Privacy Policy

Preamble

BitKan highly values the protection of your privacy and personal information. We will adopt the safety precautions to safeguard the protection of your personal info to the extent required by the laws and regulations. During your use of our products and/or services, we might collect and use your relevant info to the extent necessary for us to provide better services for you and other users. We intend to demonstrate through this privacy policy (“Privacy Policy”) how we collect, use, save, share and transfer such info during your use of our products and/or services, and the protective methods that we make available to you relating to access, update, delete and restrictive process of such info.

It needs to be particularly stated that this policy only applies to our products and services and not to services provided by other third parties. For example, we might from time to time introduce third parties other than us and our affiliates to provide products and services, and the personal info that you provide to such third party will be exempt from application of this Privacy Policy.

Before you use our products or services, please make sure that you carefully read and thoroughly understand this Privacy Policy before using relevant products or services. If you have any query, opinion or suggestion, please contact us.

Part I Definition

Personal Info: refers to all kinds of information that can be recorded electronically or through other means, and can independently or collectively with other information identify the personal identity of a natural person, including without limitation, the name, date of birth, identification info, biometric info, address and telephone number of a natural person.

Sensitive Personal Info: refers to the personal info that once leaked, illegal provided or abused might lead to harassment of personal and property safety, detriment to personal fame, physical and mental health, discriminatory treatment, including without limitation, personal ID number, personal biometric info, bank account number, content of communication, health and physiology.

Party II Privacy Policy

This party of Privacy will help you understand the following content:

  1. How we collect and use your personal info
  2. How we use Cookie and similar technologies
  3. How we share, transfer, public disclose your personal info
  4. How we protect and save your personal info
  5. EEA user rights
  6. How we process Minors’ personal info
  7. Notices and amendments
  8. How to contact us

I. How we collect and use your info

Base on the principles of legality, just and necessity, we collect and use your personal info for the purposes stated below:

A. To help become our member

We provide membership service to you through third party platform account and your independently registered account. To become our member and to facilitate us to provide membership service, you need to provide third party platform account, mobile phone number or email account address and create membership account and password. If you only use basic service such as market price watch and news browsing, you don’t have to sign up and provide such info.

If you provide extra info, such as your real name, gender, ID number, contact, it will help us to provide ID verification service. If you don’t provide such info, we will be unable to provide relevant services, but will not affect use of basic functions such as browsing, search.

If you use the services that require third party platform account and independently registered account, we may both use your info in order to ensure you use the same membership in our services.

B. To display and push products or services

In order to improve our products or services, or recommend advertisement, news that you might be interested in, we would extract your browsing and search preference, behavior habits, location info from your browsing and search records, equipment info, and location info, and display, push information and establish indirect user portraits based on feature tags.

C. To provide our products or services

1. Info that you provide to us

To facilitate delivery of our products or services, we might record the info that you provide to us. If we entrust third party to make delivery to you, we would share your info with the third party only upon obtaining your consent. If you refuse to provide your info, we would be unable to deliver relevant services.

2. Info that we collect during use of our services

To provide better user-oriented web presentation, search results for you and evaluate product compatibility, discern account abnormalities, we will collect the info relating to the services you use and the method of use and correlate such info, which includes:

Equipment Info: we will receive and record relevant info of your equipment (including without limitation equipment model, operating system version, equipment setup, UDID and other hardware, software feature info), relevant info of equipment location(including without limitation IP address, GPS location and WIFI access point, Bluetooth, base station and other sensor info) in accordance with the limits of authorization conferred during installation and use of the software.

Log info: when you use our products or services, we will automatically collect the details regarding use of our services and save them as internet log info, including without limitation your search content, IP address, telecom operator, language, date of visit and your visited web history.

Unless otherwise stipulated by laws and regulations or upon your authorization, we will process your personal info in the de-identified and anonymized manner.

When you contact us, we may keep a record of our communication content or contact info and etc. so as to help us to contact you, help resolve your issues or record the processing scheme and outcome of relevant problems.

D. To provide safety safeguard

Please note that in order to ensure the authenticity of member’s identity and to protect better safety safeguard, you can provide us ID info, facial feature and etc. to complete real name authentication. If you refuse to provide such info, you may be denied access to some services, but it will not affect browsing, search services.

