This platform is managed and operated by VIEWFUTURE FOUNDATION LTD. It is a special platform for users to carry on digital assets trading and provide them related services (hereinafter referred to as "the service" or "service"). For the convenience of expression, this platform is collectively referred to as "we" or other first person address in this agreement. As long as the natural person or other subject login the platform, they are the users of this platform, hereinafter referred to as "you" or other second person address. This platform and you are collectively referred to as "both parties", we or you are individually referred to as "one party".
Before using our products or services, please read this policy carefully and understand it thoroughly, especially the clauses marked in bold. You should read it carefully and use the products and services after confirming that you fully understand and agree. If you have any questions, comments or suggestions on the content of this policy, you can contact us through various official contact lists. If you do not agree to any of the terms of this policy, you should immediately stop accessing this platform.
Part I: Definition
Personal information: Refers to all kinds of information recorded by electronic or other means that can the identity of a specific natural person or various information reflecting the activities of a specific natural person.
Personal information deletion: Refers to the behavior of removing personal information in the system involved in the realization of daily business functions, keeping them away of being retrieved and accessed.
Juveniles: Juveniles under the age of 18.
- How do we collect and use your information
- How do we share, transfer and publicly disclose your information
III. How do we protect your information
- How do you manage your information
- How do we deal with juveniles’ information
VII. How to contact us
- How do we collect and use your information
When using our products and / or services, we need / may need to collect and use your personal information as follows:
- In order to provide you with the basic functions of our products and / or services, you must authorize us to collect and use the necessary information. If you refuse to provide them, you will not be able to use our products and / or services normally;
- In order to provide you with additional functions of our products and / or services, you can choose the information that authorize us to collect and use. If you refuse to provide it, you will not be able to use the relevant additional functions or gain the functional effect we intend to achieve, but it will not affect your normal use of the basic functions of our products and / or services.
You understand and agree that:
- We are committed to creating a variety of products and services to meet your needs. As we provide you with a wide range of products and services, and there are differences in the specific product / service scope selected by different users, the basic / additional functions, the type and scope of personal information will be differently collected and used. Please refer to the specific product / service function;
- In order to bring you a better experience, we are making continuous efforts to improve our technology, and then we may launch new or optimized functions from time to time, which means that we may need to collect and use new personal information or change the purpose or way of using personal information. In this regard, we will separately explain to you the purpose, scope and ways of use of the corresponding information by updating this policy, pop-up windows, page prompts, etc. We also provide you the way of independent choice and consent, collecting and using the information after obtaining your express consent.In this process, if you have any questions, opinions or suggestions, you can contact us through various contact information provided by this platform, and we will answer them for you as soon as possible.
We will collect and use your personal information to realize the following functions of this policy:
(I) To help you register and provide you with the services of this platform;
- Registration services
We provide you with basic membership services through the account. You need to fill in the following information when applying for registration in order to let you register as a member and use our membership services:
(1) Identity information. This information can help us verify whether you are qualified to register as a member of this platform, which including but not limited to your name, your residential address, other different certificates issued by your country or government to prove your identity information, the ID number involved and all other information that can help us verify your identity (hereinafter collectively referred to as "identity information"). The identity information varies depending on whether you are an individual user or an institutional user. According to the laws and regulations of different jurisdictions, the information we collect for users from different countries or regions may be different. The following information and data are used as an indicative example:
Individual users: Nationality, full name (including the name used before and name in local language), ID number, e-mail address, telephone number, social security number ("SSN"), passport number or any government issued ID number, date of birth, identity certificate (e.g. passport, driving license or government identity certificate).
Institutional users: Legal name of the company (including legal name in local language), registration information, business telephone number, personal information of authorized representative, main place of business, personal information of all beneficial owners, identification documents of shareholders / beneficial owners (passport or ID card issued by the government), company structure, documents related to the establishment of the company, resolutions of the board of directors, declaration of sources of funds, risk and compliance control instructions and other information or documents required by the platform.
(2) Service information. This information helps us to contact you and smoothly provide you with different modes of digital asset transaction services, including but 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"). At the same time, please understand that our services are constantly updated and developed. If you choose to use other services not covered in the above description, and we need to collect your additional information based on this service, we will explain the scope and purpose of information collection to you through page prompt, interaction process, agreement, pop-up prompt, and obtain your consent.
If you only need to use the browsing service, you do not need to register and provide the above information.
- Other registration services
Real name authentication: when you finish the steps of registration, you need to enter "About Me" to complete the certification in identity authentication. You need to provide your nationality, real name, ID number or passport number to the platform in the process of using real name authentication.
