EFFECTIVE DATE: [01/01/2021]

This Privacy Policy (“Policy”) applies to the trading platform (including any mobile applications and websites used to access the platform) (collectively referred to as “Platform”) provided by ALIXPAY (“Company,” “we,” “our”). It describes how the Company collects, uses, and discloses Personal Information obtained from Platform Users and any account services provided through the Platform, and how we use and disclose that information. In this Policy, “Personal Information” refers to information provided by Users that can directly or indirectly identify that User.
By registering and using the Platform, you agree that your Personal Information will be processed as described in this Policy and the Terms and Conditions applicable to the Platform (“Service Agreement”); capitalized terms used in this document will have the same meaning as stated in the Service Agreement.

Information We Collect About You and How We Collect It

We collect and process Personal Information about you directly from you when you register to use the Platform or provide such information as part of the Know Your Customer (“KYC”) process, as well as automatically through your use of the Platform.

Information We Collect Directly from You

Personal Account and Profile Information: There are several types of accounts that can be set up on the Platform. We collect information after you register for an Account: name, mobile phone number, and/or email address. When your Account meets certain criteria, we may collect additional information: name as in ID/passport, ID/passport number, date of birth, nationality, mailing address, residence address, mobile phone number, and email address.

Financial Information: We may collect additional financial and investment information from you to verify your status and eligibility to set up other types of accounts or perform certain transactions on the Platform, including your investment experience, financial certificates and training (including any certificates received, issuing organization, and issuance date), your annual income, liquid net worth, estimated net worth, source of funds and wealth, and whether you have ever been denied account opening by another financial institution.

Other Required Information: We may need to collect certain additional information to comply with legal requirements, such as whether you are a Politically Exposed Person or on any restricted persons lists, and applicable tax reporting forms, such as W8-BEN.

Communication with Us: We collect information you provide to us during support and feedback via email or when you contact us through contact forms on the Platform. We use this information to respond to your inquiries, provide support, facilitate transactions, and improve our Platform.

Notice to Authorized Individuals: Please note that if you are acting as an Authorized Individual on behalf of a User and providing Personal Information for that User, you are responsible for ensuring that you have all necessary rights and consents to provide that Personal Information to us for use in connection with the Platform, and that our use of the Personal Information you provide to the Platform does not violate any applicable laws, rules, regulations, or orders.

Information We Collect Automatically

Log Data: When you use the Platform, our servers automatically record information using cookies and other tracking technologies, including information your browser sends whenever you access the Platform or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the website you visited before arriving at the Platform, your browser type and settings, the date and time of your request, information about your browser and plugin configuration, language preferences, and cookie data. Such log data is not regularly deleted.

Device Information: In addition to log data, we may also collect information about the device you use for the Platform, including what type of device it is, the operating system you are using, device settings, unique device identifiers, and crash data. The information we collect may depend on the type of device you are using and its settings.

Combined Information: We may combine this information with other information we have collected about you, including, if available, your name, username, email address, and other Personal Information.

Geolocation: If you have granted permission through your mobile device to allow us to collect location information through the mobile app, we may obtain your physical location information about latitude and longitude from technologies such as GPS, Wi-Fi, or near cell towers. You can withdraw permission for us to collect such physical location information from your mobile device through your mobile device settings, although we do not control this process. If you have questions about how to disable location services on your mobile device, we recommend contacting your mobile service provider or mobile device manufacturer.

How We Use Your Information

We use your information, including your Personal Information, for the following purposes:

To tailor the content and information we may send or display to you, to provide location-based customization and personalized guidance and assistance, and to personalize your experience while using our Platform.

To understand how users access and use the Platform, both on an aggregate and individual basis, to improve our Platform and meet user desires and preferences, and for other research and analytical purposes.

For marketing and advertising purposes. For example, we may use your information, such as your email address or contact number registered with us, to send news and newsletters, special offers and promotions, to conduct contests and sweepstakes, or to contact you about products or information we think may be of interest to you. We may also use information we learn about you to help us advertise our Platform on third-party websites.

To provide the Platform to you, to facilitate communications and transactions on the Platform, to communicate with you about your use of our Platform, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.

Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to monitor information about your use of the Platform. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).


Cookies: Cookies are identifiers consisting of letters and numbers that we transfer to your computer’s hard drive via your web browser for record-keeping purposes. Some cookies help us make navigating your Platform easier, while others are used to facilitate faster login processes or to track your activity on our Platform. There are two types of cookies: session cookies and persistent cookies.

Session Cookies: Session cookies exist only during an online session. They disappear from your computer when you close the browser or turn off the computer. We use session cookies to allow our system to uniquely identify you in a session or when you have logged into the Platform. This enables us to process your online transactions and requests and verify your identity after you have logged in as you navigate through our Platform.

Persistent Cookies: Persistent cookies remain on your computer after you have closed the browser or turned off the computer. We use persistent cookies to track aggregate and statistical information about user activity. Please note that our system currently does not respond to do-not-track signals.

Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can adjust your browser settings to block them in the future. General settings in most browsers will guide you on how to prevent your computer from accepting new cookies, how to have your browser notify you when you receive new cookies, or how to completely disable cookies. Users on our Platform who disable cookies may not be able to browse certain areas of the Platform.

