Privacy Policy

Last updated: January 31, 2025

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

[Introduction and Reminder Clause]

The NCN Exchange platform is a platform dedicated to users to conduct digital asset transactions and provide related services (hereinafter referred to as "the service" or "service"). For the convenience of expression, this platform is collectively referred to as "we" or other first-person pronouns in this agreement. As long as the natural persons or other subjects who log on to the platform are users of this platform, the following uses "you" or other second-person pronouns, we and Collectively, you are referred to as the "parties", and we or you are simply referred to as the "party".

We fully understand and respect the importance of your personal information to you, and we will take corresponding security protection measures in accordance with the requirements of laws and regulations to protect the security of your personal information. In view of this, we formulate this "Privacy Policy" (hereinafter referred to as "this policy/this privacy policy") and remind you:

This policy applies to all products and services we provide. If the product or service we provide to you has a separate privacy policy, the product or service shall apply its separate privacy policy; if our product or service does not have a separate privacy policy, this policy shall apply.

It is important to note that this policy does not apply to the services provided by other third parties to you, and the services provided to you by third parties shall be subject to their privacy policies separately explained to you.

Before using our products or services, please be sure to read and thoroughly understand this policy, especially the terms marked in bold/bold underline. You should read it carefully and start using it after confirming your full understanding and agreement. If you have any questions, comments or suggestions about the content of this policy, you can contact us through various contact methods provided by our officials. If you do not agree to any terms in this policy, you should immediately stop accessing this platform.

Part 1 : Definition

Personal information: refers to various information recorded electronically or in other ways that can identify a specific natural person alone or in combination with other information or reflect the activities of a specific natural person.

Personal sensitive information: refers to personal information including ID number, personal biometric information, bank account number, property information, whereabouts, transaction information, and children’s information under the age of 14 Personal sensitive information is marked in bold).

Personal information deletion: refers to the act of removing personal information from the system involved in the realization of daily business functions, so that it can be kept in a state where it cannot be retrieved or accessed.

Children: Refers to minors under the age of fourteen.

Part 2 : Privacy Policy

This privacy policy section will help you understand the following:

1. How we collect and use your information

2. How do we use cookies and similar technologies

3. How do we share, transfer, and publicly disclose your information

4. How do we protect your information

5. How do you manage your information

6. How do we deal with the information of minors

7. How to update this privacy policy

8. How to contact us

1. How we collect and use your information

When you use our products and/or services, we need/may need to collect and use your personal information including the following two types:

1. In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide the corresponding information, you will not be able to use our products and/or services normally;

2. In order to provide you with additional functions of our products and/or services, you can choose to authorize us to collect and use information. If you refuse to provide, you will not be able to use the relevant additional functions or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services.

You understand and agree:

1. We are committed to creating a variety of products and services to meet your needs. Due to the many types of products and services we provide you, and the specific product/service ranges that different users choose to use, correspondingly, the basic/additional functions and the type and scope of personal information collected and used will be different. Please follow The specific product/service function shall prevail;

2. In order to bring you a better product and service experience, we are constantly striving to improve our technology, and then we may launch new or optimized functions from time to time, and may need to collect and use new personal information or change Purpose or method of using personal information. In this regard, we will separately explain to you the collection purpose, scope and use method of the corresponding information by updating this policy, pop-up windows, page prompts, etc., and provide you with a way to choose your consent, and after obtaining your express consent Collect and use. During this process, if you have any questions, comments or suggestions, you can contact us through the various contact methods provided on this platform, and we will answer you as soon as possible.

We will collect and use your personal information to realize the following functions of this policy:

(1) Help you register and provide you with the services provided by this platform;

1. Registration service

We provide you with basic membership services through this platform account. In order to register as a member and use our membership service, you need to fill in and provide the following information when applying for registration:

(1) Identity information. This information can help us verify whether you are eligible to register as a member of the platform, including but not limited to your name, your residential address, other different certificates issued by your country or government that have your identity information and the involved Number and all other information that can help us verify your identity (hereinafter collectively referred to as "identity information"). The identity information varies according to whether you are an individual user or an institutional user. According to the laws and regulations of different jurisdictions, the information we collect for users from different countries or regions may be different. The following information and data serves as an indicative example:

Individual users: nationality, full legal name (including previous names and local language names), ID number, email address, phone number, social security number ("SSN"), passport number or any government-issued ID number, birth Date, identification (for example, passport, driving license or government-issued identification).

