TokenPocket Privacy Policy

Last updated: April 5, 2024

Dear User:
TokenPocket Foundation Ltd. (hereinafter referred to as "we") respects and protects the privacy of users (hereinafter referred to as "you" or "user"). When you use TokenPocket, we will collect and use your personal information in accordance with this Privacy Policy (hereinafter referred to as "this Policy") and strictly keep the personal information you provide confidential.
We recommend that you carefully read and understand the entire contents of this Policy before using this product. Important information, including disclaimers and other clauses, will be highlighted in bold. The definitions of keywords in this Policy are consistent with our "TokenPocket Service Agreement".
This Policy may be updated online by us at any time. Once the updated policy is published, it will replace the original policy. If you do not accept the modified terms, please stop using TokenPocket immediately. Your continued use of TokenPocket will be deemed as acceptance of the modified policy. The modified policy will automatically take effect immediately upon publication on TokenPocket. You acknowledge that this Policy and other relevant regulations apply to TokenPocket and the DApps we own on TokenPocket.

I. What information do we collect from you?

Please be aware that we collect the following information from you to meet your needs for the TokenPocket service, and we attach great importance to protecting your privacy. When collecting your information, we will strictly adhere to the principles of "legality, legitimacy, and necessity." You also acknowledge that if you do not provide the relevant information required for our service, your experience with the TokenPocket service may be affected.
We will collect your mobile device information, account information (including account operation records, transaction records, wallet address, etc.), and other personal information. To meet your specific service needs, we will collect your name, bank card number, mobile phone number, and other information. We
may collect your location information; for example, when you use location-related services, we may record the location of your device to provide you with relevant services. GPS location information is sensitive personal information. If you refuse to provide this information, it will not affect your use of other functions of this product or service, but only location-related functions.
You acknowledge that your wallet password, private key, mnemonic phrase, and Keystore on TokenPocket are not stored or synchronized to our servers. We do not provide services to retrieve your wallet password, private key, mnemonic phrase, or Keystore.
In addition to the above, you acknowledge that when you use certain TokenPocket features, we will provide you with specific prompts before collecting your personal information and may request more personal information from you.
When you are redirected to a third-party DApp, the third-party DApp will collect your personal information. TokenPocket does not hold the personal information collected from you by third-party DApps. When filling in your personal information on a third-party DApp, you should carefully review the relevant user agreement and privacy policy. We are not liable for any losses caused by your actions on third-party DApps.
Within the scope permitted by laws and regulations, we may collect and use your personal information without your authorization or consent in the following circumstances:
(1) related to national security and defense security;
(2) related to public safety, public health, and major public interests;
(3) related to criminal investigation, prosecution, trial, and execution of judgments;
(4) the personal information collected is information that you have voluntarily disclosed to the public;
(5) collecting your personal information from legally publicly disclosed information, such as legal news reports, government information disclosure channels, etc.;
(6) necessary for maintaining the security and compliance of the service, such as discovering and handling product and service failures;
(7) other circumstances stipulated by laws and regulations. We collect information in the following ways:
     a. You provide us with information. For example, you provide your email address when providing feedback, or you provide it to us additionally when using our specific services.
     b. We obtain information with your consent during your use of TokenPocket, including your mobile device information and your operation records on TokenPocket, etc.

II. How We Use Your Information

We verify the connection between you and your wallet using the unique serial number of your mobile device. We will promptly send you important notifications, such as software updates, changes to the Service Agreement, and the terms of this policy. We provide a "Fingerprint Login" option in TokenPocket's "System Settings" for convenient and secure management of your digital tokens.
We process your feedback by collecting your publicly disclosed wallet address and the mobile device information you provide. We collect your personal information for internal audits, data analysis, and research to continuously improve our services. In accordance with the TokenPocket Service Agreement and other relevant regulations, we will use user information to manage and process user behavior. This is in accordance with legal and regulatory requirements and the need to cooperate with regulatory agencies.

III. How do you control your information?

You have the following autonomy over your personal information in TokenPocket:
(1) You can import your other wallets into TokenPocket by syncing your wallet, or import your wallet in TokenPocket into other digital token management wallets.
(2) TokenPocket will display the information of the imported wallet to you. You acknowledge that you can modify your digital token type, transfer funds, and receive payments through the "Assets" section.
You acknowledge that in the "Me" section of TokenPocket, you can freely choose to perform the following operations:
(1) In the "Address Book", you can view and modify your "Contacts" at any time;
(2) In the "System Settings", you can choose not to enable the "Application Lock" option, that is, you can choose not to use the verification service to enter TokenPocket;
(3) In the "Personal Center", you do not need to provide your name, mobile phone number, bank card, etc., but you need to provide the above information when you use specific services;
(4) In the "Submit Feedback" section, you can submit your questions and suggestions for improvement regarding TokenPocket at any time. We will be happy to communicate with you and actively improve our services.
You acknowledge that we will notify you in advance when we collect information from you for specific purposes, and you have the right to refuse. However, you also acknowledge that when you choose to refuse to provide relevant information, it means that you waive your right to use TokenPocket's services.
You acknowledge that neither you nor we have control over whether your transaction records are made public, because based on the open-source nature of the blockchain transaction system, your transaction records are public and transparent throughout the entire blockchain system.
You acknowledge that when you use TokenPocket's functions to jump to a third-party DApp, our "TokenPocket Service Agreement" and "TokenPocket Privacy Policy" will no longer apply. Regarding your control over your personal information on third-party DApps, we recommend that you carefully read and understand their privacy rules and relevant user service agreements before using third-party DApps.
You have the right to request us to update, modify, or delete your relevant information. You acknowledge that we may collect your information in accordance with the requirements of Article 1, Section 6 of this policy without obtaining your authorization or consent.

