IMTOKEN PTE. LTD. (“imToken” “we”, “us” or “our”) respects and protects the privacy of Users (“you”, “your” or “Users”) and User control over data. imToken minimizes the collection of personal information due to the nature of decentralization and we do not collect your private keys in any circumstances. When deemed necessary to provide you with a greater user experience, imToken may collect, use, disclose and process your personal information, in accordance with this Privacy Policy (“Policy”) when you:

• access or use our website, applications, and support; and/or
• provide us with your personal information, regardless of the medium through which such personal information is provided.

Any discrepancy between the definitions of any defined term used in this Policy and the imToken Terms of Use, the definition of any defined term used in this Policy shall prevail.

By providing us with your personal information, you consent to our collection, use, disclosure (including transfer) and processing of your personal information in accordance with this Policy. PLEASE DO NOT PROVIDE ANY PERSONAL INFORMATION TO US IF YOU DO NOT ACCEPT THIS POLICY.

Our applications may link to third-party websites, apps, or smart contracts not managed by us. These links are for your convenience. When using third-party services, imToken's Terms of Use and this Policy will no longer apply.

We reserve the right to update this Policy online from time to time, without notice to you, and the revised Policy will come into effect and supersede the older versions once posted on our Website or Applications. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. The revised Policy will apply to personal information provided to us previously. IN PARTICULAR, IF YOU DO NOT ACCEPT THE REVISED POLICY, PLEASE IMMEDIATELY STOP YOUR USE OF THE WEBSITE AND APPLICATIONS, AS YOUR CONTINUED USE OF OUR WEBSITE OR APPLICATIONS WILL BE REGARDED AS YOUR ACCEPTANCE OF THE REVISED POLICY.

How Do We Collect Information

• You provide your personal information to us through your engagement with the Products
• You contact us or interact with our employees through various communication channels
• You authorize us to obtain your personal Information from a third party
• You opt-in to be included in an email, notification or contact list
• We may collect certain information automatically due to your visit or use of the Products
• We may receive from affiliates where you have agreed based on the affiliates terms of use

What Information Do We Collect

• User-Generated Data: We collect data related to the blockchain addresses and transactions that you initiate or engage with through our product.
• Browser Information for Analytics: To enhance your experience, we gather information about your browser interactions for analytical purposes.
• IP Address Handling: For security, to prevent malicious activities, and to comply with legal standards, we might temporarily process or store your IP address.

While we minimize the collection of personal information, in order to satisfy your needs or requests for specific product functions, we may collect personal information including but not limited to your name and contact details such as telephone number, email address, or any additional personal information.

We do not collect financial payment or banking information, however, certain features provided by third-parties may necessitate you submitting this information.

How We Use Your Information

We collect, use or disclose your personal information for one or more of the following purposes:

• to provide you with products and/or support that you request for;
• to create your account or profile, if required, for your use of the product;
• to improve your experience with the product and enable you to interact with Third Party Platforms;
• to manage your relationship with us;
• to associate your wallet by the unique serial number of your mobile device;
• to push important notifications to you, such as software updates, and terms and policy changes;
• to assist with your enquiries, feedback, complaints and requests;
• to notify you of our products, programmes, events and promotions;
• to resolve any disputes, investigating any complaint, claim or dispute;
• to conduct our internal audit, behavior tracking, data analysis and research;
• to comply with our obligations in accordance with laws, regulations and to cooperate with regulatory authorities;
• to comply with international sanctions and applicable regulation for securities and to counter money-laundering or financing of terrorism;
• to enforce obligations owed to us, and contractual terms and conditions; or
• any other reasonable purposes related to the aforesaid.

Accuracy of personal information

We generally rely on personal information provided by you (or your authorised representative). In order to ensure that your personal information is current, complete and accurate, please update us if there are changes to your personal information by informing our Data Protection Officer at: [email protected].

How You Control and Update Your Own Information

You are entitled to control your personal information provided to imToken. You are also responsible for ensuring that all personal information that you provide to us is true, accurate and complete. Our applications may provide features for you to exercise the controls mentioned under this section. In other cases, if you want to exercise these controls, please contact our Data Protection Officer at: [email protected]. We will respond to your request as soon as reasonably possible.

If you choose not to provide us with the personal information we require, it may not be possible for you to use the Applications or for us to contact you, or provide products or support which you need from us.

• Right to Access or Right to Know: You have the right to access your personal information and request details on our processing, including why we process it.
• Right to Rectification or Correction: You have the right to correct, update, or complete inaccurate or incomplete personal information.
• Right to Erasure or Deletion: You can request the anonymization, erasure, or deletion of your personal information if no overriding legitimate interest exists.
• Right to Restrict Processing: You have a right in certain circumstances to stop us processing your personal information other than for storage purposes.
• Right to Portability: You may import your other wallets into imToken and export your wallets from imToken to other token management wallets.
• Right to Withdraw Consent: You have the right to withdraw consent for processing at any time, without affecting previous lawful processing.
• Right to Opt Out of Targeted Advertising, Sale, or Sharing: You may request the cessation of personal information use for targeted advertising.

Information We may Share or Transfer

In order to provide the Product Services, and with better and more secure experience, we must share your personal information in certain cases. This includes sharing your personal information within our Group Entities, with our Service Providers and the other third parties. We do not sell, trade or otherwise transfer your personal information to third parties without your consent.

