Ubox (hereinafter referred to as “Ubox”, “we”, “us”, or “our”) is fully aware of the importance of privacy to you and will do our best to protect your privacy and provide you with more secure and reliable services.
- How Ubox Collects and Use Your Personal Data
Ubox collects and uses your personal data in accordance with applicable laws and regulations, the principles of legitimacy, necessity, and good faith, and this Policy. We collect your information for the purposes of providing you with products and services, improving our Site and services, offering better customer service support, sending periodic account-related information and updates, and providing information related to our company, Site, products, and services. The following are examples illustrating how we collect and use your person data:
- When you register for an account with us, update your account information, accept “Ubox User Agreement”, use our products or services, subscribe to our newsletters, or fill out and submit a form as requested, we may collect your personal data, including login information (username), name, email address, phone number, IP address, and other information you provide to us;
- If you use our Site to buy, sell or transfer digital assets, we may collect your real name, ID number, and other identity information required to provide blockchain-based services and anti-money laundering laws and regulations and verify your identity. For compliance purpose, we may also collect your financial information and documents, such as your source of funds or assets involved in transactions on our Site, and/or source of wealth. If you are a seller of digital assets and need to receive payment, we may also collect your bank card information (bank, bank location, card number, and bank reserved mobile phone number), and share this information with third-party payment companies with your consent, if necessary. We may also collect your blockchain address, which may become your personal information when you use our services;
- When you use our Site, products, and services, we may automatically collect and record information about how you use our products and services, including but not limited to device characteristics, IP address, access date and time, log information, and location information and image and video information authorized by you;
- When you use the software upgrade function, we may collect your system and access permissions so that our system can verify your identity and notify you of software version updates. Also, to continually improve product design and better serve you, we may collect device identification codes (which can be reset by reinstalling related software), usernames, and IP addresses to track usage of our Site’s various features;
- During the provision of services and products to you, we may use the contact details you provided when using our Site or related products and services to send you notifications, such as message push notifications, security verifications, user experience surveys, and notifications about services, products, features, or activities that may interest you. If you do not wish to receive such messages, you can unsubscribe by using the method provided in the SMS message or contact us directly to unsubscribe;
- To better understand how you use our Site, products, and services, you can submit feedback through our feedback feature. When you submit feedback, we may collect relevant images, email addresses, your account number, and other personal data required so that we can process your feedback in a timely manner;
- When you use or access some of business functions of our Site, you may authorize us to access your system permissions, including but not limited to: camera, microphone, system album (if photos are stored in an external storage device, we may access photo information in the external storage device), and location information. If we access these types of system permissions, we will obtain your consent in advance, and you can also set your system permissions to open or close them;
- If any abnormalities or crashes occur while you are using our Site or services, and when you restart, our system will upload error logs to help us improve and optimize the service experience. The error log contents include crash information, crash time, device model, device operating system, and the version number of the APP or software used. You can turn on or off the sending of error logs;
- During your use of our Site, products, and services, we may also collect non-identifying information about you. Non-identifying information refers to information that cannot be used to identify an individual. For example, we may collect partial information about the pages currently visited, such as the visited pages and the response events of the operations. The purpose of collecting this information is to understand how users use our Site, products, and services so that we can improve them and better meet users' needs. We may independently decide to collect, use, process, transfer, or disclose non-identifying information for other purposes. We will try to isolate your personal data and non-identifying information and use them separately. If personal data is mixed with non-identifying information, it will still be considered personal data processing;
You acknowledge and agree that the services and products we offer to you are constantly being updated and changed. If the information and usage methods required for a certain function, service, or product are not described in this Policy, we will explain them to you separately through page prompts, website announcements, etc., and obtain your prior consent before collecting your information. We will use and store your information in accordance with this Policy. If you choose not to provide the aforementioned information, it may result in your inability to access or use certain services or parts thereof.
- How Ubox Secures Your Personal Data
Ubox places great importance on the security of your personal data. We use appropriate physical, electronic, management, and technical security measures to protect your personal data from unauthorized access, disclosure, use, modification, damage, or loss. For example, we develop information security policies and processes that comply with industry and international standards, and continuously improve and update them based on evolving standards and requirements. We deploy access control mechanisms to ensure that only authorized users can access your personal data. We use encryption technology to ensure the confidentiality of data, and protective mechanisms to prevent data from being maliciously attacked. We require all users who access your personal data to sign relevant confidentiality agreements and assume confidentiality obligations accordingly. Additionally, we hold regular and irregular security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal data.
Please be mindful of protecting your login name, password, and other information when using our Site, products, and services. Once you disclose such information, you may suffer losses and other adverse effects. If you suspect or have discovered that your login name, password, and other personal information may have been leaked, please contact us immediately so that we can take appropriate measures to prevent or mitigate any related losses. We will not be responsible for any personal data leaks caused by your own actions or inactions.
In addition, you acknowledge and agree that despite our efforts to protect the security of your personal information and to implement and continuously improve the aforementioned security measures, we cannot guarantee the absolute security of your data.
