The Agreement shall be released and come into effect on October 25, 2018.
We collect user’s specific and necessary personal information (hereinafter referred to as “necessary information”), for the specific requirements applicable to legal provisions and the specific needs of the service. For non-essential information, you have the right to decide whether or not to provide it. However, the absence of non-essential information may result in your inability to use specific permissions or services on the platform.
1. What personal information do we collect
- 1.1. Information required for registrationWhen you register for a platform account, you may need to provide personal information requested by the platform, including but not limited to: name, email address, mobile number, username, ID and information related to your bank account (including bank, account type, account number) and so on. In order to increase account security, you can apply for SMS or email for secondary verification. To enable SMS verification, you need to provide a mobile number.
- 1.2. Information required to verify user identityTo comply with applicable legal requirements including global anti-money laundering, knowing your user, and counter-terrorism financing, and global industry regulatory standards, we are required to collect and verify your identification documents. Information collected during authentication includes, but is not limited to: name, email address, mobile number, username, ID information, ID photo, your personal photo, and information related to your bank account (including bank, account type, account number) and so on. When providing information, you should ensure the authenticity, accuracy and completeness of the information. After registration, please update your personal information in real time to ensure its authenticity and effectiveness. We have reasonable grounds to suspect that the information you provided is incorrect, untrue, outdated or incomplete, we reserve the right to notify you to correct or directly delete the information and terminate some or all of your activities on the platform as appropriate. If we are unable to locate you through the contact information you provided, you are solely responsible for any loss or expense incurred during the use of the service. This rule applies to both personal and business accounts.
- 1.3. Information required to use the serviceDuring your use of the platform, we monitor and collect information about your access to and use of the platform, including but not limited to: access date and time, device identification, operating system, browser, and IP address. This information may be obtained directly from the platform or a third party service provider. The collection of these service usage data helps the system ensure that the platform interface is available to platform users, as well as support for government investigations or judicial review. In addition, we may use “Cookies” to enhance your user experience. Cookies are small text files placed on your computer by websites you visit, and they are widely used to make the platform run more efficiently. These files may record anonymous information about your preferences and how you navigate the platform and pass it on to us. When you visit the platform, your web browser stores cookies on your computer's hard drive to keep records and sometimes track information about them. All such information is stored in encrypted form and does not store personal information about you. Your use of the platform will be interpreted as your consent to store cookies on your device.
- 1.3.2. Transaction InformationFor all corporate and personal accounts, the transaction information we collect includes, but is not limited to: deposit snapshots, account balance, transaction records, withdrawal, order activity, and distribution records. The collection of this data is used to monitor suspicious transaction behavior to prevent user violations and to assist in government investigations or judicial review. For the avoidance of doubt, we may obtain your personal information from other third parties, such as public data, credit centers, identity agencies, distributions and channel agencies, as required by applicable law or the need to provide this service.
2. How we use personal information
- 2.1. Providing and maintaining this serviceWe will use the IP address and unique identifier stored in your cookies to verify your identity and provide this service. Due to applicable legal requirements and system requirements, we are unable to provide you with this service without your personal information such as identification, contact information and transaction related information.
- 2.2. Protecting platform and platform account securityWe will use your personal information to protect the security of the platform, platform accounts and files. We will use your IP address and Cookies data to prevent spam, phishing and distributed denial of service (DDoS) attacks. In addition, we will use your personal information to analyze trading activities in order to detect money laundering, fraud, etc. and funds flowing to suspicious accounts as early as possible.
- 2.3. Compliance requirements of applicable lawApplicable law requires us to collect personal information, including but not limited to the provisions of Section 1 of this Policy, from our users when providing certain core services. For example, to comply with applicable legal requirements including anti-money laundering, user understanding, and counter-terrorism financing, and global industry regulatory standards, we will verify your identity and may hire a third party to verify the authenticity of your personal information by comparing your personal information with other third party data or public data. In addition, when you buy or sell digital currency, we will provide additional personal information as required by applicable law. If you refuse to provide such personal information, we will freeze or close your account due to the inability to provide legally compliant services. For residents of the European Economic Area (including the UK, Switzerland) (hereinafter referred to as “EEA Residents”), in the course of providing this service and collecting, using, sharing, transferring, protecting and preserving your personal information, It will comply with the relevant regulations of the European Union's General Data Protection Regulation. If you are an EEA resident, you need to expressly agree to transfer your personal information from the EEA to the outside of the region (for the avoidance of doubt, by clicking/checking the “Agree” button or other button with similar meaning during the registration process, which means you agree to the transfer); If you refuse to agree or expressly revoke the consent to us, we will stop providing you with the Service.