Third-Party Analytics: We use automated tools and applications, such as Google Analytics, to assess the use of our Platform. We may also use other analytics services to evaluate our Platform. We use these tools to help us improve our Platform, performance, and user experience. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

Third Party Links

Our platform may contain links to third-party websites. Any access and use of those linked websites are not governed by this Policy, but instead are governed by the privacy policies of those third-party websites. We are not responsible for the information practices of those third-party websites.

Personal Information Security

We have implemented reasonable precautions in accordance with applicable laws and regulations to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please note that despite our efforts, no data security measures can guarantee 100% safety. Therefore, all Users (including their Authorized Individuals) of the Platform must comply with the security requirements in the Terms and take additional steps to help ensure the security of their personal information and access to their accounts:
You should choose a strong username, password, and PIN to access your account (“User Credentials”) that no one else knows or can easily guess. User Credentials must meet the requirements we specify when you set up those User Credentials. You should keep your User Credentials safe and private, and not share your User Credentials with any third parties.

You should install antivirus, anti-spyware software, and a firewall on your personal computer and mobile devices.

You should regularly update your operating system, antivirus products, and firewalls with security patches or newer versions.

You should disable file and printer sharing on your computer, especially when connected to the internet.

You should regularly back up your important data.

You should consider using encryption technology to protect sensitive or confidential information.

You should completely log out and clear your browser cache after each online session with the Platform.

You should not install software or run programs from unknown sources.

You should delete spam or chain emails.

You should not open email attachments from unknown senders.

You should not disclose personal, financial, or credit card information to less known or suspicious websites.

You should not use untrusted computers or devices.

You should not use public computers or internet cafes to access online services or perform financial transactions.

You should immediately notify us at [email protected] if you become aware of any unauthorized use or access to your Account or User Credentials. We are not responsible for any lost, stolen, or compromised User Credentials or for any activity on your Account resulting from unauthorized use of your User Credentials.

Access, Correction, and Deletion

We have implemented reasonable precautions in accordance with applicable laws and regulations to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please note that despite our efforts, no data security measures can guarantee 100% safety. Therefore, all Users (including their Authorized Individuals) of the Platform must comply with the security requirements in the Terms and take additional steps to help ensure the security of their personal information and access to their accounts:
You should choose a strong username, password, and PIN to access your account (“User Credentials”) that no one else knows or can easily guess. User Credentials must meet the requirements we specify when you set up those User Credentials. You should keep your User Credentials safe and private, and not share your User Credentials with any third parties.

You should install antivirus, anti-spyware software, and a firewall on your personal computer and mobile devices.

You should regularly update your operating system, antivirus products, and firewalls with security patches or newer versions.

You should disable file and printer sharing on your computer, especially when connected to the internet.

You should regularly back up your important data.

You should consider using encryption technology to protect sensitive or confidential information.

You should completely log out and clear your browser cache after each online session with the Platform.

You should not install software or run programs from unknown sources.

You should delete spam or chain emails.

You should not open email attachments from unknown senders.

You should not disclose personal, financial, or credit card information to less known or suspicious websites.

You should not use untrusted computers or devices.

You should not use public computers or internet cafes to access online services or perform financial transactions.

You should immediately notify us at [email protected] if you become aware of any unauthorized use or access to your Account or User Credentials. We are not responsible for any lost, stolen, or compromised User Credentials or for any activity on your Account resulting from unauthorized use of your User Credentials.

Information Transfer

Please note, we may store your Personal Information on servers located in countries where our headquarters are situated. If that jurisdiction is outside your place of residence, you consent to the transfer of your Personal Information to that jurisdiction for the purposes of providing the Platform to you, even if that other jurisdiction has less personal information protection than your place of residence. We will ensure that security terms are applied in accordance with our obligations to maintain the security of your Personal Information under the laws of your place of residence.

Retention

We retain your Personal Information as long as you maintain an Account on the Platform. We will cease retaining your Personal Information, or remove the means by which Personal Information can be linked to specific individuals, as soon as reasonably practicable assuming —
(a) the purpose for which that Personal Information was collected is no longer served by retaining it;and (b) retention is no longer necessary for legal, accounting, or business purposes. Please note that some laws may require us to keep transaction or account records for a certain period.

Children Under 18

Our Platform is not designed for children under 18 years old. If we learn that a child under 18 has provided us with Personal Information, we will delete that information from our systems.

Contact Us

If you have questions about the security aspects of our Platform or wish to make a complaint, please contact us via our live chat service or at [email protected].

Changes to This Policy

This policy is effective as of the Effective Date set forth above. We may change this policy from time to time, so please review it periodically. We will post any changes to this policy on the Platform. If we make any changes to this policy that significantly affect our practices regarding Personal Information that we have collected from you previously, we will endeavor to provide you with prior notice of such change by highlighting the change on our Platform or providing push notifications through the Website (you should ensure that your Website settings allow for such push notifications) or by emailing the address you provided in your Account (for this reason, you should ensure your account information is updated promptly if it changes).