Updated on January 16 ，2020

HTX Limited ((hereinafter referred to as "the Platform" or "We") respects and protects Your privacy.

This Privacy Policy provides detailed policies and methods of how we handle our users’ personal data (hereinafter referred to as “this Policy”). “Personal Information” under this Policy means any information which, either alone or in combination with other data, enables You to be directly or indirectly identified, for example, Your name, email address, username, contact details, or any unique identifier such as an IP address, device ID or another online identifier. We are well aware of the importance of the above personal information to You, and sincerely thank You for the trust You show us when You use the services of this Platform. Through this Policy, we will inform You of how the HTX OTC platform collects, stores and protects Your information as well as provides Your information externally and clearly specify Your rights.

This Policy is closely related to Your use of the services of this Platform. In order to ensure that You have full confidence in our handling of personal data, You must carefully read and understand the terms and conditions of this Privacy Policy and make choices as You deem appropriate. Unless You accept, approve and agree to be bound by each of the terms and conditions of this Policy, You may not use our services or any part thereof; if You use our services or any part thereof, You will be deemed as having carefully read and fully understood this Policy, and You have accepted and agreed to this Policy. In this Policy, terms and conditions hereunder that have a significant bearing on Your rights and interests or involve Your sensitive personal information will be presented in bold type in order to attract Your attention.

If necessary, we reserve the exclusive right to update, modify, change, reissue or revise this Policy at any time in the future to meet our needs. You are hereby kindly advised to visit this page regularly and review this Policy from time to time, and make sure that You are fully aware of the currently valid version of this Policy.

1. Applicable Scope of this Policy

This Policy applies to all users of the HTX OTC Platform, including general users, certified Advertisers,and other users.

2.1 Application for Registration

When You register Your account with this Website or use Your account on this Website, You must provide Your personal registration information in accordance with the requirements of this Website, including, but not limited to, Your cyber name, nationality, phone number, email address, and other identification information.

2.2 Real-name Authentication

After You register and log in, You need to enter the "Personal Center" to complete Your real-name authentication. In the process of such real-name authentication, You need to provide the Platform with Your real name, ID card number or passport number.

2.3 Advanced Certification

When Your transaction volume on this Platform exceeds a certain limit, the Platform will require You to undergo advanced certification, in order to ensure the safety of Your assets. You agree that in the advanced authentication process, in addition to providing the information required for the real name authentication, You will also undergo the advanced authentication procedures of "facial recognition" and voice recording, as is required by the Platform. Facial recognition will involve the collection of Your relevant video streams or face images on the Platform. Some of the functions of video authentication will involve access to the voice recording or camera functions. However, your prior consent is required for opening the above functions.

2.4 Security Management

When You use the services provided by this Website or visit this Website, we, in order to ensure Your transaction security and the safe and stable operation of services, will need to automatically receive and record Your web browser information, Your device information, including the device identification information (the type and model of the device through which You log into Your account), Your IP address and records on the web page You request to visit, Your location, network environment, device fingerprint information, service log information, software information, location information, etc.

2.5 Keeping and Inquiry of Transaction Records

The data collected by this Website in connection with Your transactions on this Website include but are not limited to transaction records. If You need to access Your order transaction records, You can query Your personal transaction details in the "Order Records" section of the Platform, including the cyber name of the transaction counter-party, the time when an order is placed, the serial number of the order, the unit price in the transaction under the order, the type and quantity of digital assets under the order, Payment method, the payment reference code, inter alia.

In particular, in order to save the records and screengrabs of Your online chat with Your transaction counter-party after the order is placed, which may be used as proof of transaction in any possible subsequent dispute, You need to activate the camera function permission when using the corresponding function.

2.6 Application for Advertiser Certification

When You apply for certification of Your "advertisement placement qualification" on this Website, You may be asked by the Platform to provide Your mobile phone number, email address, WeChat account number; Your emergency contact and his/her telephone number and relationship with You; address of Your registered permanent residence; a photocopy of the page specifically on You in Your household registration booklet; certificate of Your address (e.g., housing property ownership certificate, housing rental contract or utility bill); video proof (to be recorded in accordance with the sample) and other possible materials required by this Platform for compliance and safety purposes.

