Updated on 2024-07-01

Dear users:

Topcredit Technology Limited(hereinafter referred to as "we") respects and protects the privacy of users (hereinafter referred to as "you" or "users"), when you use Topcredit Wallet, we will collect and use your personal information in accordance with this privacy policy (hereinafter referred to as "this policy"). Your personal information and the personal information you provide will be kept strictly confidential. We recommend that you carefully read and understand the entire content of this policy before using the Services (as defined in the Topcredit Wallet Service Agreement). Important information, including disclaimers and other terms, will be shown in bold. This policy can be updated by us online at any time. Once the updated policy is published, it will replace the original policy. If you do not accept the revised terms, please stop using Topcredit Wallet immediately, and your continued use of Topcredit Wallet will be deemed to accept the revised policy. Once the revised policy is posted on Topcredit Wallet, it will automatically take effect immediately. This policy and other relevant regulations apply to Topcredit Wallet and our own DApps on Topcredit Wallet. By accessing, visiting or using the Service, you expressly consent to our collection, storage, use and disclosure of your information as described in this Privacy Policy. Please note that if you disagree with anything in this Privacy Policy, you must not access the Website and/or use the Service.

Ⅰ. Collected Information Please be aware that we collect the following information from you for the purpose of satisfying your service needs in Topcredit Wallet, and we attach great importance to the protection of your privacy. When we collect your information, we will strictly abide by the principle of "lawful, legitimate and necessary". You will need to understand that if you do not provide the relevant information required for our services, your service experience in Topcredit Wallet may be affected as a result. Please note: Your private key, and mnemonics on Topcredit Wallet are not stored or synchronized to our server. We do not provide services to retrieve your wallet password, private key, and mnemonic phrase. In addition to the above, please note that when you use the specific functions of Topcredit Wallet, we will give you a special reminder to collect more personal information from you before actually collecting your personal information. When you jump to a third-party DApp, the third-party DApp may collect personal information from you. Topcredit Wallet does not hold the personal information collected from you by third-party DApps. When you fill in personal information on third-party DApps, you should pay attention to consult the relevant user agreements and privacy instructions of the third-party DApps. We are not responsible for any losses caused by your actions on third-party DApps. To the extent permitted by laws and regulations, we may collect and use your personal information without your authorization and consent under following circumstances: (1) Related to national security and national 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 collected personal information is disclosed to the public with your authorization; (5) Your personal information will be collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels; (6) Necessary for maintaining the security and compliance of services, such as finding and dealing with failures of products and services; (7) Other situations stipulated by laws and regulations. We collect information in the following ways: a. When you voluntarily provide us with information. for whatever reason; b. When you authorize us to obtain your information from third parties; c. Your use of our apps and services; d. When you contact or interact with our employees through various communication channels, such as through social platforms, communication platforms, face-to-face meetings, telephone calls, emails, faxes and other letters; e. When you transact with us, contact us or ask us to contact you; f. When you require to subscribe to our newsletter; g. We copy all or part of your transaction records through the blockchain system. However, your actual transaction records should be subject to the records of the blockchain system;

Ⅱ. How we use your information We will send you timely important notices such as software updates, service agreements and changes to the terms of this policy. We provide you with the "Fingerprint/Face Unlock" option in the"Security and Privacy" portion of Topcredit Wallet, allowing you to manage your digital tokens conveniently and more securely. We process the feedback you submit to us by collecting your disclosed wallet address and mobile device information provided. We collect your personal information for our internal audit, data analysis and research, etc., in order to continuously improve our service level. In accordance with the "Topcredit Wallet Service Agreement" and our other relevant regulations, we will use user information to manage and process users' usage behavior.

Ⅲ. How you manage your information You have the following voluntary control over your personal information in Topcredit Wallet: (1) Topcredit Wallet will show you the information of your imported wallet. Please note that you will be able to transfer and receive assets through the "Assets" section. Please note that in the "Security and Privacy" section of Topcredit Wallet, you can freely conduct the following operations: (a) You may view your mnemonics and private key; (b) In "Security Settings", you can choose to disable the "Unlocking operation required" option, that is, you can choose not to use the verification service to enter Topcredit Wallet; (2) In "Security and Privacy", you can choose to disable the "Face / Fingerprint Payment" option, that is, you can choose not to invoke your biometrics (fingerprint and face) authentication during transactions. Please note that when we collect information from you for a specific purpose, we will give you notice in advance and you have the right to opt out. You agree and acknowledge that when you choose to refuse to provide relevant information, you may not have access to all of the Services or features of Topcredit Wallet. Please note that both you and we have no control over whether your transaction records are made public, because based on the open source nature of the blockchain transaction, your transaction records are open and transparent in the entire blockchain system. Please note that when you use Topcredit Wallet to jump to a third-party DApp, our "Topcredit Wallet Service Agreement" and "Topcredit Wallet Privacy Policy" will no longer apply, and your control over your personal information on the third-party DApp will no longer apply. We recommend that you read and understand its privacy rules and related user service agreements in detail before using third-party DApps. You have the right to ask us to update, change or delete your relevant information. You understand that we may collect your information in accordance with the requirements of Article I, Section (6) of this policy without your authorization.

