《TokenPocket Privacy Policy》
83 |Last Updated: May 29, 2021.
84 | 85 |
86 | Dear Users,
87 | TokenPocket Foundation Ltd. (“TPF” or “we”) respects and protects the privacy of Users (“you” or “Users”).
88 | TPF will collect and use your Personal Information, generated from your use of TokenPocket in accordance
89 | with this Privacy Policy (“Policy”).
90 | TPF recommends that you shall carefully read and understand the whole contents of this Policy before your
91 | use of the product (“TokenPocket”). Additionally, significant information including the Disclaimer is in
92 | bold form in this Policy. Definitions of key words in this Policy are consistent with those in the
93 | TokenPocket Terms of Service of TPF.
94 |
95 | TPF reserves the right to update this Policy online from time to time, and the new policy will immediately
96 | replace the older one once posted. In particular, if you do not accept the revised policies, please
97 | immediately stop your use of TokenPocket. Your continuous use of TokenPocket will be regarded as your
98 | acceptance of the revised policy. Furthermore, the revised policies will take into effect immediately upon
99 | being posted on TokenPocket.
100 | You acknowledge and accept that this Policy and other relevant rules apply to TokenPocket and the DApps
101 | owned by TPF on TokenPocket.
102 |
103 |
Information We Collect
105 |
106 | We collect your information in order to provide the services you requested on TokenPocket, and we highly
107 | value the protection for your privacy. We strictly abide by the principle of “lawful, justifiable and
108 | necessary” during our collection of your information. You acknowledge that, if you do not provide us with
109 | necessary information, your user experiences on TokenPocket may be influenced.
110 | We may collect your Personal Information, including but not limited to your mobile device information,
111 | operation records, transaction records and wallet addresses.
112 | 1.1 In order to satisfy your needs for specific services, we may collect your name, bank card
113 | number,
114 | telephone number (Mobile phone number registration method), email address (Email registration method),
115 | etc.
116 | 1.2 You confirm that your Wallet Password, Private Key, Mnemonic Words, Keystore on
117 | TokenPocket (the
118 | decentralized solution) are not stored or synchronized on TPF’ servers. TPF does not offer the service to
119 | restore your Wallet Password, Private Key, Mnemonic Words or Keystore.
120 | 1.3 Apart from the foregoing provisions, when you are using specific function of TokenPocket,
121 | we may give
122 | you special notification to ask for more Personal Information.
123 | 1.4 After you link to the third-party-developed DApps from TokenPocket, your Personal
124 | Information will be
125 | collected and held by the third-party-developed DApps instead of being collected or held by TokenPocket.
126 | When you fill in your Personal Information on a third-party-developed DApp, you should pay attention to
127 | the Terms of Use and Privacy Policy of the third-party-developed DApp. We are not accountable for any
128 | losses caused by your operation on the third-party-developed DApp.
129 | 1.5 To the extent permitted by laws and regulations, TPF may collect and use following
130 | Personal
131 | Information without your prior consent or authorization:
132 | a. information related to national security and national defense;
133 | b. information related to public security, public health, significant public
134 | interests;
135 | c. information related to criminal investigation, prosecution, trial and
136 | enforcement;
137 | d. the Personal Information collected is publicized by yourself;
138 | e. the Personal Information is collected from legally publicly disclosed
139 | information, such as legal news
140 | reports, government information disclosure and other channels;
141 | f. the Personal Information is necessary to maintain the security and
142 | compliance
143 | of services, such as to
144 | detect or to solve the malfunction of products and services;
145 | g. other circumstances prescribed by laws and regulations. We collect
146 | information in the following
147 | ways:
148 | 1). Information you give us. For example, you fill in your name,
149 | telephone number, or bank card number in
150 | “My Account” column or you provide your email address when submitting feedbacks, or you give extra
151 | information to us when you use our specific services.
152 | 2). we collect information during your use of TokenPocket,
153 | including your mobile devices information and
154 | your operation records on TokenPocket, etc.
155 |
156 |
How We Use Your Information
158 |
159 | 2.1 We may associate you with your wallet by the unique serial number of your mobile
160 | device.
161 | 2.2 We may promptly push important notifications to you, such as software update, update of
162 | Terms of
163 | Service and this Policy.
164 | 2.3 We offer you the “Touch ID” option in the “Settings” column of TokenPocket to provide you
165 | with a
166 | convenient and safe way to manage your digital Tokens.
167 | 2.4 We deal with your feedbacks by using the Wallet Address and the mobile device information
168 | provided by
169 | you.
170 | 2.5 We may collect your Personal Information to conduct our internal audit, data analysis and
171 | research
172 | etc. to enhance our services.