2.7 Information Obtained from Third-party Partners

We may obtain information that You generate or share when using a third-party partner’s services. For example, we or our third-party partners may collect Your information by deploying secure Cookies and related similar technologies, so as to provide You with a more personalized user experience and the necessary technical features to maintain the services. We will strictly require our third-party partners（SDK: AliyunSlsObjc、JSPath、Tinker、Bugly、Getui、Zendesk、Aliyun Slider、Aliyun face++） to comply with all relevant provisions of this Policy, but cannot guarantee the behavior of the third-party completely. The platform is not responsible for the leakage of user information caused by third parties

2.8 Information obtained by processing customer complaints in which the Users require the Platform to intervene

In the course of using the services of this Platform, if You encounter disputes such as where "payments are made and yet digital assets are not received" or where "digital assets have been released yet the payment fails to be received", the Platform may, in handling such dispute, require You to provide detailed transaction proof (such as transaction details, proof of payment, proof of currency transfer, information on the receipt and payment accounts) on the basis of the actual circumstances.

2.9 Verification of important operational conducts

In order to protect Your account and assets, we need to verify Your identity or legitimacy of asset source, when You perform some important account operations (e.g., recovering Your password, reporting the loss of Your account, freezing trading fund, opening an account and asset account certification)or Your transaction may be suspected of money laundering; therefore, You may need to provide us with a photo showing You holding Your identity card, transaction vouchers and other identification materials that can identify You based on Your consent during the course of Your business transaction. If You do not agree to provide the above information, You will not be able to complete specific operations, however, Your access to other services provided by us will not be affected.

2.10. In accordance with relevant laws and regulations as well as state standards of relevant jurisdictions, we may collect and use Your personal information without obtaining Your approval under any of the following circumstances:

(1) where our collection and use of Your personal information is directly related to state security and/or national defense security;

(2) where our collection and use of Your personal information is directly related to public safety, public health and major public interests;

(3) where our collection and use of Your personal information is directly related to a criminal investigation, prosecution, trial and execution of judgment.

(4) where our collection and use of Your personal information is for the purpose of protecting the life, property or any other major legal interests of You or any other person, yet it is unlikely to obtain Your consent;

(5)where Your personal information collected by us is disclosed to the public by Yourself;

(6) where Your personal information collected and used by us is gathered from legally and publicly disclosed information, e.g., legitimate news reports, government information disclosures, inter alia;

(7) where our collection and use of Your personal information is necessary for signing and performing contracts in accordance with Your requirements;

(8) where our collection and use of Your personal information is necessary for maintaining the safe and stable operation of the services provided hereunder, such as uncovering and dealing with the faults in the services; and;

(9) other circumstances prescribed by applicable laws and regulations.

2.11 This Website legally obtains Your other personal information.

Please understand that the services we provide to You are constantly updated and developed. If You choose to use any other service that has not been covered in the above description, and we need to collect Your information based on such service, we will explain to You the scope and purpose of such information collected through page prompt, interactive processes, agreements and pop-up prompt, to obtain Your consent to such collection. We will use, store, provide and protect Your information in accordance with this Policy and the corresponding user agreement; if You choose not to provide the above-mentioned information, You may be unable to access one or some of the services; however, Your access to other services provided by us will not be affected. In addition, third parties may provide services to You through HTX OTC, and in this case, when You access the service page operated by a third party, please note that the relevant services are provided to You by such a third party. If a third party collects personal information from You, it is recommended that You carefully review the privacy policy or agreement of the third party.

1. Purpose of Our Collection of Your Personal Information and Our Use Thereof

We collect personal information for specific purposes, including but not limited to:

3.1 Process Your registration and provide You with the services offered by this Website;

3.2 Notify You of any change in our services;

3.3 Report to the relevant regulatory authorities in accordance with the requirements of the competent authorities of the relevant sovereign countries or regions;

3.4 When You use the services provided by this Website, this Website will use Your information for legitimate purposes, such as identity authentication, customer service, security, fraud monitoring, marketing and promotion, archiving and backup, or jointly promoting this Website with a third party to ensure the safety of the products and services provided by this Website to You;

3.5 Collect and process information to help this Website design new products and services and improve the existing services provided by this Website;

3.6 In order to enable You to know the specific content of the services provided by this Website, You agree to allow this Website to send You marketing information, commercial electronic information and advertisements related to You, in replacement of general and comprehensive advertisements;

