Last updated on: February 15, 2019
respected user:
SMARTBABY PTE. LTD. (hereinafter referred to as "the company" or "we") respects and protects the privacy of users (hereinafter referred to as "you" or "user"). When you perform the following actions, the company will follow this privacy policy (hereinafter referred to as (referred to as "this policy") collects, discloses and processes your personal information:
(a) access or use our websites or mobile applications (“Apps”) and Services; and/or
(b) provide us with your personal information, regardless of the medium through which it is provided.
The company recommends that you carefully read and understand the entire content of this policy before using the application, and important information including disclaimers and other terms will be reflected in bold. The definition of relevant keywords in this policy is consistent with the company's "SmartBaby Service Agreement". If the definitions or terms used in this policy are inconsistent with those in the SmartBaby Service Agreement, this policy shall prevail.
By providing us with your personal information, you agree to our collection, use, disclosure (including transmission) and processing of your personal information in accordance with this Policy. If you do not accept this policy, please do not provide us with any personal information.
This policy may be updated by the company online at any time without notice. The updated policy will become effective upon posting on our application and replace the original policy. The revised policy will immediately apply to the personal information you provide to us. If you do not accept the revised terms, please stop using the app immediately, and your continued use of the app will be deemed acceptance of the revised policy.
1. What information do we collect about you
1. We will collect your mobile device information, operation records, transaction records, wallet address and other personal information.
2. In order to meet your specific service needs, we will collect your personal information, including but not limited to your name, bank card number, mobile phone number, email address and other information.
3. You are aware that your wallet password, private key, mnemonic, and Keystore on the app will not be stored or synchronized to our server. The company does not provide services for retrieving your wallet password, private key, mnemonic phrase, and Keystore.
4. We may ask you to collect more personal information so that you can use certain functions on the app. If you do not agree to provide such personal information, it is deemed that you have given up the use of specific functions of the application.
5. To the extent permitted by laws and regulations, the company may collect and use your personal information in the following situations without your authorization and consent:
(1) Related to national security and national defense security;
(2) Related to public security, public health, or major public interests;
(3) Related to criminal investigation, prosecution, trial and execution of judgments;
(4) The collected personal information is in the public domain;
(5) Collect your personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;
(6) Necessary for maintaining the safety and compliance of services, such as discovering and handling product and service failures;
(7) Other circumstances permitted by laws and regulations.
6. We collect information in the following ways:
(1) When you voluntarily provide information to us, no matter what the reason is;
(2) When you authorize us to obtain your information from a third party;
(3) You use our applications and services;
(4) When you contact or interact with our employees through various communication channels, such as social platforms, communication platforms, face-to-face meetings, telephone calls, emails, faxes and letters, etc.;
(5) When you have a transaction with us, contact us or ask us to contact you;
(6) When you request to subscribe to our emails; and/or
(7) We copy all or part of your transaction records through the blockchain system. But your transaction records should be subject to the records of the blockchain system.
7. Our applications may contain some technologies that collect personal information, and the specific collection methods will be described in this policy (see Article 5 below) or the applicable terms and conditions.
8. It is your initiative to provide us with personal information, and you can withdraw your consent at any time. However, if you choose to refuse to provide us with the personal information we request, you may not be able to use the application, and we may not be able to contact you or provide you with the products or services you need.
9. In some cases, you may provide us with personal information that is not your own. If you provide other people's information, you should ensure that you have obtained the consent of the information subject to allow us to collect the personal information of the information subject, and the information subject agrees to your disclosure of their personal information to us. You agree that you will indemnify and hold us harmless if such information subjects file a claim against us for our collection, use and disclosure of their personal information in accordance with the terms of this policy.
10. You should ensure that the personal information you provide to us is true, accurate and complete. You should notify us when your personal information changes.