In order to enhance the safety for use of services provided by our affiliates or partners or us, protect your personal and property safety and those of other members or the general public from harassment, prevent security risks caused by phishing sites, fraud, network vulnerability, computer viruses, network attack, network intrusion and etc., accurately discern circumstances in breach of laws and regulations or our protocols, we may use or integrate your membership info, equipment info, network log and info obtained from our affiliates, partners upon your authorization or shared as required by law, to comprehensively evaluate your account, verify ID, detect and prevent security incident, and take necessary measures including record, audit and disposal in accordance with laws and regulations.

E. Appraisal

We may use your personal info to appraise effects of our advertisement, promotion and other activities.

F. Questionnaire

We will invite you to participate in questionnaire related to our services. The personal info collected during the investigation shall be used for analyzing and improving our services.

G. To maintain legal and regulatory compliance

Some of our services are subject to laws and regulations requiring us to collect and use your personal identification info, formal identification info, online identifiers, and/or usage data in certain ways. The consequences of not processing your personal info for such purposes is the termination of your account as we cannot perform the services in accordance with legal and regulatory requirements.

EEA Residents: For individuals who reside in the European Economic Area (including the United Kingdom) or Switzerland (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process this personal info to comply with our legal obligations.

H. Other purposes

If we use the info for other purposes not stated in this policy, we will obtain your prior consent.

I. Exceptions to obtaining authorizations

Pursuant to relevant laws and regulations, collection of your personal info under the following circumstances will be dispensed with your authorization or consent:

  1. Relating to national security or national defense security;
  2. Relating to public safety, public health or public interests;
  3. Relating to criminal investigation, prosecution, judgement and execution;
  4. Intended for protection of your personal info, life, property and other major legal rights and interests while your consent is difficult to be obtained;
  5. Collected info made public by yourself;
  6. Personal info collected through public info legally disclosed, such as news coverage, government public info and other channels;
  7. Necessary for execution of contract required by you;
  8. Necessary for maintaining safe and stable operation of products or services, such as discover and resolve product or service malfunction;
  9. Necessary for lawful news coverage;
  10. Necessary for conducting statistics or academic research by academic research institution for the purpose of public benefits while anonymizing the personal info before submitting it to academic institutions;
  11. Other circumstances stipulated by laws and regulations.

If we cease to operate, we shall stop collecting your personal info and send notice of cessation of operation to each user individually. If notice is difficult to send individually, we shall adopt reasonable and effective measures such as public notification and anonymize or delete any personal info held by us.

II. How we use Cookie and similar technologies

A. Cookie

We have established websites for provision of our products and services. To ensure regular and efficient operation of website and provide better user experience and recommend contents that you may find interesting, we may record relevant info in your computer or mobile equipment. Such info may include Cookie, Flash Cookie, or other local storage from your browser or affiliate application (collectively as “Cookie”). The client could store data such as your preference through the Cookie. Please understand that some of our services may be achieved only through use of Cookie. If your browser or its additional services permit, you can modify level of acceptance to the Cookie or deny our Cookie, which may result in safe access to our website and use of our services under some circumstances.

B. Web beacon and pixel tags

Besides Cookie, we may use web beacon, pixel tags and other similar technologies in the client. For example, we can send you emails that may include address link to our website content. If you click the link, we may track such click to help us know your preference for our products or services so that we could proactively improve user experience.

III. How we share, transfer and publicly disclose your personal info

A. Share

1. We will not share your personal info with other companies, institutions or persons, except for the following circumstances:

2. Obtaining express consent. We will share your personal info with other parties when obtaining your express consent.

3. Mandatory requirement. we may externally share your personal info in accordance with laws and regulations, as required by the legal proceedings or administrative or judicial bodies.

4. Affiliate companies. For the convenience of recommending info or services that you may find interesting, protect the personal and property safety of affiliate companies, other members or the public from harassment, your personal info may be shared with our affiliate companies. We only share personal info to the extent necessary (for example, in order to facilitate your use of products or services from our affiliate company, we only share your account info with our affiliate company), if we share your sensitive personal info or affiliate company change the purpose for which personal info is used, we will request your authorization or consent once again.

Partners. For achieving the purposes stated in this Privacy Policy, some of our services may be jointly provided by us and our authorized partners. We may share some of your personal info with our partners in order to provide better client service and membership experience. We only share your personal info on the basis of just, legitimate, necessary and specific purposes and only provide the personal info to the extent necessary. Our partners are not entitled to use your personal info for purposes not related to products or services.