Advanced authentication: when your trading volume in this platform exceeds a certain limit, the platform will require advanced authentication for you in order to maintain the security of your assets. In addition to the real name authentication information, you can approve the advanced authentication of "face recognition" by the platform. Face recognition will involve the collection of your related video stream or face image by the platform.
Account information display: if you already have an account on this platform, we may display your above personal information in the service (certification only shows the result of whether the authentication is passed or not), as well as the operations you perform in the products and services associated with the platform account, including the centralized display of your personal data and transaction orders through this platform account. We will respect your choice of platform account settings.
(II) Security management service and service information providing
When you use the services provided by this platform or visit this platform, in order to ensure the security of your transaction and the stable operation of the service, we need to automatically receive and record: your web browser information, the device type, model version and other device identification symbols and other device information used by your login account, the IP address and record on the web page you requested to visit, the region and network environment, device fingerprint information, service log information, software information, location information, etc.
Please note that individual device information is a kind of information that cannot identify a specific natural person. If we combine this kind of information with other information to identify a specific natural person, or combine it with personal information, this kind of information will be regarded as personal information during the period of combination. Except for obtaining your authorization or other provisions of laws and regulations, we will anonymize and de identify this kind of information.
In order to provide you with more convenient and personalized information display and push service, we may extract your preference features according to your device information and your browsing information of the platform or client in the future. We may also produce indirect crowd portraits based on feature tags for display, push information and possible commercial advertisements. If you do not agree to receive such push information or withdraw your consent to collect personal information, you can contact us according to the contact information provided in this policy.
We try to ensure your browsing experience. If you don't want to receive the commercial advertisement that we send you, you can unsubscribe by reply to SMS, or close the function by other ways we provide.
In addition, we will use your above information in order to continuously improve and optimize the above functions.
(III) Transaction record keeping and inquiry service
We collect relevant data about your exchanges on this platform, including but not limited to trading records. If you want to inquiry your order transaction records, you can get your personal transaction details in the "orders" of the platform. The details including: order time, order number, transaction information, type and quantity of digital assets, etc.
(IV) Customer service and dispute settlement
When you contact us or apply for after-sale and dispute settlement, in order to protect the security of your account and our system, we need you to provide the necessary personal information to verify your membership.
In order to contact you and help you solve the problem as soon as possible, or record the solution and results of relevant problems, we may save the communication records and relevant contents (including account information, order information, other information provided by you to prove relevant facts, or contact information left by you) between you and us. We will use your account information and order information.
In order to provide services and improve the quality of service, we may also use your other information, including the relevant information you provided when you contacted customer service staff, and the questionnaire reply information you sent to us when you participated in the survey.
- If the information you provide contains the personal information of other users, you need to ensure that you have obtained legal authorization of them before providing the personal information to this platform. If it involves personal information of juveniles, you need to obtain the consent of the corresponding guardian of juveniles before publishing it. Under the above circumstances, the guardian has the right to contact us to request correction or deletion of the content involving personal information of juveniles.
- If we use the information for other purposes not specified in this policy, or use the information collected for a specific purpose for other purposes, or we take the initiative to obtain your personal information from a third party, we will obtain your prior consent all the time.
If we obtain your information indirectly from a third party, we will explicitly require the third party in writing to obtain your consent in accordance with the law before collecting your personal information, and inform you of the content of the shared information. If sensitive information is involved, your explicit confirmation is required before it is provided to us, and the third party is required to verify the legality and compliance of the source of personal information We promise that if the third party violates the law, we will explicitly require the other party to bear the corresponding legal responsibility. At the same time, we will strengthen the security of personal information (including sensitive information reporting, sensitive information encrypted storage, access control, etc.). We will use the protection means and measures for our own users' personal information to protect the personal information indirectly obtained no less than the way we use.
- Exceptions to authorization
You fully understand and agree that your authorized consent is not required for us to collect and use your personal information under the following circumstances, and we may not respond to your request for correction / modification, deletion, cancellation, withdrawal of consent or information request:
(1) Related to national security and national defense security;
(2) Related to public safety, public health and major public interests;
(3) Related to judicial or administrative law enforcement, such as criminal investigation, prosecution, trial and judgment execution;
(4) In order to protect your or other person’s life, property and other major legitimate rights and interests, but it is difficult to get his or her consent;
(5) Personal information that you disclose to the public on your own;
(6) Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.