• If you have consented to our disclosure of your personal information to our strategic business partners and associates, we may disclose your personal information to them. They will use your personal information only for the purposes you have consented to.
• You agree that we may disclose or share your personal information with third parties such as:
  • service providers and data processors working on our behalf and providing services to us such as conducting know-your-customers checks, know-your-transactions check, accounting, data processing or management services, website hosting, maintenance and operation services, e-mail message services, analysis services, handling of payment transactions, marketing etc; and
  • our consultants and professional advisors such as accountants, lawyers, auditors, etc.
• To the extent permitted by applicable laws and regulations, imToken may collect and use the personal information in the following circumstances without your prior consent or authorization:
  • information related to national security and national defense;
  • information related to public security, public health, significant public interests;
  • information related to criminal investigation, prosecution, trial and enforcement;
  • personal information in the public domain;
  • personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
  • personal information necessary to maintain the security and compliance of products, such as to detect or to solve the malfunction of products;
  • in the case of mergers and acquisitions, if transfer of personal information is involved, we may require the receivers of personal information to be continuously bound by this Policy; or
  • other circumstances permitted by laws and regulations.

Automatic Data Collection Technologies

We use Automatic Data Collection Technologies on our Applications. Examples of such technologies include:

• Cookies (or browser cookies). Cookies are small text files which are set by a website or application operator so that your browser or device may be recognised.

  • We may make use of cookies on our Websit or Applications to store and track information such as the number of users and their frequency of use, profiles of users and their online preferences. Cookies do not capture information which would personally identify you, but the information collected may be used to assist us in analysing the usage of our Applications and to improve your online experience with us.
  • You can control the use of cookies through your browser settings. Most browsers allow you to block cookies, delete cookies, or set preferences for certain websites. However, this may affect the functionality of the Applications.

• Web analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and mobile applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or mobile application, or to find out what information and functions our visitors are most interested in. The web analytics function on our Applications are provided by third-party service providers.

How We Protect Your Personal Information

• If imToken ceases operation, we will stop the collection of your personal information, and take steps to delete or anonymize your personal information held by us within a reasonable period.
• To protect your personal information, we may adopt data security techniques, improve internal compliance levels, provide security training for our staff, and set security authority for access to relevant data to protect your personal information.

Data Security Safeguards

We are committed to protecting the security of your personal information. We have implemented appropriate technical and organizational measures to protect your personal information from unauthorized access, disclosure, use, alteration, destruction, or accidental loss. These measures include:

• Encryption of sensitive data
• Secure access controls
• Regular security audits, penetration testing and vulnerability assessments
• Employee training on data protection
• Incident response plans
• Data backup and recovery procedures

Data Breach Notification

In the event of a data breach that poses a high risk to the rights and freedoms of individuals, we will promptly notify the affected individuals and the Personal Data Protection Commission (PDPC) as required by applicable laws and regulations. The notification will include details about the nature of the breach, the types of personal data affected, and the steps we are taking to mitigate the impact of the breach.

Retention of personal information

We will cease to retain your personal information, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

We may retain your personal information for as long as it is needed in relation to a legal claim, complaint, litigation or regulatory proceedings, in line with imToken’s data retention policy requirements.

Disclaimer

• After you use a Third-Party Service, you acknowledge that this Policy no longer applies to the collection, use, disclosure and transfer of your personal information by these third parties. We are unable to guarantee that any third parties will implement reasonable security measures to protect your personal information.
• You are solely responsible for your use of Third-Party Service and agree that you will not hold imToken liable for any damages incurred or injuries inflicted as a result of the collection, use, disclosure and transfer of your personal information by these third parties.
• YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IMTOKEN WILL ADOPT MEASURES AS REASONABLE AS POSSIBLE TO PROTECT YOUR PERSONAL INFORMATION UNDER CURRENT TECHNIQUES ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS, TO AVOID THE DISCLOSURE, TAMPERING OR DAMAGE OF INFORMATION. SINCE IMTOKEN TRANSFERS DATA WIRELESSLY, IMTOKEN MAKES NO GUARANTEE ON THE PRIVACY AND SECURITY OF WIRELESS INTERNET DATA TRANSFERRING.

Governing Law and Dispute Resolution

• You shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of the products provided by us.
• This Policy shall be governed by and construed in accordance with the laws of the Republic of Singapore.
• In the event of any dispute arising out of or in connection with this Policy, including any question regarding its existence, validity or termination, the Parties shall first seek settlement of that dispute. In the event that such dispute is not resolved within a period of thirty (30) days from the commencement of such settlement process, such dispute shall be referred to and finally be resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be . incorporated by reference in this clauseThe tribunal shall consist of one (1) arbitrator to be appointed by the Chairman of the SIAC. The language of the arbitration shall be English. Each of the Parties irrevocably submits to the non-exclusive jurisdiction of the courts of Singapore to support and assist the arbitration process pursuant to the foregoing of this paragraph, including if necessary the grant of interlocutory relief pending the outcome of that process.
• Any translated versions of this Policy are provided for the convenience of Users, and are not intended to amend the original English version of this Policy. If there is any discrepancy between the English version and non-English version of this Policy, this English version shall prevail.