CoinPal Privacy Policy

1.Introduction

This Privacy Policy addresses the privacy rights associated with our collection, use, storage, sharing, and protection of your personal information. This Privacy Policy applies to the CoinPal website and all related websites, applications, servers and tools, regardless of how you access or use them, but does not apply to websites or services that we do not own or control, including those of other CoinPal users. This Privacy Policy is intended to give you access to information about privacy practices and to help you understand your privacy options when using our websites and services. Please note that the services we offer may vary by region. We have defined some of the terms used in the privacy policy. You can find the definition of the terms in the Definition section of this Privacy Policy. If you have questions about privacy practices which are not covered in this Privacy Policy, please contact us.

By registering, accessing or using the products, services, content, technology or features offered by our website and all related websites, applications and services (collectively the "CoinPal Services"), you accept this Privacy Policy. To ensure that you have full confidence in our handling of your personal data, you should read and understand the provisions of the Privacy Policy in detail. In particular, once you log in to our website, whether or not you register on the website, you indicate to us that you accept, agree, promise and confirm:

• You disclose your personal information to us voluntarily with your required consent;
• You will abide by all the terms and conditions of this Privacy Policy;
• You agree that we will collect your information by logging into this website, registering on this website and/or using the services we provide;
• You agree to any changes of this Privacy Policy in the future;
• You agree that our branch offices, affiliates, and employees will contact you for products and services that may be of interest to you (unless you have indicated that you do not wish to receive such messages).

We may revise this Privacy Policy at any time by posting a revised version on our website. The revised version will take effect when it is released. In addition, if the revision contains major changes, we will let you know 30 days in advance by posting a modification notice on the "Rules Update" page of our website. After the 30-day notice period, we will treat you as having made all explicit amendments to this rule.

2.How Do We Collect Information from You?

Collect from Website Visitors

When you visit CoinPal website or use CoinPal service, we will collect information that you send to us via your computer, mobile phone or other access device. Information sent to us includes: the data on the web page you visit, the IP address of your computer, the device identifier, the type of operating system you are using, your location, mobile network information, standard web log data, and other information. Web log data includes the type of browser you use and the inbound and outbound traffic to our website. When you visit CoinPal website or use CoinPal service, we also collect information about your transactions and activities.

Please check Section 3, "What Information Do We Collect" and Section 4, "How We Use Cookies" for more information. Visitors have the right to refuse to provide personal identity information but they may be prevented from using CoinPal's services.

Collect from CoinPal Users

You can provide your information to us by filling out a form on our website (such as CoinPal account registration) or by contacting us (for example by email or phone). The ways in which you provide information to us include:

• When you register your CoinPal account;
• When you log in to your CoinPal account;
• Submit any order through your CoinPal account;
• When participating in a promotion or investigation;
• When reporting a problem or raising a request.

Website visitors and CoinPal users have the right to refuse to provide personal identity information, but they should be aware that this may prevent them from using CoinPal's services.

3.What Information Do We Collect?

When you apply for an CoinPal personal account, perform any transaction on the CoinPal platform or use other CoinPal services, we collect personal information from you. This may include:

• Contact information: such as your name, mailing address, residential address, phone number, email address, and other information;
• Financial information: such as the full bank account number and/or credit card number that was associated with your CoinPal account or provided to us when using CoinPal service;
• Authentication information: such as your full legal name, nationality, date of birth, ID number;
• Details of any transaction made using CoinPal service;
• Additional personal information or documents required at our discretion by CoinPal compliance team;
• Any other information you choose to provide to us, for example, gather relevant information from your contact with our customer service team and collect relevant results when you respond to our survey.

When you apply for an CoinPal corporate account, perform any transaction on the CoinPal platform or use other CoinPal services, we collect corporate information from you. This may include:

• Contact information: such as primary business address and/or other actual business address, telephone number, email address, and other information;
• Identification information: such as the company's legal name (including legal name of local language), registration information, certificate of incumbency, personal information of all beneficial owners, and the identity documents of the shareholder/actual beneficial owner holding 20% or more of the shares;
• Business description;
• Additional corporate information or documents required at our discretion by CoinPal compliance team;
• Any other information you choose to provide to us, for example, gather relevant information from your contact with our customer service team and collect relevant results when you respond to our survey.

It is your responsibility to provide accurate and up-to-date information to us.