(7) According to the requirements of signing and performing relevant agreements or other written documents with you;
(8) It is necessary to maintain the safe and stable operation of the products and / or services provided, such as finding and handling the faults of products and / or services;
(9) It is necessary for legal news report;
(10) It is necessary for academic research institutions to carry out statistical or academic research based on the public interest. When they provide the results of academic research or description to the public, they de label the personal information contained in the results;
(11) Other circumstances stipulated by laws and regulations.
Please note that according to applicable laws, the use of following processed data does not need to inform you and obtain your consent if we take technical measures and other necessary measures to process personal information, so that the data receiver can’t reidentify specific individuals and can’t recover, or we may conduct de identification research, statistical analysis and prediction on the collected information, so as to improve the content and layout of this platform and provide products or services for business decision-making Support, improve our products and services (including the use of anonymous data for machine learning or model algorithm training).
- If we stop operating the products or services of this platform, we will stop the activities of continuing to collect your personal information in a timely manner, notify you of the notice of the stop operation in the form of one by one or announcement, and delete or anonymize the personal information held by us related to the closed business.
- I How can we share, transfer and publicly disclose your information
We will not share your personal information with any other companies, organizations or individuals except for the following circumstances:
- Under legal circumstances: we may share your personal information according to laws and regulations, litigation, dispute resolution needs, or according to the requirements of administrative and judicial organs.
- Sharing with explicit consent: After gaining your explicit consent, we will share your personal information with other parties.
- Your initiative choose: We will share the necessary information related to the transaction in your order information to the counterparties of digital assets according to your choice, achieving your needs of transaction and after-sales service.
- Share with authorized partners: Our related parties, trusted third parties who help us operate our platform, conduct business, or provide services to you, as long as these parties agree to keep the information confidential. When we believe that the information disclosed is appropriate and comply with laws, regulations, rules and regulations, or come from the order and execution of the court or other competent that authorities our strategy. But the related parties must to provide services or protect the rights, property or security of us or others.
We will not transfer your personal information to any company, organization or individual except for the following circumstances:
- Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
- In case of merger, acquisition or bankruptcy liquidation of this platform, or other situations involving merger, acquisition or bankruptcy liquidation, we will require the new company or organization holding your personal information to continue to be bound by this policy if the transfer of personal information is involved. Otherwise, we will require the company, organization or individual to seek your authorization again.
(III) Public disclosure
We will only disclose your personal information in the following circumstances:
- We may publicly disclose your personal information with your explicit consent or based on your initiative choice;
- If we determine that you have violated laws and regulations or seriously violated the relevant agreements and rules of this platform, or in order to protect the personal and property safety of users or the public of this platform from infringement, we may disclose personal information about you in accordance with laws and regulations or with your consent, including relevant violations and the measures taken by this platform against you.
(IV) Exception of obtaining prior authorization for sharing, transferring and public disclosure of personal information
Under the following circumstances, no prior authorization is required for sharing, transferring or disclosing your personal information:
- Related to national security and national defense security;
- Related to public safety, public health and major public interests;
- Related to judicial or administrative law enforcement, such as criminal investigation, prosecution, trial and judgment execution;
- In order to protect your or other personal life, property and other major legitimate rights and interests, but it is difficult to get his or her consent;
- Personal information that you disclose to the public on your own;
- Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.
Please note that according to the applicable laws, if we take technical measures and other necessary measures to process the personal information, so that the data receiver can’t re identify a specific individual and can’t recover, the sharing, transfer and public disclosure of such processed data do not need to notify you and obtain your consent.
III. How do we protect your information
- We implement proper measures of physical, electronic, management and technical to protect your personal data. We try our best to ensure that any personal data collected through our platform is free from any nuisance from any third party unrelated to us. Our safety measures include but are not limited to:
(1) Physical measures: Records with your personal data will be stored in a locked place.
(2) Electronic measures: Computer data containing your personal data will be stored in computer systems and storage media subject to strict login restrictions.
(3) Management measures: We have set up relevant departments for the security protection of user information, and established relevant internal control system. We take strict authorization principle for the staff who may come into contact with your information. Only our authorized staff can come into contact with your personal data, and these staff need to abide by our internal code of personal data confidentiality. In addition, we continue to strengthen the publicity of relevant laws and regulations, privacy and security standards and security awareness for staff training. What’s more, we also regularly organize relevant internal personnel to carry out emergency response training and emergency drills, so that they can master the post responsibilities and emergency response strategies and procedures.
(4) Technical measures: Encryption technology such as Secure Socket Layer Encryption may be used to transport your personal data.