- 2.4. Assessing or improving website performance and service qualityWe analyze the website data to better understand the user's product and service experience. Our operations team will use the personal information you provide to continuously analyze your data to ensure that your user experience is optimized, to send you specific information (including advertising, promotional information) or to personalize your services based on your preferences. In addition, your personal information will be used to address various issues you may encounter while using the Platform and enjoying the Service.
- 2.5. User communicationIn order to communicate effectively with you, we may use your personal information. We will promptly inform you about account logins, transactions and account security, and answer your requests and questions. All communication with you will be stored in the platform system for review accuracy.
- 2.6. Implementation of service agreements and other agreementsThe information we process (such as your identity and financial information) is very sensitive, so it is important for us to monitor, investigate, prevent or mitigate any illegal activities and strictly enforce our agreements with third parties. To do so, we collect and use information about your use of the Platform and monitor your actions in the use of the Service. If you refuse to provide us with personal information for this purpose, we will stop providing you with this service.
- 2.7. Acquisition, merger or other transactionWe may provide or transfer your personal information to interested parties for the purpose of selling business, acquisitions, mergers or other transactions. If you do not agree to disclose your personal information for this purpose, you have the right to cancel your account at any time.
3. How do we share personal information
- We may disclose your personal information to third parties, as well as to the judiciary or government agencies, or transfer your personal information.
- 3.1. Sharing with third parties or transferring to third parties3.1.1. We will share your personal information with our affiliates, employees, contractors or other third parties in the following specific circumstances (1) We may share your personal information with our group companies or affiliates so that we can provide you with better service; (2) We may also share your personal information with certain contractors or service providers (including but not limited to marketing agencies (such as advertising agencies), IT specialists, database providers, backup and system recovery specialists, email providers, or outsourced call centers). They will process your information or data for us and will be required to meet our standards for handling and protecting information in the process; (3) We may also share your personal information with other third parties. We will provide them with your consent or when they need to obtain your information for the products or services you provide.
- 3.1.2. We will transfer your personal information to other third parties in the following specific circumstances(1) When we are prepared to sell or transfer part or all of our business, your personal information may be transferred to our specific potential buyer, provided that such personal information is protected by appropriate protection of confidentiality clauses; (2) When we reorganize or be acquired, your personal information will be transferred to a specific buyer so that the buyer can continue to provide services to you; (3) When we comply with applicable laws, any regulatory standards or practices, or when we are required by any public or regulatory agency to transfer your personal information; (4) When we enter the judicial process or need to defend.
- For the avoidance of doubt, if your data or information is shared anonymously, our sharing of personal information will not be restricted by the specific circumstances aforementioned, as such data or information will no longer belong to personal information.
- 3.2. Disclosure to public institutions
- We will disclose your personal information to the judicial and government departments in the following situations(1) Enforced by a court order or other legal process; (2) In order to report possible illegal activities; (3) In order to investigate possible violations of this policy or our terms of Service.
4. How do we protect personal information
- We have implemented a number of security measures to ensure that your personal information is not disclosed, stolen, misused or tampered with. Our data security measures include, but are not limited to: strict security management systems, comprehensive security technologies, such as PCI scanning, Secure Sockets Layer (SSL) encryption, anonymization, internal data access control, sensitive data encryption storage, and physics security protection, etc. In the event of a personal information leak or other security incident, we will immediately initiate an emergency response, and inform you of the situation by shutting down the data channel, pushing notifications, issuing announcements, etc., recovering the losses and repairing the corresponding defects as much as possible.
- However, please understand that due to technical limitations and possible malicious acts of various third parties, the form of Internet electronic storage does not guarantee 100% security of information. Therefore, we recommend that you take good care of the information on your terminal and prevent your platform account and associated banks from leaking for personal reasons, understand and take independent security precautions to protect the security of your personal information. If you suspect that your personal information, especially the platform account or password information, has been leaked, please immediately freeze your account and contact our customer service staff.
5. Preservation of personal information
- In order to comply with global industry data retention standards, we will retain your personal information for the duration of your account and for 5 years after the account is closed, unless the applicable law has other special provisions for the retention period.
6. Contact Us
- We respect the privacy of all users. If you have any questions or concerns about this policy, or if you would like to submit a data protection request, please refer to our FAQ https://www.exshell.com and contact us via our contact information posted on the platform.