3.7 Invite You to participate in the survey related to the services provided by this Website;

3.8 Data analyses carried out in cooperation with government agencies, public agencies, associations, etc.;

3.9 Handle bookkeeping affairs and collecting any fee;

3.10 Personalize Your experience (your information will help us better respond to Your personalized needs);

 3.11 For all other legitimate purposes and other purposes authorized by You.

1. Protection and Storage of Your Personal Information

4.1 We will provide reasonable and feasible measures, procedures and steps to protect Your personal data, including reasonable physical, electronic and management measures to protect Your personal data. However, there is no method of transmission over the Internet or electronic storage that is absolutely secure. Therefore, despite our best efforts, we cannot guarantee that these measures will provide completely risk-free protection.

4.2 We only keep Your personal information for a period of time as is necessary for the purposes stated in this Policy and within the time limit stipulated by applicable laws, regulations and regulatory requirements. The above data are stored overseas for a minimum term of five(5) years.

4.3 In order to ensure Your information security, we are committed to using various currently available general security technologies and supporting management systems to minimize the risks that Your information may be disclosed, damaged, misused, accessed without authorization, disclosed without authorization or altered. For example, the Secure Socket Layer (SSL) software is used for encrypted transmission, encrypted information storage and strict restriction of data center access. When transmitting and storing sensitive personal information (including personal biometric information), we will adopt security measures such as encryption, authority control, removal of identification marks, and de-sensitization, inter alia.

4.4 We have set up relevant safety and risk control departments to protect the users' information, and have established relevant internal control systems, adopting the principle of minimum sufficient authorization for staff who may come into contact with Your information. We will provide sustained training to our staff on relevant laws and regulations, privacy and safety guidelines, enhance publicity and education on safety awareness, and organize our relevant internal personnel to carry out emergency response training and emergency drills on a regular basis, so as to enable them to fully understand their job duties and emergency response strategies and procedures. In addition, we will regularly review our personal data collection, storage and processing processes. Furthermore, we will limit the access of our employees and suppliers to Your data in accordance with the principle of “as necessary”, and our employees and suppliers must abide by strict contractual confidentiality obligations.

4.5 You must properly keep Your account information, transaction password and other identity elements. When You use the Platform services, we will identify You by Your login name and other identity elements. If You disclose any of the above-mentioned information, You may suffer losses and be in a disadvantageous position. If You find out that Your login name and/or other identity elements have been or may have been disclosed, please contact us promptly so that we can adopt appropriate measures in time to avoid or reduce the losses.

4.6 After You terminate Your use of the Platform services, we will stop collecting and using Your information, unless any of the applicable laws, regulations or regulatory authorities requires otherwise. If we stop operation, we will stop collecting Your personal information in time, notify You of our termination of operation through a notice specifically delivered to You or by public announcement, and will delete or anonymize Your personal information we hold.

4.7 The foregoing provisions may be inapplicable when You visit any other website maintained by a third party. Your visit to such third-party websites is not protected by this Policy. In this case, please check and read such third party's privacy policy. The websites of these third parties are not owned or controlled by us. We have not authorized these websites to collect any personal information from You. Therefore, we do not assume any responsibility for any and all loss caused by the exposure or use of Your personal data on such third-party websites or the practices or policies of such third-party websites.

4.8 Access to Your personal information as is kept by us is strictly confidential, and such access is subject to approval by relevant management departments of HTX OTC. Only relevant personnel who "need to know" Your personal information can obtain such approval.

For Users in the European Economic Area (EEA) Only

We will adopt all reasonable and necessary steps to ensure that Your information and materials are handled safely in accordance with the provisions of this Policy. All the information and materials You provide to us are stored on our secure server. When we transfer our data to a place outside the European Economic Area, we will ensure that adequate safeguard measures are taken. Please contact us if You want to know more about the specific mechanism we use to transfer Your personal information out of the European Economic Area.

