Effective Date: Mar 01, 2020
Who We Are and What We Do
This Policy applies to our operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch that we may subsequently form. Personal Information We Collect
The types of Personal Information we collect and our privacy practices depend on whether you are a customer, user, visitor or employee and the requirements of applicable law.
• Transaction Details. If you make a transaction using the Service, we record the status of the transaction, information about the recipients, your memo (which is not visible to third parties), amount, and additional technical details. We also store the transaction ID that can be used as proof that a payment was made. You should be aware that some information (such as public keys or other unique identifiers) collected using blockchain technologies is stored permanently and/or publicly, and you may not be able to delete such information.
• Nex token Community Programs. From time to time, we may offer you the opportunity to share or promote your interest in our Services on our Site and/or third-party sites through a variety of programs in accordance with applicable law. You should read the privacy policies, platform rules, and program terms carefully to understand the information we and other third parties collect, use and share about you and your rights and obligations. Some programs require us to validate your identity and may require name, email, phone number, country of residence and physical address, proof of address, nationality, government-issued ID, tax identifier, social network IDs, amount of QKC and program points, languages you speak, your date and place of birth and similar data. If you have any questions, please contact us as described below.
• Communications with Us. We may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us.
• Surveys. We or our third-party service providers may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
• Posting. We may offer forums, blogs, or social media pages. When you use these sites and disclose information about yourself, your personal information is collected by us and the third party sites. Depending on the site and your settings, the content you provide on these channels may be considered “public” and may not subject to privacy protections. We are not responsible for the privacy practices of third party sites.
• Registration for Sweepstakes or Contests. We may run sweepstakes and contests. The contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
• Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address; user settings; IMEI; MAC address; cookie identifiers; mobile carrier; mobile advertising and other unique identifiers; details about your browser, operating system or device; location information; Internet service provider; server log information; date, time and pages/features that you visited/requested before, during and after using the Services; information about the links you click and other information about how you use the Services. If you use any of our open source software, we may collect telemetry information such as bandwidth upload and download speeds, the amount of free and used storage space on your device and other statistics about your device. If you use our Site, we will collect metadata about the files you upload for storage, and we will record instances in which you have used your private key to authenticate communications. Information we collect may be associated with accounts and other devices.
• Information from Other Sources. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service.
This supplemental information allows us to verify the information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
How We Use Your Information
• We Process the Personal Information for a variety of business purposes including to: o Manage individual information technology and accounts;
o Respond to questions, comments, and other requests;
o Provide access to certain areas, functionalities, and features of our Services;
o Answer requests for the customer or technical support;
o Sending you technical notices, support or administrative notifications;
o Allow you to register for events;
o Measure interest and engagement in our Site and Services;
o Conduct research for technical development and demonstration;
o Undertake activities to verify or maintain the quality or safety of a Service;
o Improve, upgrade, or enhance the Service;
o Develop new products or services;
o Verify individual identity;
o Communicate with you about your account, activities on our Site and Services and policy changes;
o Process your financial information and other payment methods for products or services purchased;
o Process applications and transactions;
o Debug to identify and repair errors that impair existing intended functionality;
o Prevent potentially prohibited or illegal activities or protect vital interest;
o Enforce our Terms;
o Use for purposes disclosed at the time you provide Personal Information or otherwise with consent;
o Use as necessary to perform a contract, comply with a legal obligation, or to pursue our legitimate interests; or
o Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• We may use Personal Information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interest with your rights. Such uses include:
o To provide you with materials about offers, products, and services that may be of interest, including new content or Services. We may provide you with these materials as permitted by applicable law. Such uses include customizing or tailoring content, advertisements, and offers;
o To notify you about offers, products, and services that may be of interest to you;
o To provide Services to you and our sponsors; and
o Other purposes you consent to or are disclosed when you provide Personal Information.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes as described below.
• De-identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create.
• Sharing Content with Friends or Colleagues. Our Site and Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by us or any other third parties for any other purpose.
Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt-out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
• Operationally Necessary. This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
• Performance Related. We may use technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services; • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign in to our Site or Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising or Targeting Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Site and Services or on third party sites. Third-Party Websites, Social Media Platforms and Software Development Kits
The Services may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such services, you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
Onward Transfer—How We May Disclose Your Information
o Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust PersonalInformation include service providers for IT and related services, payment processing, customer service activities, and the provision of the Site and Services.
• Business Partners. We may provide Personal Information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
• Third-Party Advertisers and Marketers. Through our Services, we may allow third- processes party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site and Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third-party advertising partners, you may follow the instructions below.
• Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information, other account information, and content, if we believe doing so, is required or appropriate to (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
International Data Transfers
You agree that all information Processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the European Union, the United States or other countries. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request.
• General. You have the right to object to or opt-out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Site, Services or other legal purposes as described above.
• Mobile Devices. We may send you to push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
• Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from data partners and other advertising partners that participate in self- regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.aboutads.info/choices/,
www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, and https://youradchoices.ca/choices/.
To separately make choices for mobile apps on a mobile device, you can download DAA’s App Choices application from your device’s app store. Alternatively, for some devices, you may use your device’s platform controls in your settings to exercise choice. Please note you must separately opt-out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.
• Rights of Access, Rectification, Erasure, and Restriction. In accordance with applicable law, you may have the right to: o request confirmation of whether we are processing your Personal Information;
o obtain access to or a copy of your Personal Information;
o receive an electronic copy of Personal Information that you have provided to us;
o ask us to send your Personal Information to another company;
o restrict our uses of your Personal Information;
o seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and o request erasure of Personal Information held about you by us subject to certain exceptions prescribed by law.
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
Security of Your Information
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
The Site and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
HONG KONG Privacy Rights
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.
Human Resources Data
The following section applies to our processing in the context of human resources, recruitment, and applicant consideration.
We collect Personal Information from current, prospective, and former employees, their contact points in case of a medical emergency, and dependents and beneficiaries under any insurance or other similar policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification numbers, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, the contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We Process Human Resources Data for a variety of business purposes including:
• Workflow management, including assigning, managing and administering projects;
• Human Resources administration and communication;
• Payroll and the provision of benefits;
• Hiring and recruitment;
• Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
• Job grading activities;
• Performance and employee development management;
• Organizational development and succession planning;
• Benefits and personnel administration;
• Absence management;
• Helpdesk and IT support services;
• Regulatory compliance;
• Internal and/or external or governmental compliance investigations;
• Internal or external audits;
• Litigation evaluation, prosecution, and defense;
• Diversity and inclusion initiatives;
• Restructuring and relocation;
• Emergency contacts and services;
• Employee safety;
• Compliance with statutory requirements;
• Processing of employee expenses and travel charges; and
• Acquisitions, divestitures, and integrations.
We will use Personal Information we collect for Human Resources activities only for employment-related purposes as more fully described above. If we intend to use this Personal Information for any other purpose, we will notify the individual and provide an opportunity to exercise their rights under applicable law.
• “Personal Information” is any information relating to an identified or identifiable natural person according to applicable law.
• “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction according to applicable law.