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Privacy Policy
Last Updated: October 25, 2022

BlockPI, its affiliates and related entities ("BlockPI", "we", "us" or "our") respect and value the privacy of your information. The following Privacy Policy sets forth our policies and practices regarding how we use and share the information we collect through your use of our products and services (collectively, the "Service"), and your navigation of our websites.

We will collect, use, disclose and process your personal information ("Personal Information"), in accordance with this Privacy Policy ("Policy") when you:

(a) access or use our website and any Services; and/or

(b) provide us with your Personal Information, regardless of the medium through which such Personal Information is provided.

We solemnly recommend that: you shall carefully read and understand the whole contents of this Policy before your use of our website or any Services.

By providing us with your Personal Information, you consent to our collection, use, disclosure (including transfer) and processing of your Personal Information in accordance with this Policy. Please DO NOT provide any Personal Information to us if you do not accept this Policy.

We reserve the right to modify and update this Policy from time to time, without prior notice to you, and the revised Policy will come into effect immediately and supersede the older versions once posted on the website. The revised Policy will apply to Personal Information provided to us previously. In particular, if you do not accept the revised Policy, please immediately stop your access to or use of the website or any Services provided by us. Your continuous access to or use of the website or any Services provided will be regarded as your acceptance of the revised policy.

1. Information We Collect

1.1 We collect your Personal Information, including but not limited to your device information, operation records, etc.

1.2 In order to satisfy your needs or requests for specific services, we may also collect Personal Information including but not limited to identification information such as your name, bank card number, telephone number, email address or biological information such as facial features, fingerprint.

1.3 We may also request for you to provide us with additional Personal Information for us to enable your use of any specific functions of the Services. Your refusal to provide us with the requested Personal Information will be considered as your choice to not use a particular specific function of such Services.

1.4 To the extent permitted by applicable laws and regulations, we may collect and use the Personal Information in the following circumstances without your prior consent or authorization:

(i) information related to national security and national defense;

(ii) information related to public security, public health, significant public interests;

(iii) information related to criminal investigation, prosecution, trial and enforcement;

(iv) Personal Information in the public domain;

(v) Personal Information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

(vi) Personal Information necessary to maintain the security and compliance of the services, such as to detect or to solve the malfunction of products and services; and/or

(vii) other circumstances permitted by laws and regulations.

1.5 We collect information in the following ways:

(i) when you provide us with your Personal Information for whatever reasons;

(ii) when you authorize us to obtain your Personal Information from a third party;

(iii) when you register for an account to use the Services;

(iv) when you contact us or interact with our employees through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;

(v) when you transact with us, contact us or request that we contact you; and/or

(vi) when you request to be included in an email or our mailing list.

1.6 Our Services may contain certain technologies that collect Personal Information in the manner described in this Policy or the applicable terms and conditions.

1.7 Your provision of Personal Information to us is voluntary and you may withdraw your consent for us to use your Personal Information at any time. However, if you choose not to provide us with the Personal Information we require, it may not be possible for your access to or use of the website and our Services, or for us to contact you or provide products or services which you need from us.

1.8 In certain circumstances, you may also provide us with the Personal Information of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her Personal Information and that he/she has consented to your disclosure of his/her Personal Information to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such Personal Information in accordance with the terms of this Policy.

1.9 You are responsible for ensuring that all Personal Information that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your Personal Information.

2. How We Use Your Information

2.1 We collect, use or disclose your Personal Information for one or more of the following purposes:

(i) to provide you with products and/or services that you request for;

(ii) to manage your relationship with us;

(iii) to facilitate your access to or use of our website;

(iv) to push important notifications to you, such as software update, and modification or update of terms, rules, and polices if applicable;

(v) to assist with your enquiries, feedback, complaints and requests;

(vi) to notify you of our products, services, programmes and events;

(vii) to resolve any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct;

(viii) to conduct our internal audit, data analysis and research;

(ix) to conduct user behavior tracking by tracking your use of the website and the Services;

(x) to comply with our obligations in accordance with laws, regulations and to cooperate with regulatory authorities;

(xi) to comply with international sanctions and applicable regulation for securities and to counter money-laundering or financing of terrorism;

(xii) to enforce obligations owed to us, and contractual terms and conditions; and/or

(xiii) any other reasonable purposes related to the aforesaid.

2.2 If you have consented, we may use your Personal Information, from time to time, for additional purposes such as to inform you of the latest activities, special offers and promotions offered by our strategic business partners, associates and affiliates.

3. How You Control Your Own Information

3.1 You are entitled to control your Personal Information provided to us. You are entitled to ask us to update, revise, and delete your Personal Information and/or withdraw any consent provided to us. If you wish to withdraw any consent you have given us at any time, or if you wish to update, revise, delete or have access to your Personal Information held by us, or if you do not accept any amendment to this Policy, please contact us at Email: info@blockpi.io.

3.2 Our website or other Services may contain links to other websites, applications or smart contracts that are not owned, operated, developed or maintained by us. These links are provided only for your convenience. This Policy only applies to our website and the Services provided by us. When visiting these third-party websites, or using these third-party applications or smart contracts, you understand that our terms, rules and any other polices may no longer apply. You are encouraged to carefully review their privacy policies and related terms of service.

3.3 We may charge you a fee for responding to your request for access to your Personal Information held by us. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received. We will endeavour to respond to your request within thirty (30) days, and if that is not possible, we will inform you of the time by which we will respond to you.