Institutional users: company legal name (including legal name in local language), registration information, business phone number, personal information of authorized representatives and authorized users, main business location, personal information of all beneficial owners), identity of shareholders/beneficial owners Proof documents (passport or government-issued ID card), company structure, company establishment documents, board resolutions, declaration of funding sources, risk and compliance control instructions, and other information or documents required by the platform.

(2) Service information. This information helps us to contact you and smoothly provide you with different modes of digital asset transaction services, including but not limited to your personal identification information, contact information, transaction information, and your debit card information and/or other account information (Hereinafter collectively referred to as "service information"). At the same time, please understand that the services we provide to you are constantly updated and developed. If you choose to use other services that are not covered in the foregoing description, based on the service we need to collect additional information about you, we will explain the scope of information collection to you through page prompts, interaction procedures, agreement agreements, pop-up prompts, etc. And purpose, and with your consent.

If you only need to use the browsing service, you do not need to register as our member and provide the above information.

2. Other registration services

Real-name authentication: After you register and log in, you need to enter the "personal center" to complete the real-name authentication in the identity authentication. You need to provide your real name, ID number or passport number to the platform during the process of using the real-name authentication.

Advanced authentication: When your transaction amount on this platform exceeds a certain limit, the platform will require advanced certification for you in order to maintain the security of your assets. In addition to the real-name authentication information in the authentication process, you agree that the platform will perform advanced authentication of "face recognition" for you. Face recognition will involve the platform's collection of your relevant video streams or facial images.

Account information display: If you already have an account on this platform, we may display your above-mentioned personal information in the service (real-name authentication only shows the result of whether the authentication is passed), as well as the products and services you perform in the products and services associated with the platform account Operations, including centralized display of your personal information and transaction orders through this platform account. We will respect your choice of platform account settings.

(1) Security management service and service information push service

When you use the services provided by this platform or access this platform, in order to ensure the security of your transaction and the safe and stable operation of the service, we need to automatically receive and record your web browser information, and the device information you use to log in to your account ( IDFA, operating system, device model, device manufacturer, system version, Android ID, IMEI, MAC address, etc.), the IP address and records on the webpage you request to access, the region, network environment, device fingerprint information, service log information , Software information, location information, etc.

Please note that separate device information is information that cannot identify a specific natural person. If we combine this type of non-personal information with other information to identify a specific natural person, or combine it with personal information, during the combined use period, this type of non-personal information will be treated as personal information, unless you have obtained your authorization Or unless otherwise provided by laws and regulations, we will anonymize and de-identify this type of information.

In order to provide you with information display and push services that are more convenient and more in line with your personalized needs, we may extract your preference features based on your device information and your browsing and usage information on this platform or client in the future, and based on feature tags Produce indirect crowd portraits, which are used to display and push information and possible commercial advertisements. If you do not agree to receive such push information or withdraw your consent to collect personal information, you can contact us in accordance with the contact information provided in this policy.

We strive to ensure your browsing experience. If you do not want to accept the commercial advertisements we send to you, you can reply to unsubscribe through SMS prompts or unsubscribe or close by other means provided by us.

In addition, we will also use your above-mentioned information in order to continuously improve and optimize the above-mentioned functions.

(2) Transaction record storage and inquiry services

We collect relevant data on your exchanges on this platform, including but not limited to transaction records. If you need to check your order transaction records, you can check your personal transaction details in the "Order Management" of the platform, including: counterparty nickname, order time, order number, transaction information, digital asset type and quantity, etc.

(3) Customer service and dispute handling

When you contact us or apply for after-sales and after-sales, dispute settlement, in order to protect your account and system security, we need you to provide the necessary personal information to verify your membership.

In order to facilitate contact with you and help you solve the problem as soon as possible or record the handling plan and results of related problems, we may save your communication records with us and related content (including account information, order information, other information provided by you to prove relevant facts) Information, or the contact information you left), if you consult, complain, or provide suggestions for a specific order, we will use your account information and order information.

