Introduction

We fully understand the importance of your personal information and are committed to protecting the security of your personal information in accordance with applicable laws and regulations. This Nodexx Privacy Policy (hereinafter referred to as the "Policy") is intended to explain how we collect, use, store, share, and protect your personal information, as well as the rights you are entitled to regarding your personal information.

This Policy applies to all products and services provided by us. Where a separate privacy policy is provided for a specific product or service, such separate privacy policy shall prevail with respect to that product or service. Where no separate privacy policy is provided, this Policy shall apply.

Definitions

Personal Information: Refers to all kinds of information recorded electronically or by other means that can, either independently or in combination with other information, identify a specific natural person or reflect the activities of a specific natural person.

Sensitive Personal Information: Refers to personal information including, but not limited to, identification document numbers, biometric information, bank account information, property information, location tracking information, transaction information, and personal information of children under the age of fourteen (14).

Deletion of Personal Information: Refers to the removal of personal information from the systems involved in the daily operation of product functions, rendering such information irretrievable and inaccessible.

Part II Privacy Policy

I. How We Collect and Use Your Information

(I) Types of Information We Collect

1.1 Information You Provide Directly

Information that you voluntarily submit when registering an account, making deposits, participating in social interactions, or using our services, including but not limited to:

Account name;
Contact information;
Identity verification information, including copies of both sides of your identity card, facial recognition data (where applicable), and other biometric information required for identity verification.

1.2 Information Collected Automatically

When you access and/or use our platform and services, we may collect the following technical information relating to your use of our services:

Browser Information, including but not limited to:

IP address;
Domain name;
Login information;
Browser type and version;
Time zone settings;
Browser plug-in types and versions;
Operating system;
Platform information.

Log Information, including but not limited to:

Device information;
Device manufacturer;
Operating system version;
Android ID;
IMEI number;
Device fingerprint information;
Location information;
System activity;
Number and duration of visits;
Page interaction records.

We collect location information only where necessary, and you may disable location permissions through your device settings at any time.

1.3 Information Obtained from Third Parties

We may obtain information relating to you from third parties (collectively, "Third-Party Information"), including but not limited to:

Banks involved when you make transfers for the purpose of using our services;
Advertising providers;
Search providers;
Analytics service providers;
Public databases;
Credit reporting agencies;
Identity verification partners;
Authorities or institutions conducting investigations relating to your use of our services;
Any other information we may collect from time to time where legally permissible.

Third-Party Information may be used for purposes including but not limited to:

Assisting internal and/or external investigations;
Complying with our legal or regulatory obligations;
Conducting personal data processing activities such as identity verification, payment processing, compliance with court orders, regulatory reporting obligations, anti-money laundering ("AML"), and counter-terrorist financing ("CTF") compliance;
Any other lawful purposes that we reasonably deem necessary from time to time.

II. Rules for the Use of Information

Legal Basis for Processing Personal Information

We process your personal information based on the following lawful grounds:

To ensure the security of the assets in your account;
To provide you with a more convenient and personalized user experience;
To assist in any investigation or resolve any potential disputes;
To improve the quality of our services;
To manage the operation of the Platform;
To conduct data analysis regarding the use of the Platform;
For any other lawful purposes that we may reasonably deem necessary from time to time.

De-identification

Where data is de-identified or anonymized for statistical analysis, algorithm optimization, or similar purposes, such data will no longer be regarded as personal information.

Third-Party SDKs

(1) Umeng Mobile Analytics SDK / Social Sharing SDK

Purpose of Use:

To perform operational statistics and analytics for the App;
To enable content sharing within the App.

Service Provider:

Umeng Tongxin (Beijing) Technology Co., Ltd.

Types of Personal Information Collected:

Device information (including IMEI, MAC Address, Android ID, IDFA, OAID, OpenUDID, GUID, SIM IMSI, ICCID);
Location information;
Network information.

Privacy Policy:

https://www.umeng.com/page/policy

(2) Bugly Crash Reporting SDK

Purpose of Use:

To collect and report application crash and exception information.

Service Provider:

Tencent Technology (Shenzhen) Company Limited

Types of Personal Information Collected:

Device information (including IMEI, MAC Address, Android ID, IDFA, OAID, OpenUDID, GUID, SIM IMSI, ICCID);
Location information;
Network information.

Privacy Policy:

https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56

Termination of Services

If we cease operating the Platform or discontinue any of our products or services, we will promptly stop collecting your personal information, notify you of such discontinuation by individual notice or public announcement, and delete or anonymize the personal information relating to the discontinued business in accordance with applicable laws and regulations.