3.4 In many circumstances, we need to use your Personal Information in order for us to provide you with products or services that you require. If you do not provide us with the required Personal Information, or if you withdraw your consent to our use and/or disclosure of your Personal Information for these purposes, it may not be possible for us to continue to serve you or provide you with the products and services that you require.

4. Information We May Share or Transfer

4.1 We will keep your Personal Information for so long as we need the Personal Information for our business and legal purposes.

4.2 We do not sell, trade or otherwise transfer your Personal Information to third parties without your consent.

4.3 If you have consented to our disclosure of your Personal Information to our strategic business partners and associates, we may disclose your Personal Information to them. They will use your Personal Information only for the purposes you have consented to.

4.4 You agree that we may disclose or share your Personal Information with third parties such as:

(i) service providers and data processors working on our behalf and providing services to us such as conducting know-your-Customers checks, accounting, data processing or management services, website hosting, maintenance and operation services, e-mail message services, analysis services, marketing etc.; and

(ii) our consultants and professional advisors (such as accountants, lawyers, auditors).

4.5 If we need to transfer your Personal Information to any country for the purposes set out above, we shall obtain your prior consent and ensure that the recipient of the Personal Information protects your Personal Information to the same level as we have committed to protecting your Personal Information. Where these countries or territories do not have personal data protection laws that are comparable to the laws applicable to our relationship with you, we will enter into legally enforceable agreements with the recipients.

4.6 We will not share with or transfer your Personal Information to any third party without your prior consent, except for the following circumstances:

(i) the collected Personal Information is publicized by yourself;

(ii) the Personal Information is collected from public information which was legally disclosed, such as news (lawfully reported), government information disclosure and other channels;

(iii) in order to abide by applicable laws, regulations, legal procedures, and administrative or judiciary authorities or to enforce our Policy or protect our or others' rights, property or safety;

(iv) in the case of mergers and acquisitions, if transfer of Personal Information is involved, we may require the receivers of Personal Information to be continuously bound by this Policy.

5. Automatic Data Collection Technologies

5.1 We may use automatic data collection technologies on our website or any Services. Examples of such technologies include but not limited to:

(a) Cookies (or browser cookies). Cookies are small text files which are set by a website or application operator so that your browser or device may be recognized. We may make use of cookies on our website or other Services to store and track information such as the number of users and their frequency of use, profiles of users and their online preferences. Cookies do not capture information which would personally identify you, but the information collected may be used to assist us in analysing the usage of our website and other Services and to improve your online experience with us. You can disable the cookies by changing the setting on your browser. However, this may affect the functionality of the Services.

(b) Web analytics. Web analytics is the term given to a method for collecting and assessing the behavior of visitors to websites. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of our website, or to find out what information and services our visitors are most interested in.

6. How We Protect Your Information

6.1 If we cease operation, we will stop the collection of your Personal Information, and take steps to delete or anonymize your Personal Information held by us within a reasonable period.

6.2 To protect your Personal Information, we may adopt data security techniques, improve internal compliance levels, provide security training for our staff, and set security authority for access to relevant data to protect your Personal Information.

6.3 We will send you messages about information security and update articles concerning the use of our Services and information protection on our website for your reference.

7. Protection for the Minors

7.1 The following special provisions apply to minors who are under the age of 18 years old:

(a) The minors shall not use our website or any Services without the guidance from their parents or guardians.

(b) The parents and guardians of the minors shall provide guidance to the minors on using our website or any Services after reading this Policy and other terms, rule or policies.

(c) We will ensure the confidentiality and security of the minors' Personal Information in accordance with the applicable laws and regulations.

8. Disclaimer

8.1 After your accessing to the websites or any services provided or operated by third parties, you acknowledge that this Policy no longer applies to the collection, use, disclosure and transfer of your Personal Information by these third parties. We are unable to guarantee that these third-party websites, applications and/or smart contracts will implement reasonable security measures to protect your Personal Information.

8.2 You are solely responsible for your use of these third-party websites, applications and/or smart contracts and agree that you will not hold us liable for any damages incurred or injuries inflicted as a result of the collection, use, disclosure and transfer of your Personal Information by such third-party websites, applications and/or smart contracts.

8.3 YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE WILL ADOPT MEASURES AS REASONABLE AS POSSIBLE TO PROTECT YOUR PERSONAL INFORMATION UNDER CURRENT TECHNIQUES ON AN "AS IS", "AS AVAILABLE" AND "WITH ALL FAULTS" BASIS, TO AVOID THE DISCLOSURE, TAMPERING OR DAMAGE OF INFORMATION. SINCE WE TRANSFER DATA WIRELESSLY, WE MAKE NO GUARANTEE ON THE PRIVACY AND SECURITY OF WIRELESS INTERNET DATA TRANSFERRING.

9. Miscellaneous

9.1 You shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of the Services provided by us.

9.2 The validity, interpretation, alternation, enforcement, dispute resolution of this Policy and its revised versions shall be governed and construed in accordance with the laws of Singapore. Where there is no applicable law, this Policy shall be interpreted by applicable commercial and/or industrial practices. Any dispute arising out of or in connection with this Policy shall be referred to and finally resolved by arbitration in Singapore International Arbitration Centre ("SIAC") in accordance with the Arbitration Rules of the SIAC ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause.

9.3 You may access this Policy and other terms, rules or policies on our website. We encourage you to check all of the up-to-date terms, rules and other policies each time you access or use our website and any Services provided by us.