Ⅳ. We may share or transfer 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 third parties without your consent.
3. If you agree to our disclosure of your personal information to strategic partners or related parties, we may disclose your personal information to such entities. These entities will only use your personal information for the purposes for which you have agreed.
4. You agree that we may disclose or share your personal information with the following third parties: (1) Service providers and data processors that represent us and provide services to us, such as accounting, data processing or management services, website hosting, maintenance and operation services, mail messaging services, analytics services, payments for us transaction processing, marketing, etc.; (2) We may share some or all of your information with our parent company, subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us. If you opt in to receive marketing communications from third parties, we may permit these entities to use your information for their own marketing purposes. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt out by contacting us as provided in the "How to Contact Us" section; and (3) Our consultants and professional advisors (e.g. accountants, lawyers, auditors).
5. Without your prior consent, the company will not share or transfer your personal information to any third party, except in the following cases: (4) The DApps integrated on TopcreditWallet include DApps owned by the company and DApps provided by third-party platforms. DApps provided by third-party platforms are subject to separate terms. Those terms will govern its use. We make no representation as to the quality, suitability or functionality of the DApps. Topcredit Wallet only provides a browser for users to enter these DApps. Before accepting services or conducting transactions on third-party DApps, users should judge and evaluate whether there are risks in the services or transactions provided by the third-party DApps. (1) The collected personal information is disclosed to the public with your authorization; (2) The collected personal information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels; (3) To provide or enforce this policy in accordance with applicable laws and regulations, the requirements of legal procedures, administrative or judicial authorities to protect the rights, property or safety of us or other parties; (4) In the case of mergers and acquisitions, if the transfer of personal information is involved, the company will require the recipient of personal information to continue to be bound by this policy.

Ⅴ. Automatic data collection technology We use automatic data collection technology in our applications. e.g: (1) Cookies (or browser cookies). Cookies are small text files set by the operator of a website or app to identify your browser or device. We may use cookie technology on our applications to store and track information such as the number and frequency of users, distribution of users, and online preferences of users. Cookies do not capture information that can identify you, but the information they collect can help us analyze the usage of the app to improve your experience. You can turn off cookies in your browser settings. However, this may affect the functionality of the app. (2) Network analysis. Web analytics is a method of collecting and evaluating the behavior of web page and mobile application visitors. This includes analyzing traffic patterns, for example to determine how often certain features of a website or mobile application are accessed, or to understand what information or services are of most interest to visitors. Our app uses web analytics services provided by third-party tools.

Ⅵ. How we protect your information (1) If we cease operations, we will stop the collection of your personal information in a timely manner, announce the notice of stopping operation on Topcredit Wallet, and delete or anonymize your personal information held within a reasonable period of time. (2) In order to protect your personal information, we will take data security technical measures, improve internal compliance level, increase internal employee information security training, and set security access rights for relevant data to safely protect your private information. (3) We will push security related information to you in the "Message" section of Topcredit Wallet, and update the information on wallet usage and information protection for your reference.

Ⅶ. Protection of minors We make the following special agreements to protect minors under the age of 18: (1) In the event that the user is a minor, you represent that you are utilizing Topcredit Wallet under the agreement and supervision of a parent or a legal guardian. (2) We suggest that parents and guardians of minors should guide minors to use Topcredit Wallet under the premise of reading this policy, the "Topcredit Wallet Service Agreement" and our other relevant rules. (3) Topcredit Wallet will protect the confidentiality and security of minors' personal information in accordance with relevant national laws and regulations. Ⅷ. Business Transfers; Bankruptcy In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any User information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from Users of the Service to third parties. Other than to the extent ordered by a bankruptcy order or other court, the use and disclosure of all transferred User information will be subject to this Privacy Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

Ⅸ. Disclaimer (1) Please note that after you access a third-party platform or service through Topcredit Wallet, the privacy policy published by the third-party platform or service will apply accordingly. The collection and use of your personal information by this third-party platform or service is not under our control and is not subject to this policy. (2) We cannot guarantee that third-party platforms or services will adopt personal information protection measures in accordance with our requirements. You should choose and use third-party platforms or services carefully, and properly protect your personal information. We are not responsible for the privacy protection of other third-party platforms or services. (3) We will take reasonable security measures to protect your personal information as far as possible under the existing technical level, so as to avoid information leakage, tampering or damage. We transmit data wirelessly, therefore, we cannot ensure the privacy and security of data transmitted over wireless networks.

1. Others(1) As a company providing services to you, we will not proactively provide your personal information to third parties other than those agreed in the agreement, unless we obtain your consent and inform the other party of their identity, contact information, processing purpose, and processing method and so on. If later due to service needs, we will process your personal sensitive information, we will seek your opinion again, and use it after obtaining your consent.

Please understand and note that since the laws, regulations and policies in the field of digital tokens are not yet sound, the digital tokens in this field may have major risks such as inability to cash and technical instability. And the price volatility of digital tokens is much higher than that of other financial assets. We prudently remind you that you should rationally choose to hold or dispose of any digital token according to your own financial situation and risk appetite. The market data function provided by Topcredit Wallet is only a search result of capturing the exchange rate information of digital tokens of some exchanges, and does not represent the latest information or the best quotation. (2) You need to fully understand and abide by all relevant laws, regulations and rules in your jurisdiction and the use of our services. If you encounter any questions about the use of personal information during the use of Topcredit Wallet, please contact us through the "Customer Service" option provided in Topcredit Wallet, and we will try our best to solve your problem in time. (3) Please note that any comment or opinion you express on the platform does not represent the views of Topcredit Technology Limited and we do not assume responsibility for the comments and opinions expressed.