III. Data Sharing and Transfer

(I) Principles of Data Sharing

We will not share your personal information with any third party without your separate consent, except under the following circumstances:

Necessary Service Providers

We may share your personal information with payment service providers, banks, payment institutions, and other cooperating organizations that lawfully provide payment and settlement services where necessary to deliver our services.

Legal Requirements

We may disclose your personal information where required to respond to lawful requests, investigations, or orders issued by judicial authorities or other competent governmental agencies in accordance with applicable laws.

Corporate Transactions

Where a merger, acquisition, restructuring, transfer of control, or other similar corporate transaction results in a change of control over the Platform, we will notify you at least thirty (30) days in advance. You will have the right to discontinue using our services or close your account before such change takes effect.

(II) Cross-Border Transfer of Personal Information

Where it is necessary to transfer your personal information outside your jurisdiction, we will:

Complete any security assessment organized by the competent national cybersecurity authority where required by applicable laws;
Execute a standard contractual arrangement or other legally recognized transfer mechanism with the overseas recipient;
Clearly disclose the identity of the overseas recipient and relevant transfer information in this Privacy Policy or through other legally required notices.

IV. Your Rights

You may access and manage your personal information in the following ways:

(I) Accessing, Correcting, and Deleting Your Personal Information

You have the right to obtain a copy of your personal data upon request and to verify whether the personal information we hold about you is accurate and up to date.

If any of your personal information is inaccurate or incomplete, you may request that we update or correct it.

You may also request the deletion of your personal information. However, we may refuse your deletion request where we are required to retain such information under applicable laws or where retention is otherwise necessary for legitimate legal purposes.

For requests relating to access, correction, or deletion of your personal information, please contact us using the contact details provided in Section VIII of this Policy.

To protect your personal information, we will verify the identity of the requesting party before processing any request to ensure that the requester is legally entitled to make such request.

Although we generally process such requests free of charge, we reserve the right to charge a reasonable fee where requests are repetitive or manifestly excessive.

(II) Withdrawing Your Consent

Certain business functions require the processing of basic personal information in order to operate properly (please refer to Section I of this Privacy Policy).

For any processing activities beyond those necessary for providing the core services, you may grant or withdraw your consent at any time by contacting us using the contact information provided in Section VIII of this Policy.

Once you withdraw your consent, we will cease processing the relevant personal information to the extent required by applicable laws.

However, your withdrawal of consent will not affect the lawfulness of any processing activities carried out based on your consent before such withdrawal.

(III) Account Cancellation

You may request the cancellation of your account by contacting us using the contact details provided in Section VIII of this Policy.

Upon successful cancellation of your account, we will cease providing you with our products and services and will delete or anonymize your personal information in accordance with applicable laws and regulations.

(IV) Responding to Your Requests

To protect the security of your information, we may require you to submit a written request or otherwise verify your identity before processing your request.

Under normal circumstances, we will respond within fifteen (15) business days. If additional time is required due to the complexity of the request, we will inform you of the reason for the delay in advance.

If you are dissatisfied with our response, you may submit a complaint through the contact channels provided by us.

We generally do not charge any fees for reasonable requests. However, for repetitive requests or requests that exceed reasonable limits, we may charge an appropriate administrative fee where permitted by law.

We may decline your request where:

the requested information is not directly related to your identity;
the request is repetitive or unfounded;
fulfilling the request would require disproportionate technical effort (for example, developing a new system or fundamentally changing existing business practices);
fulfilling the request would pose a serious risk to the legitimate rights and interests of others; or
the request involves trade secrets.

In accordance with applicable laws and regulations, we may be unable to respond to your request under any of the following circumstances:

Where the request relates to national security or national defense;
Where the request relates to public security, public health, or significant public interests;
Where the request relates to criminal investigations, prosecutions, trials, or enforcement of judgments;
Where there is sufficient evidence demonstrating that the data subject has acted in bad faith or abused his or her rights;
Where responding to the request would seriously prejudice the legitimate rights and interests of you, another individual, or an organization; or
Where trade secrets are involved.

V. Protection of Minors

Children refer to individuals under the age of fourteen (14).

The Platform prohibits children under the age of fourteen (14) from registering or using our services.

We may use age confirmation prompts, parental supervision mechanisms, and other reasonable technical measures to identify underage users.

If we discover or reasonably believe that a user is under the age of fourteen (14), we will require the account to be closed and will not permit continued access to our products or services. We will delete the relevant personal information as soon as reasonably practicable.

If you become aware that any person under the age of fourteen (14) is using our services, please notify us immediately so that we may take appropriate measures to prevent such individual from accessing our products or services.