In order to provide services and improve service quality for reasonable needs, we may also use other information about you, including relevant information you provide when you contact customer service, and questionnaire response information sent to us when you participate in a questionnaire survey.

(4) Other

1. If the information you provide contains personal information of other users, you need to ensure that you have obtained legal authorization before providing such personal information to this platform. If it involves children's personal information, you need to obtain the consent of the corresponding child's guardian before publishing. In the foregoing circumstances, the guardian has the right to contact us through the channels in Article 9 of this policy to request correction or deletion of the content of the child's personal information.

2. If we use information for other purposes not specified in this policy, or use information collected for specific purposes for other purposes, or if we actively obtain your personal information from a third party, we will obtain you in advance Agreed.

If we obtain your information indirectly from a third party, we will explicitly ask the third party in writing to collect personal information after obtaining your consent in accordance with the law, and inform you of the content of the shared information, which involves sensitive information. Before it is provided to us, it needs to be clearly confirmed by you, and requires the third party to make a commitment to the legality and compliance of the source of personal information. If the third party violates the behavior, we will explicitly require the other party to bear the corresponding legal responsibility; at the same time; , We will strengthen the security of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control, etc.). We will use no less than the same protection measures and measures as our own users' personal information to protect personal information obtained indirectly.

3. Exceptions for obtaining authorization and consent

You fully understand and agree that we do not need your authorization or consent to collect and use your personal information under the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, and information request:

(1) Related to national security and national defense security;

(2) Related to public safety, public health, and major public interests;

(3) Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial, and execution of judgments;

(4) In order to protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to obtain the consent of the person;

(5) Your personal information disclosed to the public on your own;

(6) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

(7) Necessary for signing and fulfilling relevant agreements or other written documents with you;

(8) Necessary for maintaining the safe and stable operation of the products and/or services provided, such as detecting and disposing of product and/or service failures;

(9) Necessary for legal news reports;

(10) When it is necessary for academic research institutions to conduct statistical or academic research based on public interests, and when they provide academic research or description results to the outside, they de-identify the personal information contained in the results;

(11) Other circumstances stipulated by laws and regulations.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information, the data recipient cannot re-identify specific individuals and cannot be restored, or we may conduct de-identification research on the collected information , Statistical analysis and prediction, used to improve the content and layout of this platform, provide product or service support for business decisions, and improve our products and services (including the use of anonymous data for machine learning or model algorithm training), then such processing The use of the later data does not require separate notice to you and your consent.

4. If we stop operating the products or services of this platform, we will promptly stop continuing the activities of collecting your personal information, and notify you of the stop operation notices in the form of one-by-one delivery or announcement, and the Personal information related to business suspension is deleted or anonymized.

2. How do we use cookies and similar technologies

If your browser or browser add-ons allow, you can modify the acceptance of cookies or reject our cookies. See AboutCookies.org for details. However, if you do so, it may affect your safe access to our platform in some cases, and you may need to change user settings every time you visit our platform. You understand and agree that:

1. When you visit our platform, we use Google Stats through cookies to record our performance and check the effectiveness of online advertising. A cookie is a small amount of data that is sent to your browser and stored on your computer's hard drive. Cookies can only be sent to your computer hard drive when you use your computer to access our platform.

2. Cookies are often used to record the habits and preferences of visitors when browsing various items on our platform. The information collected by Cookies is anonymous collective statistical data and does not contain personal information.

3. Cookies cannot be used to obtain the data on your hard disk, your email address, and your private data. It allows the platform or service provider system to recognize your browser and capture and remember information. Most browsers are preset to accept cookies. You can choose to set your browser not to accept cookies, or to notify you as soon as a cookie is installed. However, if cookies are disabled, you may not be able to activate or use certain features of our platform.

3. How we share, transfer and publicly disclose your information

(1) Sharing

We will not share your personal information with companies, organizations and individuals other than the service providers of this platform, except in the following cases:

1. Sharing under statutory circumstances: We may share your personal information externally in accordance with laws and regulations, litigation, dispute resolution needs, or according to the legal requirements of administrative and judicial authorities.

2. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

3. Sharing when you actively choose: We will share the necessary information related to the transaction in your order information with the counterparty of the digital asset transaction according to your choice, so as to realize your transaction and after-sales service needs.

4. Sharing with authorized partners: our affiliates, trusted third parties who help us operate our platform, conduct business, or provide services to you, as long as these parties agree to keep this information confidential; when we believe that the disclosure The information is appropriate to comply with laws, regulations, rules and regulations or orders from courts or other competent authorities, to implement our platform strategy, to properly operate the platform, to provide services for related parties, or to protect us or others rights, property or safety.

(2) Transfer

We will not transfer your personal information to any company, organization or individual, except in the following cases:

1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

2. In the event of a merger, acquisition or bankruptcy liquidation on this platform, or other situations involving mergers, acquisitions or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be subject to this Otherwise, we will require the company, organization and individual to ask you for authorization again.

(3) Public disclosure

We will only publicly disclose your personal information under the following circumstances:

1. With your explicit consent or based on your active choice, we may publicly disclose your personal information;

2. If we determine that you have violated laws and regulations or seriously violated the relevant agreements and rules of this platform, or in order to protect the personal and property safety of users of this platform or the public from infringement, we may comply with laws and regulations or obtain your consent. Disclose your personal information under , including relevant violations and the measures that this platform has taken against you.

(4) Exceptions to obtaining prior authorization and consent when sharing, transferring, and publicly disclosing personal information

In the following situations, sharing, transferring, and publicly disclosing your personal information does not require your prior 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 judicial or administrative law enforcement such as criminal investigation, prosecution, trial and execution of judgments;

4. For the protection of your or other personal life, property and other major legitimate rights and interests, but it is difficult to obtain the consent of the person;

5. Personal information that you disclose to the public by yourself;

6. Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.

Please be informed that according to applicable laws, if we take technical measures and other necessary measures to process personal information, so that the data recipient cannot re-identify specific individuals and cannot recover, the sharing, transfer, and public disclosure of such processed data do not require Separately notify you and obtain your consent.

4. How do we protect your information

1. We implement appropriate physical, electronic, management and technical measures to protect and guarantee the security of your personal data. We try our best to ensure that any personal information collected through our platform is free from interference by any third parties not related to us. The security measures we take include but are not limited to:

(1) Physical measures: records containing your personal data will be stored in a locked place.

(2) Electronic measures: Computer data containing your personal data will be stored on computer systems and storage media subject to strict login restrictions.

(3) Management measures: We have set up relevant departments internally to protect the security of user information, and established relevant internal control systems, and adopt strict authorization principles for staff who may have access to your information. Only authorized staff can access To your personal data, these employees are required to abide by our internal code of confidentiality of personal data. In addition, we continue to strengthen the publicity of relevant laws and regulations, privacy and safety standards and safety awareness for staff training, and regularly organize relevant internal personnel to conduct emergency response training and emergency drills, so that they can master job responsibilities and emergency response strategies and procedures

(4) Technical measures: Encryption technology such as Secure Socket Layer Encryption may be used to transmit your personal data.

(5) Security measures: In order to protect your information security, we are committed to using various current general security technologies and supporting management systems to minimize your information from being leaked, damaged, misused, unauthorized access, and unauthorized disclosure and risk of change. For example: encrypted transmission through network security layer software (SSL), encrypted storage of information, and strictly limited access to data centers. When transmitting and storing sensitive personal information (including personal biometric information), we will adopt security measures such as encryption, permission control, de-identification, and desensitization.

(6) Other measures: regularly review our personal data collection, storage and processing procedures; and restrict our employees and suppliers' access to your data according to necessary principles, and our employees and suppliers must abide by strict Contractual confidentiality obligations. .

2. If you are aware of any security vulnerabilities on our platform, please contact us immediately so that we can take appropriate action as soon as possible.

3. Despite the implementation of the above technical and security measures, we cannot guarantee the absolute security of data transmission on the Internet, so we cannot absolutely guarantee that the personal data you provide to us through our platform is safe at all times. We will update and publish security risks, personal information security impact assessment reports and other relevant content from time to time, which you can obtain through announcements on this platform.