We may obtain your information from third parties such as credit bureau and authentication service provider. You can choose to give us access to certain personal information stored by third parties such as social media sites (for instance, Facebook and Twitter). The information we receive varies from site to site and is controlled by the site that provides the information. By associating a third-party managed account with your CoinPal account and authorizing CoinPal to access such information, you agree that CoinPal may collect, store and use such information subject to this Privacy Policy. We strictly abide by the "reasonable, relevant, and necessary principles" to collect your personal information, and do not collect information that is prohibited by laws and regulations.

To help protect you from fraud and to prevent abusing your personal information, we may collect information about your use of our website or CoinPal services and their interactions. For example, we may evaluate your computer, mobile phone, or other access device to identify any malware or activity. We may also collect other information you provide or about you in other ways.

In accordance with relevant laws and regulations and national standards, we may collect and use your personal information in accordance with the law without the consent of you under below situations:

• Directly related to national security and national defense security;· Directly related to public safety, public health, and major public interests;
• Directly related to criminal investigation, prosecution, trial and execution of judgments;
• Difficult to obtain your own consent to protect your or other people's important legal rights such as life or property;
• The personal information collected is disclosed to the public by yourself;
• Collect personal information from legal publicly disclosed information, such as legal news reports, government information release, etc.;
• Required to sign and perform the contract according to your requirements;
• Required to maintain the safe and stable operation of the services provided, such as the failure to discover or dispose of products or services;
• Other circumstances as stipulated by laws and regulations.

4.How We Use Cookies?

When you visit our website or use CoinPal service, we (including our business partners) use a small text file called cookies or other tracking technologies to track information about your use of our websites and services. A cookie is a small text file stored on your computer or mobile device when you visit the website. It allows websites to remember your actions and preferences over a period of time (such as login, language, font size, and other display preferences), so you don't have to log back in when you return from one page to another. Cookies are often used to record the habits and preferences of visitors as they navigate through various projects on the platform. The information collected by the cookies is anonymous collective statistics and does not contain personal data. Cookies cannot be used to obtain data on your hard drive, your email address, and your private data, which allows the platform or service provider system to recognize your browser and capture and remember information.

We use these technologies to achieve the following goals: Identify your customer identity; customize your online experience, customize CoinPal services, website content and advertising; evaluate promotional effects; help ensure your account is safe and unharmful; reduce risk and prevent fraud; improve our website and CoinPal services reliability and security. We may also use the information we collect to ensure compliance with the Bank Secrecy Act ("BSA") and Anti-Money Laundering ("AML") Program ("BSA / AML Program") and to ensure your account security by detecting irregular or suspicious account activity.

We use both session cookies and persistent cookies. When you log out of your account or close your browser, session cookies will be invalid and will no longer work; persistent cookies will remain in your browser until you delete them or invalidate them. We will encode the cookies so that we can interpret the information stored on them.

See the Help section of your browser, browser extension, or installed application for instructions on blocking, deleting, or disabling cookies. You may encounter CoinPal cookies or pixel tags that are not under our control on the website. For example, when you view a web page created by a third party or use a third-party developed application, you may find a cookie or pixel tag placed by that web page or application. Similarly, these third parties may place their own cookies or pixel tags that are not under our control and their use is not subject to CoinPal Privacy Policy.

Most browsers are set to accept cookies automatically. When you complete a browse or page operation, some cookies expire and other cookies remain on your computer or other device until they are deleted or expired. You may choose to refuse to use our cookies, but this may affect the functionality of CoinPal service or your user experience.

5.How Do We Protect and Store User Information?

The platform implements appropriate physical, electronic, management and technical measures to protect user information. In this policy, we use the term "user information" to describe information that can be associated with a particular individual and that can be used to identify that person. We believe that personal information does not include anonymous information that cannot be used to identify a particular user. Our computers store and process your personal information in locations in the US, Asia and Europe, and around the world. Security measures taken by the platform include but are not limited to:

• Physical measures: records containing user personal information will be stored in locked places;
• Electronic measures: Computer data containing user personal information will be stored on computer systems and storage media subject to strict login restrictions;
• Engagement measures: Only employees authorized by the platform can access your personal information. These employees need to follow the internal rules of confidentiality of personal information on the platform. At the same time, we develop a personal information security incident emergency plan and regularly organize relevant internal personnel to conduct emergency response training so that these employees deeply understand job responsibilities and emergency response strategies;
• Technical measures: data encryption, physical access control in the data center, and information access authorization control;

In addition to our efforts to ensure the security of your personal data storage and processing, you should not disclose your login password or account information to anyone to protect your personal data. Whenever you log in to our website, especially when you use someone else's computer or a public internet terminal, please remember to click and quit after the operation. Your efforts and assistance are absolutely helpful for us to protect your personal information.