For minors who are at least fourteen (14) years old but under eighteen (18) years old, we encourage parents or legal guardians to supervise and guide their use of our services.

We will protect the confidentiality and security of minors' personal information in accordance with applicable laws and regulations.

If you are a minor, you should carefully read this Privacy Policy together with your parent or legal guardian and use our services or provide your personal information only after obtaining the consent of your parent or legal guardian.

Where we collect a minor's personal information with the consent of a parent or legal guardian, we will use or disclose such information only where permitted by applicable laws, expressly authorized by the parent or legal guardian, or necessary to protect the minor's interests.

If your parent or legal guardian does not agree to your use of our services in accordance with this Privacy Policy or your provision of personal information to us, you should immediately discontinue using our services and notify us promptly so that appropriate measures can be taken.

If you are the parent or legal guardian of a minor and have any questions regarding the processing of your child's personal information, please contact us using the contact information provided in this Privacy Policy.

VI. Data Security

Security Measures

We implement appropriate physical, electronic, administrative, and technical safeguards to protect the security of your personal information. We make every reasonable effort to ensure that any personal information collected through our Platform is protected against unauthorized access, use, disclosure, alteration, or destruction by unrelated third parties.

The security measures we adopt include, but are not limited to, the following:

(1) Physical Security Measures

Records containing your personal information are stored in secured facilities with restricted physical access.

(2) Electronic Security Measures

Electronic records containing your personal information are stored in computer systems and storage media protected by strict access controls and authentication mechanisms.

(3) Administrative Security Measures

We have established dedicated departments and internal management systems responsible for protecting users' personal information.

Access to your personal information is granted strictly on a need-to-know basis. Only authorized personnel may access your personal information, and such personnel are subject to strict confidentiality obligations under our internal privacy policies.

In addition, we regularly provide training on applicable laws and regulations, privacy protection requirements, and information security awareness. We also conduct periodic emergency response training and drills to ensure that relevant personnel understand their responsibilities and emergency response procedures.

(4) Technical Security Measures

We may employ encryption technologies, such as Secure Socket Layer (SSL) encryption, to protect the transmission of your personal information.

(5) Information Security Measures

To safeguard your personal information, we employ industry-standard security technologies and management practices designed to minimize the risks of unauthorized access, disclosure, alteration, misuse, loss, or destruction.

Such measures include, without limitation:

SSL-encrypted transmission;
Encrypted storage of personal information;
Strict access control over data centers;
Encryption, access control, de-identification, and data masking for Sensitive Personal Information (including biometric information).

(6) Other Security Measures

We regularly review our personal information collection, storage, and processing practices.

Access to your personal information by employees and service providers is restricted based on the principle of necessity, and all employees and suppliers are subject to strict contractual confidentiality obligations.

Reporting Security Vulnerabilities

If you become aware of any security vulnerability affecting our Platform, please notify us immediately so that we may take appropriate remedial measures as soon as possible.

Security Disclaimer

Although we implement the security measures described above, no method of transmission over the Internet or electronic storage can be guaranteed to be completely secure.

Accordingly, we cannot guarantee the absolute security of any personal information transmitted to us through the Platform.

We may periodically update and publish information relating to security risks, personal information security impact assessments, and other security-related information through announcements on the Platform.

Personal Information Security Incidents

If a personal information security incident occurs, we will promptly take appropriate remedial measures in accordance with applicable laws and regulations and, where required by law, notify the relevant regulatory authorities and affected users.

VII. Policy Updates

We may revise this Privacy Policy from time to time.

Without your explicit consent, we will not reduce your rights under this Privacy Policy.

Any updates to this Privacy Policy will be published through our official channels.

If you do not agree with any revised terms, you should immediately discontinue accessing or using the Platform.

Your continued access to or use of the Platform after the updated Privacy Policy becomes effective constitutes your acknowledgment and acceptance of the revised Privacy Policy.

For material changes, we will provide more prominent notice, including, where appropriate, public announcements on the Platform or pop-up notifications.

Material changes include, but are not limited to:

Significant changes to our service model, including the purposes for processing personal information, the categories of personal information processed, or the methods by which personal information is used;
Significant changes in our ownership or organizational structure, including changes to the data controller resulting from mergers, acquisitions, restructuring, or similar corporate transactions;
Significant changes to the primary recipients of personal information through sharing, transfer, or public disclosure;
Significant changes to your rights relating to personal information processing or to the methods by which you may exercise those rights;
Changes to the department responsible for personal information protection, our contact details, or complaint handling channels; and
Circumstances where a personal information protection impact assessment identifies a high level of risk.

VIII. Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy, please feel free to contact us at:Email: support@nodexx.co