5. How do you manage your information

You can access and manage your information in the following ways:

(1) Inquiry, correction and deletion of your information

You have the right to obtain a copy of your personal data upon request and to ascertain whether the information we hold about you is accurate and up to date. If any of your personal data is inaccurate, you may request that your information be updated. You can also request erasure of your personal data, although we may deny your erasure request in certain circumstances, for example where required by law or for other legal purposes. For data access, correction or deletion requests, you can contact us through the contact information in Article 8.

In responding to data access, correction or deletion requests, we will verify the identity of the requesting party to ensure that he/she is legally authorized to make such a request. While our goal is to respond to these requests free of charge, we reserve the right to charge you a reasonable fee if your request is repetitive or onerous.

(2) Change the scope of your authorization and consent

Each business function requires some basic personal information to be completed (see "Part 1" of this Privacy Policy). In addition, you can contact us to give or withdraw your authorization and consent through the contact information in Article 8.

When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.

(3) Cancellation of your account

You can contact us through the contact information in Article 8 to apply for canceling your account; after you voluntarily cancel your account, we will stop providing you with products or services, delete your personal information in accordance with the requirements of applicable laws, or make it Anonymization.

(4) To respond to your above request

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We will reply within 15 days. If you are not satisfied, you can also initiate a complaint through the contact information we provide.

For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain fee as appropriate. For information that is not directly linked to your identity, that repeats information for no reason, or that requires excessive technical means (for example, requiring the development of a new system or a fundamental change in existing practice), poses a risk to the legitimate rights and interests of others, or is impractical , we may reject it.

In the following situations, we will not be able to respond to your request in accordance with the requirements of laws and regulations:

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. There is sufficient evidence that the personal information subject has subjective malice or abuse of rights;

5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

6. Those involving commercial secrets.

6. How do we deal with the information of minors

This platform is open to children. If we find or suspect that a user is under the age of 14, we will ask the user to close his account and will not allow the user to continue to use the platform products or services. We will delete the relevant information as soon as possible. If you know of anyone under the age of 14 using our services, please notify us so we can take action to prevent them from accessing our products or services.

For minors who have reached the age of 14 but have not yet reached the age of 18, we expect parents or guardians to guide the minors to use our services. We will protect the confidentiality and safety of minors' information in accordance with relevant laws and regulations.

If you are a minor, it is recommended that your parents or guardians read this policy, and use our services or provide us with your information with the consent of your parents or guardians. In the case of collecting your information with the consent of your parents or guardians, we will only use or publicly disclose this information when permitted by law, with the explicit consent of your parents or guardians, or as necessary to protect your rights and interests. If your guardian does not agree with you to use our services or provide information to us in accordance with this policy, please stop using our services immediately and notify us in time so that we can take corresponding measures.

If you are a parent or guardian of a minor, please contact us through the contact information published in this policy when you have any questions about the information processing of the minor under your guardianship.

7. How to update this Privacy Policy

Our Privacy Policy is subject to change.

We will not limit your rights under this Privacy Policy without your express consent. We will post any changes to the Privacy Policy on our official channels. If you do not agree to the revised content, you should stop accessing this platform immediately. When an updated version of the Privacy Policy is released, your continued access to this platform will show and indicate that you agree to the updated content and agree to abide by the updated Privacy Policy.

For major changes, we will also provide more prominent notices (including we will notify you through the publicity of this platform and even provide you with pop-up prompts).

Major changes referred to in this policy include, but are not limited to:

1. Major changes have taken place in our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;

2. We have undergone major changes in aspects such as control rights. Such as changes in information controllers caused by mergers and acquisitions, etc.;

3. The main object of personal information sharing, transfer or public disclosure changes;

4. There are major changes in your right to participate in the processing of personal information and how to exercise it;

5. Changes in our responsible departments, contact methods and complaint channels responsible for handling personal information security;

6. The personal information security impact assessment report indicates that there is a high risk.

8. How to contact us

1. If you have any requirements and comments, you can email [email protected], which is the only valid and official email we use to communicate with you, so we do not use effective contact information for you, any No liability for actions or omissions.

2. We only publish announcements and information or post announcements on this platform through effective contact information on this platform, so we are not responsible for any losses caused by your trust in information not obtained through the above methods.

3. If you have any questions about our privacy policy, please feel free to contact us.