Our authorized partners may include the following kinds:

a. Partners specializing in advertisement and analysis services. Unless upon your permission, we would not share your personal ID info (meaning info that could identify your personal identity, such as name or ID number) with our partners providing advertisement and analysis. We would provide such partners with info relating to advertisement coverage and effectiveness rather than your personal ID info or we would filter such info so that it will not reveal your personal ID.

b. Suppliers, service providers and other partners. We will send info to our suppliers, service providers and other partners that support our business through provision of technological infrastructure service, analysis service, customer service, evaluation effectiveness of advertisement and services, facilitation of payment, conduct of academic research and study.

We would require execution of data protection agreement for companies, institutions and persons that we share personal info with, and require such entity to process personal info in accordance with our confidentiality and safeguarding requirement.

B. Transfer

We will not transfer any of your personal info to any company, institution and persons except for the following circumstances:

1. Obtaining express consent. We will transfer your personal info to other parties when obtaining your express consent.

2. In case merger, acquisition, bankruptcy, insolvency, asset transfer or similar transaction occurs to BitKan platform service provider, if transfer of personal info is involved, we will require successor company, institution and person that keep your personal info to be bound by this Privacy Policy, otherwise we would require such company, institution and person to request authorization and consent from you once again.

C. Public disclosure

We would publicly disclose your personal info only upon the following circumstances:

1. We may publicly disclose your personal info upon your express consent or out of your active choice;

2. If we are certain that you violate laws or regulations or seriously violate relevant rules or protocols in the BitKan platform, we may disclose your personal info, including relevant illegal behavior and punitive measures adopted by BitKan pursuant to relevant laws, regulations or BitKan rules or protocols.

D. Exceptions to obtaining authorization and consent prior to sharing, transferring and publicly disclosing personal info

Sharing, transferring and publicly disclosing personal info under the following circumstances shall be dispensed with your authorization or consent:

  1. Relating to national security or national defense security;
  2. Relating to public safety, public health or public interests;
  3. Relating to criminal investigation, prosecution, judgement and execution;
  4. Intended for protection of your personal info, life, property and other major legal rights and interests while your consent is difficult to be obtained;
  5. Collected info made public by yourself;
  6. Personal info collected through public info legally disclosed, such as news coverage, government public info and other channels.

Pursuant to laws and regulations, share and transfer de-identified personal info while ensuring data recipient unable to recover and re-identify personal info holder shall not be treated as sharing, transferring and publicly disclosing personal info. Record and process such data will not require notification and your separate consent.

IV. How we protect and save your personal info

A. We have adopted reasonable and feasible safeguarding measures to protect safety of your personal info and prevent personal info from unauthorized access, public disclosure, use, modification, damage or loss. We use encryption technology to enhance safety of personal info; we use trusted protection mechanism to prevent personal info from malicious attack; we set up access control mechanism to ensure only authorized personnel can access personal info; and we hold training courses on safety and privacy protection to enhance staff’s recognition of importance for protection of personal info.

B. We have data safety management system that is centered on data and encloses data full life circle, enhancing safety of the whole system from multiple dimensions, including organizational building, mechanism design, staff management, product technology and etc..

C. We will adopt reasonable and feasible measures to avoid collecting irrelevant personal info. We save your personal info within the term necessary for achieving the purposes stated in this Privacy Policy. However, under the following circumstances, we may adjust the term for saving personal info as required by laws and regulations:

  1. To comply with relevant rules under applicable laws and regulations;
  2. To comply with relevant requirements of court judgment, decisions or other legal proceedings;
  3. To comply with requirements of relevant government bodies or legally authorized institutions;
  4. To comply with relevant rules by which we reasonably believe to abide;
  5. To achieve reasonable and necessary purposes including enforce relevant user agreement or this Privacy Policy, safeguard social public interests, protect personal and property safety, other legal rights and interests of our customers, partners, other users, employees and us.

D. We strongly advise you not to send your personal info by means of communication not recommended by BitKan, since internet is not absolutely safe environment. You can establish connection and share with each other through our services. When you establish conversation or share through our services, you can voluntarily choose the object of your communication or sharing, who is able to view your content, contact, exchanged info or shared content and etc..

Please carefully protect your personal info and offer to others where necessary. If you find a leakage occurs to your personal info, especially your account or password, please contact us immediately so that we could adopt corresponding measures based on your application.