173 | 2.6 According to TokenPocket Terms of Service and other rules of TPF, TPF will manage and
174 | handle the use
175 | behaviors of Users through Users’ information.
176 | 2.7 We may use your information in accordance with laws, regulations and to cooperate with
177 | regulatory
178 | authorities.
179 |
180 |
How You Control Your Own Information
182 |
183 | You are entitled to control your Personal Information provided to TokenPocket:
184 | 3.1 You may import your other wallets into TokenPocket through synchronization of wallets and
185 | you may
186 | export your wallets from TokenPocket to other Tokens management wallets.
187 | 3.2 TokenPocket will display the information of imported wallets to you. You may add or
188 | delete Tokens,
189 | transfer and collect Tokens using the “Assets” column.
190 | 3.3 You understand that you may handle the following operations in the “Me” column on
191 | TokenPocket:
192 | a. in the “Address Book” column, you may view and edit your “Contacts”;
193 | b. in the “Settings” column, you may choose not to open “Unlock Setting”, which
194 | means you may refuse to
195 | use the verification service to enter TokenPocket;
196 | c. in the “Profile” column, you do not have to provide your name, telephone
197 | number, bank card number
198 | information. But if you wish to use specific services, you may need to provide the foregoing
199 | information;
200 | d. in the “Help” column, you may submit any questions or suggestions for
201 | TokenPocket at any time. We are
202 | glad to communicate with you to improve our services.
203 | 3.4 When we collect information from you for a specific purpose, we will ask for your consent
204 | in advance
205 | to which you are entitled to refuse. However, you understand that when you refuse to give such consent,
206 | you also give up the choice to use specific services provided by TokenPocket.
207 | 3.5 You acknowledge that since blockchain is an open source system, your transaction records
208 | are
209 | automatically public and transparent in the whole blockchain.
210 | 3.6 You understand that after you link to the third-party-developed DApps from
211 | TokenPocket,
212 | the
213 | TokenPocket Terms of Service and TokenPocket Privacy Policy will no longer apply. You are encouraged to
214 | carefully review its privacy policies and related terms of service before you start to use the
215 | third-party-developed DApps.
216 | 3.7 You are entitled to ask us to update, revise, and delete your relevant information.
217 | 3.8 We reserve the right to collect your information without your prior authorization or
218 | consent according
219 | to the Article 7 of Section 1 of this Policy.
220 |
221 |
Information We may Share or Transfer
223 |
224 | 4.1 The Personal Information collected by TPF for business and legal purposes
225 | 4.2 The Personal Information will not be sold, traded or transferred to the third parties
226 | without your
227 | consent.
228 | 4.3 The Personal Information may be disclosed to these entities if you agree to our
229 | disclosure of the
230 | personal information to strategic partners or related parties. These entities will only use your personal
231 | information for the purposes you have agreed to.
232 | 4.4 You agree that we may disclose or share your personal information to the following third
233 | parties:
234 | a. service providers and data processors who represent us and provide services
235 | to us, such as KYC
236 | inspections, accounting, data processing or management services, website hosting, maintenance and
237 | operation services, mail information services, analysis services, and payment transaction processing,
238 | marketing, etc.;
239 | b. TPF consultants and professional consultants (such as accountants, lawyers,
240 | auditors).
241 | 4.5 The Personal Information may be transferred to any other country for the above-mentioned
242 | purposes. TPF
243 | will obtain your consent and ensure that the recipient of personal information has the same level of
244 | personal information protection measures as TPF. If there is no personal information protection law
245 | applicable to the relationship between TPF and you in these countries or regions, we will sign a legally
246 | enforceable agreement with the receivers of personal information.
247 | 4.6 TPF will not share with or transfer your Personal Information to any third party
248 | without
249 | your prior
250 | consent, except for the following circumstances:
251 | a. the collected Personal Information is publicized by yourself;
252 | b. the Personal Information is collected from public information which was
253 | legally disclosed, such as news
254 | (lawfully reported), government information disclosure and other channels;
255 | c. we may share your Personal Information with our affiliates only when
256 | necessary and to the extent
257 | permitted by this Policy;
258 | d. in order to abide by applicable laws, regulations, legal procedures, and
259 | administrative or judiciary
260 | authorities, TPF will provide or implement this Policy to protect our or other parties' rights, assets
261 | or
262 | security;
263 | e. in the case of mergers and acquisitions, if transfer of Personal
264 | Information
265 | is involved, TPF may
266 | require the receivers of Personal Information to be continuously bound by this Policy.
267 |
268 |
How We Collect Data Automatically
270 |
271 | 5.1 We use automatic data collection technology in the application. E.g:
272 | a. cookies (or browser cookies). Cookies are small text files set by the
273 | operator
274 | of a website or
275 | application to identify your browser or device. We may use cookies on our apps to store and track
276 | information, such as the number and frequency of use of users, user distribution, and users' online
277 | preferences. Cookies do not capture information that can identify you, but the information they collect
278 | can help us analyze the usage of the application to improve your experience. You can turn off cookies in
279 | your browser settings. However, this may affect the functionality of the application.
