Privacy Policy
Last
Updated: Nov 7th, 2022.
Dear
Users,
TP
Global Ltd. (“TPGL” or “we”)
respects and protects the
privacy of Users (“you” or
“Users”). TPGL will collect
and use your Personal
Information, generated from
your use of TokenPocket in
accordance with this Privacy
Policy (“Policy”). TPGL
recommends that you shall
carefully read and
understand the whole
contents of this Policy
before your use of the
product (“TokenPocket”).
Additionally, significant
information including the
Disclaimer is in bold form
in this Policy. Definitions
of key words in this Policy
are consistent with those in
the TokenPocket Terms of
Service of
TPGL.
TPGL
reserves the right to update
this Policy online from time
to time, and the new policy
will immediately replace the
older one once posted. In
particular, if you do not
accept the revised policies,
please immediately stop your
use of TokenPocket. Your
continuous use of
TokenPocket will be regarded
as
your acceptance of the
revised policy. Furthermore,
the revised policies will
take into effect immediately
upon being posted on
TokenPocket.
You
acknowledge and accept that
this Policy and other
relevant rules apply to
TokenPocket and the DApps
owned by TPGL on
TokenPocket.
We
collect your information in
order to provide the
services you requested on
TokenPocket, and we highly
value the protection for
your privacy. We strictly
abide by the principle of
“lawful, justifiable and
necessary” during our
collection of your
information. You acknowledge
that, if you do not provide
us with necessary
information, your user
experiences on TokenPocket
may be influenced. We may
collect your Personal
Information, including but
not limited to your mobile
device information,
operation records,
transaction records and
wallet
addresses.
1.1
In order to satisfy your
needs for specific services,
we may collect your name,
bank card number, telephone
number (Mobile phone number
registration method), email
address (Email registration
method), etc.
1.2
You confirm that your Wallet
Password, Private Key,
Mnemonic Words, Keystore on
TokenPocket (the
decentralized solution) are
not stored or synchronized
on TPGL’ servers. TPGL does
not offer the service to
restore your Wallet
Password, Private Key,
Mnemonic Words or
Keystore.
1.3
Apart from the foregoing
provisions, when you are
using specific function of
TokenPocket, we may give
you special notification to
ask for more Personal
Information.
1.4
After you link to the
third-party-developed DApps
from TokenPocket, your
Personal Information will be
collected and held by the
third-party-developed DApps
instead of being collected
or held by TokenPocket.
When you fill in your
Personal Information on a
third-party-developed DApp,
you should pay attention to
the Terms of Use and Privacy
Policy of the
third-party-developed DApp.
We are not accountable for
any losses caused by your
operation on the
third-party-developed DApp.
1.5
To the extent permitted by
laws and regulations, TPGL
may collect and use
following Personal
Information without your
prior consent or
authorization:
a. information related to
national security and
national defense;
b. information related to
public security, public
health, significant public
interests;
c. information related to
criminal investigation,
prosecution, trial and
enforcement;
d. the Personal Information
collected is publicized by
yourself;
e. the Personal Information
is collected from legally
publicly disclosed
information, such as legal
news reports, government
information disclosure and
other channels;
f. the Personal Information
is necessary to maintain the
security and compliance of
services, such as to detect
or to solve the malfunction
of products and services;
g. other circumstances
prescribed by laws and
regulations. We collect
information in the following
ways:
1). Information you give us.
For example, you fill in
your name, telephone number,
or bank card number in “My
Account” column or you
provide your email address
when submitting feedbacks,
or you give extra
information to us when you
use our specific
services.
2). we collect information
during your use of
TokenPocket, including your
mobile devices information
and your operation records
on TokenPocket,
etc.
2.1
We may associate you with
your wallet by the unique
serial number of your mobile
device.
2.2
We may promptly push
important notifications to
you, such as software
update, update of Terms of
Service and this Policy.
2.3
We offer you the “Touch ID”
option in the “Settings”
column of TokenPocket to
provide you with a
convenient and safe way to
manage your digital Tokens.
2.4
We deal with your feedbacks
by using the Wallet Address
and the mobile device
information provided by you.
2.5
We may collect your Personal
Information to conduct our
internal audit, data
analysis and research etc.
to enhance our services.