2. How we use your information
1. We will collect, use or disclose your personal information for one or more of the following purposes:
(1) Provide you with the products and/or services you request;
(2) To handle your relationship with us;
(3) Promote your user experience;
(4) Confirm the corresponding relationship between you and your wallet through the unique serial number of your mobile device;
(5) Send you important notices in a timely manner, such as software updates, service agreements and changes to the terms of this policy;
(6) Assist you in handling your questions, feedback, complaints and requests through the wallet address and provided mobile device information;
(7) To inform you of our products, services, projects and activities;
(8) To resolve disputes, investigate any complaints, claims or disputes, or any actual or potential illegal conduct;
(9) Conduct internal audit, data analysis and research of the company;
(10) Conduct user behavior analysis by tracking the user's usage of the application;
(11) Comply with laws and regulations and requirements of regulatory agencies;
(12) Comply with the requirements of international laws and regulations for security and anti-money laundering or anti-terrorism;
(13) to perform our obligations and contractual terms and conditions; and/or
(14) Any reasonable purpose related to the aforementioned purpose.
2. If you agree, we will use your personal information for other purposes from time to time, such as informing you of the latest activities, offers and promotional information launched by our strategic partners or affiliates.
3. We provide you with the option of "Fingerprint or Face Login" in the "Usage Settings" of SmartBaby, allowing you to manage your digital tokens conveniently.
4. We provide you with the "Password-free payment" option in SmartBaby. The password-free payment will store your wallet password in the Keychain/Keystore of your mobile device through a secure encryption algorithm, and call your biometrics (fingerprint or face) when trading ) authentication, quickly complete the payment and signature.
3. How do you control your own information
You have the following independent control rights over your personal information in the application:
1. You can import your other wallets into the app by synchronizing the wallet, or import your wallet in the app into other digital token management wallets. The app will show you the information of the imported wallet.
2. You understand that you can modify your digital token type, transfer and receive money through the content of the "Assets" section.
3. You know that you can freely choose to perform the following operations in the "I" section of the application:
(1) In the "Use Settings", you can choose not to enable the "Fingerprint or Face Login" option, that is, you can choose not to use the Touch ID or Face ID verification service;
(2) In "Submit Feedback", you can give us your application questions and suggestions for improvement at any time, and we will be very happy to communicate with you and actively improve our services.
4. You understand that you can choose not to enable the "password-free payment" option, that is, you can choose not to call your biometric (fingerprint or face) authentication during transactions.
5. You know that you and we have no control over whether your transaction records are disclosed, because based on the open source nature of the blockchain transaction system, your transaction records are open and transparent in the entire blockchain system.
6. Our application will contain links to other websites, applications or smart contracts that are not owned, operated, developed or maintained by us. These links are provided for your convenience. This policy applies only to our apps. When you use third-party services, you understand that our "SmartBaby Service Agreement" and "SmartBaby Privacy Policy" will no longer apply. We recommend that you read and understand its privacy rules and user service agreements in detail.
7. You have the right to ask us to update, change, delete your personal information and/or withdraw your consent to us. If you wish to withdraw the consent you have given us, or if you wish to update, change, delete or access the personal information we hold, or if you do not accept our changes to this Policy, you may contact:
Name: Blue Yang
Email address: blue@token.im
8. In order for you to manage the personal information held by us, or to enable you to obtain information about how we used (or may use) your personal information within one year before you make such a request, we may charge you a certain amount. cost of. If we charge you, we will inform you of the amount in advance and fulfill your request after you have paid. We will endeavor to respond to you within thirty (30) days of your request. If we are unable to respond within thirty (30) days, we will let you know when we will respond.
9. In many cases, we need to obtain your personal information so that we can provide you with the products or services you requested. If you choose to refuse to provide us with the personal information we request or withdraw your consent, we may not be able to continue to provide you with the products and services you have requested.
4. We may share or transfer your information
1. We will store your personal information for business and legal purposes.
2. Without your consent, we will not sell, trade or transfer your personal information to third parties.
3. If you agree to our disclosure of your personal information to strategic partners or related parties, we may disclose your personal information to such entities. These entities will only use your personal information for the purposes for which you have consented.
4. You agree that we may disclose or share your personal information with the following third parties:
(1) Service providers and data processors who represent us and provide services to us, such as KYC checks for us, accounting, data processing or management services, website hosting, maintenance and operation services, mail information services, analysis services, payment transaction processing, marketing, etc.; and
(2) Our consultants and professional advisers (eg accountants, lawyers, auditors).