280 | b. network analysis. Web analytics is a method of collecting and evaluating
281 | the
282 | operation of visitors to
283 | web pages and mobile applications. This includes analyzing traffic patterns, such as determining the
284 | frequency of visits to certain functions of a website or mobile application, or to understand the
285 | information or services that visitors are most interested in. We use network analysis services provided
286 | by
287 | third-party tools.
288 | 5.2 We use third-party SDK in the application. E.g:
289 | SDK name: Umeng SDK
290 | Service type: analysis
291 | Collected data type: Device information (it may involve Android ID/OpenUDID information, etc., we will
292 | ask for your authorization before collecting this information)
293 | Privacy Policy Link: https://www.umeng.com/page/ policy
294 |
295 |
How We Protect Your Information
297 |
298 | 6.1 If TPF terminates operation, TPF will stop the collection of your Personal Information in
299 | time, post
300 | the announcement on TokenPocket and delete or anonymize your Personal Information held by us within a
301 | reasonable period.
302 | 6.2 To protect your Personal Information, TPF may adopt data security techniques, improve
303 | internal
304 | compliance levels, provide security training for our staff, and set security authority for access to
305 | relevant data to protect your Personal Information.
306 | 6.3 We will send you messages about information security in the “Wallet Guide” column and
307 | update articles
308 | concerning the use of wallets and information protection in the “Wallet Guide” column on TokenPocket for
309 | your reference.
310 |
311 |
Protection for the Minors
313 |
314 | The following special provisions apply to minors who are under the age of 18 years old:
315 | 7.1 The minors shall not use TokenPocket without the guidance from their parents or
316 | guardians.
317 | 7.2 The parents and guardians of the minors shall provide guidance to the minors on using
318 | TokenPocket
319 | after they read this Policy, TokenPocket Terms of Service and other relevant rules.
320 | 7.3 TokenPocket will ensure the confidentiality and security of the minors’ Personal
321 | Information in
322 | accordance with national laws and regulations.
323 |
324 |
Disclaimer
326 |
327 | 8.1 After you link to the third-party-developed DApps from TokenPocket, the privacy
328 | policies
329 | of
330 | the
331 | third-party-developed DApps will apply. The collection and use of your Personal Information by the
332 | third-party-developed DApps will be controlled neither by TPF, nor by this Policy.
333 | 8.2 You shall carefully select and use the third-party-developed DApps and protect your
334 | Personal
335 | Information. TPF shall not be held liable for the privacy protection obligation of any
336 | third-party-developed DApps.
337 | 8.3 You acknowledge and accept that, to the maximum extent permitted by applicable law, TPF
338 | will adopt
339 | measures as reasonable as possible to protect your Personal Information under current techniques on an
340 | “as
341 | is”, “as available” and “with all faults” basis, to avoid the disclosure, tampering or damage of
342 | information. since TPF transfers data wirelessly, TPF makes no guarantee on the privacy and security of
343 | wireless internet data transferring.
344 |
345 |
Miscellaneous
347 |
348 | 9.1 As a company that provides services to you, we will not actively provide your Personal
349 | Information to
350 | third parties other than the agreement, unless we obtain your consent and inform the other party's
351 | identity, contact information, processing purpose, processing method, etc. If there is service demand of
352 | processing your personal sensitive information in the future, we will ask your opinions once again, and
353 | use it after obtaining your consent.
354 | 9.2 If you are a user outside of Singapore, you shall fully understand and conform to the
355 | laws,
356 | regulations and rules in your jurisdictions which are relevant to use of TPF.
357 | 9.3 During your use of TPF services, if you come across any problems related to your Personal
358 | Information
359 | use, you may contact us through the submission of your feedbacks on TokenPocket.
360 | 9.4 You may access this Policy and other service rules of TPF on TokenPocket. We encourage
361 | you to check
362 | the Terms of Service and Privacy Policy of TPF each time you log into TokenPocket.
363 | 9.5 This English version and other translated versions of this Policy are provided for the
364 | convenience of
365 | Users, and are not intended to revise the original Chinese version of this Policy. If there is any
366 | discrepancy between the Chinese version and non-Chinese version of this Policy, the Chinese version shall
367 | prevail.
368 |
369 | This Policy shall become effective on January 10, 2018.
370 |
371 | As for any issues not covered in this Policy, you shall comply with the announcements and relevant
372 | rules
373 | as updated by TPF from time to time.
374 |
375 | TokenPocket Foundation Ltd.
376 |