policy.

Major changes include, but are not limited to:

(1) Significant changes in our service mode and business model, e.g., changes in the purpose of processing personal information, the types of personal information processed, the ways in which personal information is used, inter alia.

(2) any change in the major person(s) which personal information hereunder is shared with, transferred to or publicly disclosed to;

(3) Any significant change in Your right to participate in personal information processing and the way You exercise such right;

(4) Changes in the contact information of Our Company in charge of personal information security, or changes in the ways in which complaints hereunder are lodged; and

(5) The security impact assessment report for personal information shows that there is a high degree of risks.

3. If You do not agree with the revised privacy policy, You have the right to and should immediately stop using our products/services. If You choose to agree to the revised privacy policy and continue to use our products/services, You will be deemed to have accepted our changes to the relevant provisions of this Policy.

 

XIII How to contact Our Company

If You have any question, comment or suggestion about this Privacy Policy, You can send an email to [email protected], the official customer service email address of Huobi Pool ECO Exchange. After receiving Your question, etc., Our Company will deal with it timely and properly. Under normal circumstances, Our Company will give You a reply within fifteen (15) days. If You think that our personal information processing has damaged Your legitimate rights and interests, You can also report to the relevant government authorities or trade associations.

The full name of Our Company is: HPT FOUNDATION LTD, registered address: 6 MARINA BOULEVARD # 06 Mur17 THE SAIL @ MARINA BAY Singapore 018985.

Please read this Privacy Policy carefully before clicking on the button of "I Agree" to ensure that You fully understand the content, especially the meaning of the parts in bold type of this Policy, and the corresponding legal consequences. If You click on the "I Agree" button and thereby confirm to submit, You will be deemed to have accepted this Privacy Policy. Our Company will legally use and protect Your personal information in accordance with relevant laws and regulations as well as this Policy.