5. If we need to transfer your personal information to any other country for the above purposes, we will obtain your consent and ensure that the recipient of the personal information has the same level of personal information protection measures as ours. If there is no personal information protection law applicable to the relationship between us and you in such a country or region, we will sign a legally enforceable agreement with the recipient of the personal information.
6. Without your prior consent, the company will not share or transfer your personal information to any third party, except in the following cases:
(1) The collected personal information is disclosed to the public by yourself;
(2) The collected personal information is collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;
(3) To provide or implement this Policy in accordance with applicable laws and regulations, legal procedures, administrative or judicial authorities to protect the rights, property or safety of us or others;
(4) When mergers and acquisitions are involved, if the transfer of personal information is involved, the company will require the receiver of personal information to continue to be bound by this policy.
5. Automatic Data Collection Technology
1. We use automatic data collection technology in the application. For example:
(1) Cookies (or browser cookies). Cookies are small text files set by website or application operators to identify your browser or device. We may use cookie technology to store and track information on our applications, such as the number and frequency of users, user distribution, and users' online preferences. Cookies do not capture information that can identify you, but the information it collects can help us analyze the usage of the application to improve your experience. You can turn off cookies in your browser settings. However, this may affect the app's functionality.
(2) Network analysis. Web analytics is a method of collecting and evaluating the behavior of visitors to web pages and mobile applications. This includes analyzing traffic patterns, for example to determine how often certain features of a website or mobile application are accessed, or to understand which information or services are of greatest interest to visitors. Our app uses web analytics services provided by third-party tools.
6. How do we protect your information
1. If the company stops operating, the company will stop collecting your personal information and take measures to delete or anonymize the personal information it holds within a reasonable period.
2. In order to protect your personal information, the company will take data security technical measures, improve internal compliance level, increase internal employee information security training, and set up security access permissions for relevant data to protect your private information safely.
3. We will send you information about information security in the SmartBaby "Message Center", and update information on wallet usage and information protection in the SmartBaby "Help Center" section from time to time for your reference.
7. Protection of minors
We have made the following special agreements for the protection of minors under the age of 18:
1. Minors should use the company's related services under the guidance of their parents or guardians.
2. We recommend that parents and guardians of minors should guide minors to use the app on the premise of reading this policy, the "SmartBaby Service Agreement" and our other relevant rules.
3. This app will protect the confidentiality and security of minors' personal information in accordance with applicable laws and regulations.
8. Disclaimer
1. You confirm that after you use third-party services, this policy will no longer apply to the collection, use, disclosure and transmission of your personal information by such third parties. The Company cannot guarantee that such third parties will take reasonable security measures.
2. You will be solely responsible for the use of third-party services, and you agree that if a third party collects, uses, discloses and transmits your personal information, resulting in your loss or damage, you shall not require the company to take responsibility.
3. You acknowledge and accept that, to the maximum extent permitted by the applicable laws, the company will, under the conditions of the existing technical level, based on the principles of "as is", "as available" and "without guarantee to be free from defects". Take reasonable security measures to protect your personal information to avoid disclosure, tampering or damage of information. The Company uses wireless means to transmit data, therefore, the Company cannot ensure the privacy and security of data transmitted over wireless networks.
Nine, other
1. You need to fully understand and abide by all relevant laws, regulations and rules of your jurisdiction and the use of our company's services.
2. Applicable law and dispute resolution:
This Policy is governed by the laws of the The British Virgin Islands and shall be construed accordingly.
3. You can view this policy and other service rules of the company in our application. We encourage you to review our service agreement and privacy policy every time you visit the application.
4. Any translated version of this policy is provided for the convenience of users only, and is not intended to modify the terms of this policy. In the event of a conflict between the English and non-English versions of this Policy, the English version shall prevail.
5. This policy is applicable from March 03 , 2023 .
For matters not covered in this policy, you must abide by the announcements and related rules updated by the company from time to time.
IBTC GROUP LIMITED (Company registration number: 2075394)