1. Disclosure of Your Personal Information

5.1 We may disclose Your personal information to the following parties (they may be located outside Your jurisdiction or use Your personal information outside Your jurisdiction), provided that such parties ensure that Your personal information receives protection equivalent to or substantially identical to the privacy obligations under this Policy:

• Any of our affiliated companies (including our holding companies, subsidiaries, affiliated companies, companies controlled by us, or companies that are under common control by a third party with us, our employees, representatives, our ultimate holding company and subsidiaries thereof); in addition, such affiliated company cooperates with or provides relevant services on behalf of HTX OTC.
• If HTX OTC or all of its assets are acquired by a third party, the personal information held by HTX OTC on its customers will be part of such transferred assets.
• Banks, companies issuing credit card/payment cards or other financial institutions, which are necessary for establishing and supporting any payment You request or purchase;
• When we are obliged to disclose or share Your personal information in order to comply with any legal obligation, or to implement or apply the terms and conditions of the privacy policy and other agreements, or to protect the rights, property or safety of us, our customers or any other person. We reserve the right to share current and historical bids, inquiries and market prices, opening and closing prices, high-low prices, transaction prices, estimated and actual transaction volumes, settlement prices and other aggregated data and information related to digital assets traded on this Website.
• Any other legal entity, government department, competent authority or stock exchange, and for which such disclosure is mandatory or is required by any of the applicable regulations or contractual obligations, or is required by law, or is carried out pursuant to court orders or rules of any competent stock exchange (whether domestic or foreign).

5.2 In accordance with relevant laws and regulations and relevant regional and national standards, we may collect and use Your personal information in accordance with law without Your consent under any of the following circumstances:

(1) where our collection and use of Your personal information is directly related to state security and/or national defense security;

(2) where our collection and use of Your personal information is directly related to public safety, public health and major public interests;

(3) where our collection and use of Your personal information is directly related to a criminal investigation, prosecution, trial and execution of judgment.
(4) where our collection and use of Your personal information is for the purpose of protecting the life, property or any other major legal interests of You or any other person, yet it is unlikely to obtain Your consent;

(5)where Your personal information collected by us is disclosed to the public by Yourself;

(6) where Your personal information collected and used by us is gathered from legally and publicly disclosed information, e.g., legitimate news reports, government information disclosures, inter alia;

(7) where our collection and use of Your personal information is necessary for signing and performing contracts in accordance with Your requirements;

(8) where our collection and use of Your personal information is necessary for maintaining the safe and stable operation of the services provided hereunder, such as uncovering and dealing with the faults in the services; and;

(9) other circumstances prescribed by applicable laws and regulations.

5.3 Except for circumstances under Clauses 5.1 and 5.2 above, in no event will we provide Your personal information to any other third party unless we obtain Your explicit prior consent thereto, provided, however, Your anonymous personal information may be disclosed, that is, Your identity cannot be ascertained if such personal information is disclosed.

5.4 You hereby agree that from time to time we may use the personal data You provide to us to provide direct sale newsletters to You, and we can promote products and services to You, our subsidiaries/affiliates, our partners or third-party suppliers.

5.5 Owing to the global nature of the internet infrastructure, the information You provide to us may be transferred or transmitted to countries or places outside Your jurisdiction that do not provide protections similar to those provided by Your jurisdiction. However, Your information as is mentioned above may be used to improve security measures and monitoring procedures. Upon Your providing Your Information to us, You hereby consent to such transmission and transfer.

1. Your Rights to Your Personal Information Held by Us

For all users:

You can submit a written application to the following person to access and verify Your personal data held by HTX OTC.

For Users in the European Economic Area:

To Your personal information kept by us, You have a number of rights, including:

• You have the right to access, modify or update Your personal information that may be held by HTX OTC;
• You have the right to limit the right to process Your personal information, e.g., when the information is inaccurate or we no longer need to process such information, or when You have exercised the right to object to our processing of such information;
• You have the right to object to our use of Your personal information for direct marketing purposes at any time, and You also have the right to object to our processing of part or all of Your personal information under other circumstances (and to require us to delete such information).
• If You no longer want to use the services hereunder, You have the right to migrate Your data to a new service provider.
• If You believe that we have infringed upon any of Your rights, You have the right to file a complaint. In this case, we encourage You to contact us at [email protected] first, so that we can try to resolve the issue or dispute informally.

In order to guarantee Your above rights, we may request You to provide us with some information to help us confirm Your identity, which is a necessary operation intended to ensure that Your personal information will not be disclosed to any person who has not the right to receive it. We will exert our best efforts to respond to all reasonable requests within fifteen(15) working days. In some cases, however, if Your request is particularly complex, or You have made many requests, we may need more than a month to respond to them. In this case, we will inform You and keep You updated on the progress in such response.