6.How Do We Use the Collected User Information?

Our primary purpose in collecting personal information is to provide you with a safe, fluid, efficient, and personalized experience. We may use your personal information for the following purposes:

• Provide CoinPal service;
• Identify and confirm the identity of the user;
• Process the transaction and send you a transaction notification;
• Resolve disputes, collect fees and solve problems;
• Prevent prohibited or illegal activities;
• Personalize the user experience (specifically, customize, evaluate and improve the CoinPal service and the website content, layout and operations of our websites and applications);

Authorizing by User Agreement, we can call you, send a text message or email you (specifically, the email address provided by the user will be used to receive news, updates, announcements, related products or services promotion from the platform and updated order information).

In addition, we have adopted global standards to prevent money laundering, terrorist financing and economic sanctions, which requires us to conduct due diligence on our clients. This may include using third-party data and service providers to cross-match your personal information with its data.

Except as disclosed in this Privacy Policy, CoinPal will not share your personal data with any other third party as required by non-legal or legal reporting obligations.

7. How Do We Share Personal Information?

We will disclose your personal data or other information for the following reasons:

• The person or company you want to pay or pay to you: to handle your payment, we may share some of your personal information with them;
• Other CoinPal users who trade with you via CoinPal: We will provide them with your contact information, the date of registration, the number of payments you received from certified CoinPal users, and whether your control of your bank account has been confirmed;
• Service providers with whom we have a contractual relationship: they help us in business operations such as fraud prevention, fund collection, marketing and technical services. Our contract stipulates that these service providers may only use your information for the purpose of providing services to us, and must not use your information for their own benefit.
• Credit bureaus and collection agents: we need report account information to them if legally permitted.
• When law enforcement agencies, government officials, or other third parties require us to disclose information based on subpoenas, court orders, or other legal procedures or requirements applicable to CoinPal or one of its subsidiaries;
• When law and regulations require us to disclose information;
• When we determine for ourselves that it is necessary to disclose user information to prevent personal injury or economic loss, or to report suspected illegal activities or investigate violations of User Agreement;
• Other third parties: The premise is that you agree or require to do so. Please note that the laws governing the processing of user information in the countries or territories where these third parties are located may not be as strict as the country in which you are located.

We do not allow these third parties to use personal information for any other purpose other than the CoinPal service. If someone pays you and inputs your email address, we will provide them with your registrated name so they can confirm that they will transfer the money to the correct account. We work with third parties (including merchants) to make payments or collect payments with CoinPal. In the process, if a third party needs to notify you that a payment has been sent, or when you attempt to make a payment to a merchant or third party, a third party may share your information with us, such as your email address or mobile phone number. We can use this information to confirm your CoinPal customer status and to enable CoinPal to make payments, or to send you a payment status notification. CoinPal does not sell or rent any of your personal information to third parties for marketing purposes, but will only share your personal information with third parties in accordance with the provisions of this Privacy Policy. If you open an CoinPal account directly on a third-party website or through a third-party application, any information you input on that website or application (rather than directly on the CoinPal website) will be associated with the owner of the third-party website or application. These sites are subject to their own privacy protection rules, so it is recommended that you review their privacy protection rules before providing them with personal information. CoinPal is not responsible for the content or information specifications of such third parties.

8.How Do You Access or Change Your User Information?

You can log in to your account at any time and view your account settings and user information. You can view, modify and delete your personal information. You are responsible for the authenticity of the information you have filled out. You can also cancel your account through the CoinPal website. If you cancel your CoinPal account, we will mark your account as "logged out" in the database, but may still retain personal information in your account to resolve disputes and issues, assist with any investigation, avoid fraud, implement our User Agreement or take other actions required or permitted by law.

9.Promotion

We will share company news, promotional information and information about products and services provided by CoinPal from time to time with you. We may share personal data with third parties to help us with marketing and promotion projects or to send marketing messages. We will not sell or rent your personal information to third parties for the marketing purposes of third parties without your explicit consent. By using CoinPal, you accept this Privacy Policy and agree to accept such marketing communications. You can opt-out of these marketing communications at any time. If you do not want to receive the marketing information we send or participate in our advertising customization program, you can simply set the unsubscribe based on the relevant guidelines when you receive the marketing information or advertising customization plan we sent.

10.How Do You Contact Us About Privacy?

If you have any questions about this Privacy Policy or the use of your personal data, please send an email to [email protected] (titled "Privacy Request").