(5) Security measures: In order to protect your information security, we are committed to using a variety of current common security technologies and supporting management systems to minimize the risk of your information being leaked, damaged, misused, unauthorized access, unauthorized disclosure and change. For example: through the network security layer software (SSL) encryption transmission, information encryption storage, and strict restrictions on data center access. When transmitting and storing personal sensitive information (including personal biometric information), we will adopt encryption, authority control, de identification, desensitization and other security measures.
(6) Other measures: We will regularly review our personal data collection, storage and processing processes, and restrict the access rights of our employees and suppliers to your data according to the necessary principles. Our employees and suppliers are required to abide by strict contractual confidentiality obligations.
- If you are aware of any security vulnerabilities on our platform, please contact us immediately so that we can take appropriate action as soon as possible.
- Despite the implementation of the above technical and security measures, we can’t guarantee the absolute security of data transmission on the Internet, and we can’t absolutely guarantee that the personal data you provide to us through our platform is safe all the time. We will update and disclose the security risk, personal information security impact assessment report and other relevant contents from time to time, which can be obtained through the announcement of this platform.
- I How do you manage your information
You can access and manage your information in the following ways:
(I) Inquiry, correct and delete your information
You have the right to obtain a copy of your personal data upon request and to determine whether the information we have about you is accurate and up-to-date. If any of your personal data is inaccurate, you can ask us to update your information. You can also ask for the deletion of your personal data, but we may refuse your deletion request under certain circumstances, such as for legal requirements or other legal purposes. For data access, correction or deletion requests, you can contact us through the contact information.
In response to the requests of data access, correction or deletion, we will verify the identity of the requesting party to ensure that he / she is legally entitled to make such requests. Although our goal is to respond to these requests free of charge, we reserve the right to charge you a reasonable fee if your request is repeated or difficult.
(II) Change the scope of 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 previous personal information processing based on your authorization.
(III) Respond to your request mentioned above
To ensure security, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.
We will respond within 15 days. If you are not satisfied, you can also file a complaint through the contact information provided by us.
We do not charge for your reasonable request in principle, but we will charge certain fees for repeated requests that exceed the reasonable limit. We may refuse requests for information not directly related to your identity, unprovoked repetitive information, or the need for too many technical means (for example, the need to develop new systems or fundamentally change existing practices), risks or impractical requirements for the legitimate rights and interests of others.
We may not be able to respond to your request in the following cases, as required by laws and regulations:
- Related to national security and national defense security;
- Related to public safety, public health and major public interests;
- Related to criminal investigation, prosecution, trial and execution of judgments, etc;
- There is sufficient evidence to show that the subject of personal information has subjective malice or abuse of rights;
- Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;
- Involving trade secrets.
- How do we deal with juveniles’ information
This platform is open to juveniles. If we find or suspect that a 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. If you know that anyone under the age of 14 uses our services, please let us know so that we can take action to prevent them from accessing our products or services and delete the information as soon as possible.
For juveniles who are between 14 years and 18 years old, we expect their parents or guardians to guide them to use our services. We will protect the confidentiality and security of minors' information in accordance with relevant laws and regulations.
If you are a juvenile, we recommend your parents or guardians to read this policy and make sure you use our services or provide us with your information with the consent of your parents or guardians. In the case of collecting your information with the consent of your parents or guardians, we will only use or publicly disclose this information when permitted by law, with the express consent of your parents or guardians, or when it is necessary to protect your rights and interests. If your guardian does not agree to let you to use our services or provide us with information in accordance with this policy, please terminate your use immediately and inform us in time so that we can take corresponding measures.
If you are the parent or guardian of a minor, if you have any questions about the information processing of the minor under your guardianship, please contact us through the contact information published in this policy.
For major changes, we will also provide more significant notices (including inform you through the way of publicity on this platform and even provide you with pop-up prompt).
Major changes referred to in this policy include but not limited to:
- Our service model has changed dramatically. For example, the purpose of processing personal information, the type of personal information processed, the use of personal information, etc;
- We have made significant changes in control, etc. Such as the merger and reorganization of information controller changes;
- The main objects of personal information sharing, transfer or public disclosure change;
- The way you exercise your right to participate in personal information processing have changed significantly;
- The change of the responsible department that handling personal information security, contact information and complaint channel of personal information security;
- The personal information security impact assessment report indicates that there is a high risk.
VII. How to contact us
- If you have any requests and comments, you can send them by email firstname.lastname@example.org. This is the only valid and official email we communicate with you, so we are not responsible for your failure to use a valid contact information, any act or omission.
- We only publish announcements and information through the effective contact information on this platform or post announcements on this platform, so we are not responsible for any loss caused by your trust in the information not obtained through the above methods.