IV. We may share or transmit your information.

1. We will store your personal information for business and legal purposes.
2. We will not sell, trade, or transfer your personal information to any third party without your consent.
3. If you consent to our disclosure of your personal information to strategic partners or affiliates, we may disclose your personal information to such entities. Such entities will use your personal information only for the purposes you have consented to.
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, accounting, data processing or management services, website hosting, maintenance and operation services, email messaging services, analytics services, payment transaction processing, marketing, etc.; and
(2) our consultants and professional advisors (e.g., accountants, lawyers, auditors).
5. If we need to transfer your personal information to any other country for the purposes described above, we will obtain your consent and ensure that the recipient of the personal information has the same level of personal information protection measures as us. If there are no applicable personal information protection laws in such countries or regions regarding our relationship with you, we will enter into 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 circumstances:
(1) The personal information collected is information that you have disclosed to the public;
(2) The personal information collected is collected from legally publicly disclosed information, such as legal news reports, government information disclosure, etc.;
(3) This policy is provided or implemented in accordance with applicable laws and regulations, legal procedures, administrative or judicial authorities to protect our or other parties' rights, property or safety; (4
) In the event of a merger or acquisition, if the transfer of personal information is involved, the Company will require the recipient of the personal information to continue to be bound by this policy.

V. Automatic Data Collection Technology

1. We use automated data collection technologies in our application. For example:
(1) Cookies (or browser cookies). Cookies are small text files set by the website or application operator to identify your browser or device. We may use cookies in our application to store and track information such as the number of users and their frequency of use, user distribution, and users' online preferences. Cookies do not capture information that can identify you, but the information they collect can help us analyze the use of the application to improve your user experience. You can turn off cookies in your browser settings. However, this may affect the functionality of the application.
(2) Web analytics. Web analytics is a method of collecting and evaluating the behavior of visitors to web pages and mobile applications. This includes analyzing traffic patterns, such as determining the frequency of access to certain parts of a website or mobile application, or understanding the information or services that visitors are most interested in. Our application uses web analytics services provided by third-party tools.
2. We use third-party data support SDKs in our application. For example:
SDK Name: Umeng SDK
Service Type: Statistical Analysis
Personal Information Collected: Device Information (may involve Android ID/OpenUDID information, etc. We will request your authorization before collecting this information)
Privacy Policy Link: https://www.umeng.com/page/policy

VI. How We Protect Your Information

(1) If we cease operations, we will promptly cease collecting your personal information, post a notice of cessation of operations on TokenPocket, and delete or anonymize your personal information within a reasonable period.
(2) To protect your personal information, we will take data security technical measures, improve internal compliance, increase information security training for internal employees, and set secure access permissions for relevant data to protect your privacy.
(3) We will push information security messages to you in the TokenPocket “Wallet Guide” and update information on wallet usage and information protection in the TokenPocket “Wallet Guide” section from time to time for your reference.

VII. Protection of Minors

We have made the following special provisions for the protection of minors under the age of 18:
(1) Minors shall use our services under the guidance of their parents or guardians.
(2) We recommend that parents and guardians of minors guide them in using TokenPocket after reading this policy, the TokenPocket Service Agreement and our other relevant rules.
(3) TokenPocket will protect the confidentiality and security of minors' personal information in accordance with the provisions of relevant national laws and regulations.

VIII. Disclaimer

(1) Please note that after you access a third-party DApp through TokenPocket, you will be subject to the privacy policy published by that third-party DApp. The collection and use of your personal information by that third-party DApp is not under our control and is not bound by this policy.
(2) We cannot guarantee that third-party DApps will take personal information protection measures as required by us. You should carefully select and use third-party DApps and properly protect your personal information. We are not responsible for the privacy protection of other third-party DApps.
(3) We will take reasonable security measures to protect your personal information to the best of our ability under the current technological level, so as to avoid the leakage, alteration or destruction of information. We use wireless means to transmit data, therefore, we cannot guarantee the privacy and security of data transmitted through wireless networks.

IX. Other

(1) As the company providing services to you, we will not proactively provide your personal information to any third party other than those agreed upon in this agreement, unless we obtain your consent and inform them of their identity, contact information, processing purpose, processing method, etc. If we need to process your sensitive personal information later due to service requirements, we will seek your opinion separately again and use it only after obtaining your consent.
(2) If you are a user outside of Singapore, you need to fully understand and comply with all relevant laws, regulations and rules of your jurisdiction and the use of our services. We will establish a dedicated personal information protection department. If you encounter any problems with the use of your personal information while using our services, you can contact us by submitting feedback on TokenPocket.
(3) You can view this policy and our other service rules on TokenPocket. We encourage you to review our service agreement and privacy policy every time you visit TokenPocket. Any translated version of this policy is provided for user convenience only and is not intended to modify the terms of this policy. If there is any conflict between the Chinese version and the non-Chinese version of this policy, the Chinese version shall prevail.

This policy is effective from January 10, 2018.

For matters not covered in this policy, please comply with our announcements and related rules as they are updated from time to time.

TP Global Ltd.