- How Ubox Disclose Your Personal Data
We will not sell, trade or assign your personal information to any third parties. In the process of cooperating with third parties, we will comply with legal requirements, handle relevant data in a secure and prudent manner according to the principle of minimal necessity. If it is necessary to disclose your personal data to third parties, we will also require the third parties to strictly comply with our measures and requirements for data protection. In order to provide you with the required services, we may only transfer your personal data to third parties in the following situations:
- To meet compliance obligations such as anti-money laundering, and counter terrorism financing, we may transfer your personal data to third-party compliance consultants, outsourced service providers for compliance, and/or third-party compliance solution providers (such as identity verification, name screening, wallet risk scanning and other compliance solution service providers);
- With your explicit consent, we will share your personal data with other third parties;
- We may disclose your personal information to our affiliates;
- Some of our services are provided by our partners, and Ubox may disclose certain personal data to such partners in order to provide you with better products, services and user experience;
- The disclosure of your personal data is required under applicable legal requirements, in legal proceedings, litigation ,or in accordance with the requests from regulatory or government authorities, Ubox may disclose your personal data as requested or required. If Ubox is involved in restructuring, merger, bankruptcy and liquidation litigation or proceedings, we may also disclose your personal data to the related parties involved. Ubox may also disclose your information on other reasonable grounds.
- When you make a complaint against others or are complained against, in order to protect your and other people's legitimate rights and interests, we may disclose your name, ID number, contact information, and complaint content to related consumer rights protection departments or regulatory agencies to promptly resolve complaints and disputes.
- Retention of Personal Data
We retain your personal information only for the time necessary to complete our business purposes and within the time limits set by laws, regulations, and authorities’ requirements. If we transfer or disclose your personal data to third parties, we will also ensure that the third party complies with the aforementioned requirements through contracts or other means. We will take feasible measures to delete data that is no longer necessary for our business purposes, unless its deletion is prohibited by law or against public interests.
- Your Rights to Your Personal Data
You can manage your personal data at any time, such as your email address, and phone number, etc. You should ensure that all personal data you provide to us is the latest and accurate. We will make reasonable effort to maintain the accuracy and completeness of your personal data and update it in a timely manner.
You are entitled to: (1) access specific personal data we hold about you; (2) request us to update or correct your inaccurate personal data; (3) refuse or restrict our use of your personal data; and (4) request us to delete your personal data. If you need to view your latest personal data after your personal data has been updated, please visit our official Site. If you need to delete your personal Data, you can send an email to email@example.com and we will handle your request as soon as possible. For security reasons, we may ask you to provide a written request. If we have reasonable grounds to believe that these requests are deceptive, impractical, do not comply with legal requirements, are contrary to public interests, or infringe on the privacy rights of others, we may refuse to process the relevant requests and inform you of the reasons for our refusal.
When Ubox processes your personal data based on your consent, you also have the right to withdraw your consent at any time. However, the withdrawal of consent will not affect the legality and effectiveness of our processing of your personal databased on your consent before the withdrawal. You acknowledge and agree that such withdrawal of consent may impact your access or use our Site or services fully or partially.
- Third Party Service Providers
Our Site may provide you with social sharing and product resale features. We do not directly share your information, but you may choose to share text, images, and web pages from our Site with your friends on social media platforms. Before submitting your personal data to the aforementioned social media platforms, please carefully read their privacy policies. We are not responsible for any actions taken by such third parties with regard to your personal data.
In addition, to ensure the stable operation of Ubox or to achieve related functions and to ensure a good user experience, we may enable you to access products, services, or links provided by third-party service providers outside of Ubox. We have no control over the privacy and data protection policies of such third-party service providers, and these service providers are not bound by this Policy. Therefore, before submitting personal data to third-party service providers by you, please carefully read their privacy policies. We are not responsible for any actions taken by such third parties with regard to your personal data either.
- Protection of Minors
We attach great importance to the protection of personal data of minors. Our Site, products and services are intended for individuals who are 18 years old or above and have the full civil capacity to use our Site and services as required by law. Minors and other individuals who do not have the full civil capacity without the consent of their parents or guardians are not permitted to register their accounts with Ubox. In cases where personal data of minors or individuals who do not have the full civil capacity is collected with the consent of their parents or guardians, we will only use or disclose the relevant data when permitted by law, with explicit consent from parents or guardians, or when necessary to protect the minors.
- Transfer of Your Personal Data Overseas
Our Site provides products and services to users globally, and our servers may be deployed in multiple countries worldwide. Your personal data will be transferred and stored on servers located in China, subject to compliance with local data protection laws. Ubox will take measures to ensure that the data we collect is processed in accordance with this Policy and applicable laws, including when personal data of data subjects located within EEA is transferred to countries or regions without an equivalent level of data protection recognized by the EEA. We will use various legal mechanisms, such as signing standard contractual clauses approved by the European Commission or obtaining your separate consent for cross-border transfer of personal data, or implementing security measures such as data anonymization before cross-border data transfer.
- Modification and Update of this Policy
We may modify and update this Policy from time to time. If we make any modifications or updates, we will provide you with notice of such changes through feasible channels and methods. Please also regularly visit our Site to check for the latest version of this Policy.
Your continued access to and use of our Site, and services will be deemed as your acceptance of any modifications or updates to this Policy, and your consent to our continued collection and use of your personal data in accordance with the modified or updated Policy.
- Contact Us
If you have any questions, concerns, or suggestions, or if you have any complaints or issues that you would like to bring to the attention of our Data Protection Officer in relation to data protection, please contact us via email at firstname.lastname@example.org.