VII Cookies

• When You use this Website, You agree that we start using cookies to track Your every action and collect and keep all the information You leave, including but not limited to Your IP address, geographical location, inter alia.
• When You visit our website, we will use Google Stats via cookies to record our performance and check the effect of online advertising. Cookies are small amounts of data sent to Your browser and stored on Your computer hard drive. Cookies can only be sent to Your computer hard disk when You use Your computer to access our website.
• Cookies are often used to record the habits and preferences of visitors when they visit various items on our website. The data collected via cookies are anonymous collective statistics and do not contain personal data.
• Cookies cannot be used to obtain data on Your hard disk, Your email address, or Your personal data; instead, they enable the website or service provider’s system to recognize Your browser and capture and remember information. Most browsers are preset to accept cookies. You can choose to set Your browser to refuse to accept cookies or to notify You as soon as cookies are installed. However, if Your browser is preset to prohibit cookies, You may be unable to start or use some features of our website.

VIII Access to and Correction and Deletion of Your Personal Data

Upon Your request, You have the right to obtain a copy of Your personal data and to determine whether the information we have about You is accurate and up-to-date. If any of Your personal data is not accurate, You can request to update Your information. You can also request for the deletion of Your personal data, provided, however, we may reject Your deletion request in some cases, e.g., where such rejection is required by law or for other legal purposes. For data access, correction or deletion requests, please contact us at [email protected].

In response to an application for access to or correction or deletion of data, we will verify the identity of the applicant to ensure that such an applicant is legally entitled to make such an application. Although our goal is to respond to such an application on a gratuitous basis, we reserve the right to charge You a reasonable fee if Your request is repeated or onerous.

If You confirm to terminate the use of the Platform’s services and need to have Your account canceled, You can either visit the relevant function interface or directly contact our customer service department to have Your account canceled. If You meet the agreed conditions for account cancellation and have Your HTX account canceled, we shall nonetheless store the information that is provided by You or is generated during Your use of HTX OTC services, as is required by competent regulatory authorities, and we shall cooperate with the inquiry by the competent authority into such information during the term of our storage of Your information.

1. Protection of Information of Minors

9.1 This Website does not collect personal information of minors strictly. If we find out or suspect that the user is Minors according to the relevant jurisdiction. we will ask the user to close his/her account and will not allow the user to continue buying or selling digital currency. We will delete the relevant information of such users as soon as possible. If You know that any person who is under the age of 14 uses our services, please let us know so that we can take action to prevent them from accessing our services.

9.2 If You are a minor between 16 and 18 years old( (the person who has reached the age of 16 but is regarded as a person with full civil capacity is excluded) ), it is recommended that Your parents or guardians read this Policy and use our services or provide us with Your information subject to the consent of Your parents or guardian. If we collect Your information with the consent of Your parents or guardians, we will only use or disclose such information when it is permitted by law, expressly approved by Your parents or guardian or is necessary for protecting Your rights and interests. If Your parents or guardian disagrees with Your use of our services or You're providing us with information in accordance with this Policy, please stop using our services promptly and inform us in time so that we can take corresponding measures.
9.3 If You are the parent or guardian of a minor, please contact us through the contact information under Article 10 hereof when You have any questions in connection with the information processing of the minor of whom You are a parent or guardian.

X.How to Contact Us

If You have any questions about this Policy or have any complaints or opinions about our processing of Your personal information, please contact us at [email protected]; we only publish announcements and information through the effective contact information on this Website or by posting announcements on this Website; therefore, we shall not be held liable for any and all damages or losses You may sustain from Your trust in any information that is not obtained from either of the aforementioned channels.

Customers in the European Economic Area (EEA) only:

If You have any questions about the way in which we handle Your personal information, please contact our data protection officer at [email protected].

1. This Policy shall come into force and become applicable as of the date when the Website releases the updated latest version hereof. This Policy will be adjusted accordingly with the changes in business development, purposes and relevant contact information. However, if the adjustment is not timely, please refer to the announcement on the relevant service page of the Website. The right to interpret this Policy belongs to HTX OTC. If You have any comments, please contact us in time. Thank You!