Please note, when you voluntarily share and disclose info during use of our services, such info may involve personal info and even sensitive personal info of you and others.

Please use complex password to assist us to protect your account safety. We shall endeavor to safeguard the safety of any info that you sent to us.

V. EEA users & data

A. Direct marketing

If you are a current customer residing in the EEA, we will only contact you by electronic means (email or SMS) with information about our services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.

If you are a new customer and located in the EEA, we will contact you if you are located in the EU by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to use your personal information in this way, or to pass your personal information on to third parties for marketing purposes, please contact us support@bitkan.com. You may raise such objection with regard to initial or further processing for purposes of direct marketing, at any time and free of charge. Direct marketing includes any communications to you that are only based on advertising or promoting products and services.

B. Individual Rights

EEA Residents have the following rights, which can be exercised by contacting us at support@bitkan.com so that we may consider your request under applicable law.

1. Right to access

You are entitled to access your personal info unless otherwise stipulated by laws and regulations. You can access your personal info through the following ways:

Account info: if you intend to access or modify basic personal info in your account, you can carry it out by log into BitKan mobile app.
Search Info: you can access or erase your search results. If you cannot access your personal info through the above ways, you can contact BitKan customer service.

2. Right to rectification or supplement

When you find errors in processing your personal info, you are entitled to request us to rectify or supplement. You can make an application for revision or supplement through the means stated in “A. Right to access” of this clause.

3. Right to erasure

You can request us to erase your personal info under the following circumstances:

a. If our processing of your personal info violates laws and regulations;
b. If we collect and use your personal info without your express consent;
c. If our processing of your personal info seriously violates our agreement with you;
d. If you no longer use our products or services;
e. If we permanently cease to provide products or services to you.

When you request erasure of relevant info, we may require verification of your identity to ensure account safety.

4. Right to withdraw consent

You have the right to withdraw your consent to the processing of your personal info collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of BitKan’s processing based on consent before your withdrawal.

5. Right to restriction of processing

You have the right to restrict or object to us processing your personal info where one of the following applies:

a. You contest the accuracy of your personal info that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information;
b. The processing is unlawful and you oppose the erasure of your personal info and request the restriction of its use instead.
c. We no longer need your personal info for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.
d. You have objected to processing, pending the verification whether the legitimate grounds of BitKan’s processing override your rights.

Restricted personal info shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.

6. Right to object to processing

Where the processing of your personal info is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal info as permitted by applicable law. We can continue to process your personal info if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

7. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

8. Right to lodge a complaint

To ensure safety, you may need to submit written application or use other means to prove your identity. We may request verification of your identity before dealing with your request.
We will respond to your request as soon as practical. If you are not satisfied, you can file a complaint through BitKan customer service.
Please understand that due to technical constraints, legal or regulatory requirements, we may not satisfy all of your demand and we will reply to your request within the reasonable term.

9. Right to data portability

If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.

10. Storage of your personal info

BitKan will try to limit the storage of your personal info to the extent that storage is necessary to serve the purpose(s) for which the personal info was processed, to resolve disputes, enforce our agreements, and as required or permitted by law.

Your rights to personal info are not absolute. Access may be denied when:

a. Denial of access is required or authorized by law;
b. Granting access would have a negative impact on other's privacy;
c. Granting access would have a negative impact on other's privacy;
d. To protect our rights and properties; and
e. Where the request is frivolous or vexatious.

VI. How we process minors’ personal info

Minors shall not create their membership account without consent of parents or guardian. If you are a minor, we suggest you invite your parents or guardians to carefully read this Privacy Policy, and obtain your parents or guardian’s consent before use our service or provide info to us.

For minors’ personal info that we collected during use of our products or services under the consents of parents or guardians, we will use, share, transfer or disclose such info where permitted by laws and regulations, expressly authorized by parents or guardians, or necessary for protection of minors.

VII. Notices and amendments

We may amend this Privacy Policy from time to time. If such amendments materially reduce your rights under this Privacy Policy, we will notify you through display in notable position, email and etc. prior to the effective date of amendment. In such case, if you continue to use our services, it shall be deemed to be bound by the amended policy.

VIII. How to contact us

If you have queries of this Privacy Policy or relevant issues, please send your query to support@BitKan.com.

We will review the issues involved as soon as we can, and will reply to you within fifteen days after verification of your user identity.

Date of Issuance: [03-18],2019