2.6
According to TokenPocket
Terms of Service and other
rules of TPGL, TPGL will
manage and handle the use
behaviors of Users through
Users’ information.
2.7
We may use your information
in accordance with laws,
regulations and to cooperate
with regulatory
authorities.
You
are entitled to control your
Personal Information
provided to TokenPocket:
3.1
You may import your other
wallets into TokenPocket
through synchronization of
wallets and you may export
your wallets from
TokenPocket to other Tokens
management wallets.
3.2
TokenPocket will display
the information of imported
wallets to you. You may add
or delete Tokens, transfer
and collect Tokens using the
“Assets” column.
3.3
You understand that you may
handle the following
operations in the “Me”
column on
TokenPocket:
a. in the “Address Book”
column, you may view and
edit your “Contacts”;
b. in the “Settings” column,
you may choose not to open
“Unlock Setting”, which
means you may refuse to use
the verification service to
enter TokenPocket;
c. in the “Profile” column,
you do not have to provide
your name, telephone number,
bank card number
information. But if you wish
to use specific services,
you may need to provide the
foregoing information;
d. in the “Help” column, you
may submit any questions or
suggestions for TokenPocket
at any time. We are
glad to communicate with you
to improve our
services.
3.4
When we collect information
from you for a specific
purpose, we will ask for
your consent in advance to
which you are entitled to
refuse. However, you
understand that when you
refuse to give such consent,
you also give up the choice
to use specific services
provided by TokenPocket.
3.5
You acknowledge that since
blockchain is an open source
system, your transaction
records are automatically
public and transparent in
the whole blockchain.
3.6
You understand that after
you link to the
third-party-developed DApps
from TokenPocket, the
TokenPocket Terms of
Service and TokenPocket
Privacy Policy will no
longer apply. You are
encouraged to carefully
review its privacy policies
and related terms of service
before you start to use the
third-party-developed DApps.
3.7
You are entitled to ask us
to update, revise, and
delete your relevant
information.
3.8
We reserve the right to
collect your information
without your prior
authorization or consent
according to the Article 7
of Section 1 of this
Policy.
4.1
The Personal Information
collected by TPGL for
business and legal purposes
4.2
The Personal Information
will not be sold, traded or
transferred to the third
parties without your
consent.
4.3
The Personal Information may
be disclosed to these
entities if you agree to our
disclosure of the personal
information to strategic
partners or related parties.
These entities will only use
your personal information
for the purposes you have
agreed to.
4.4
You agree that we may
disclose or share your
personal information to the
following third parties: a.
service providers and data
processors who represent us
and provide services to us,
such as KYC inspections,
accounting, data processing
or management services,
website hosting, maintenance
and operation services, mail
information services,
analysis services, and
payment transaction
processing, marketing, etc.;
b. TPGL consultants and
professional consultants
(such as accountants,
lawyers, auditors).
4.5
The Personal Information may
be transferred to any other
country for the
above-mentioned purposes.
TPGL will obtain your
consent and ensure that the
recipient of personal
information has the same
level of personal
information protection
measures as TPGL. If there
is no personal information
protection law applicable to
the relationship between
TPGL and you in these
countries or regions, we
will sign a legally
enforceable agreement with
the receivers of personal
information.
4.6
TPGL will not share with or
transfer your Personal
Information to any third
party without your prior
consent, except for the
following
circumstances:
a.
the collected Personal
Information is publicized by
yourself;
b. the Personal Information
is collected from public
information which was
legally disclosed, such as
news (lawfully reported),
government information
disclosure and other
channels;
c. we may share your
Personal Information with
our affiliates only when
necessary and to the extent
permitted by this Policy;
d. in order to abide by
applicable laws,
regulations, legal
procedures, and
administrative or judiciary
authorities, TPGL will
provide or implement this
Policy to protect our or
other parties' rights,
assets or security;
e. in the case of mergers
and acquisitions, if
transfer of Personal
Information is involved,
TPGL may require the
receivers of Personal
Information to be
continuously bound by this
Policy.
5.1
We use automatic data
collection technology in the
application. E.g:
a.
cookies (or browser
cookies). Cookies are small
text files set by the
operator of a website or
application to identify your
browser or device. We may
use cookies on our apps to
store and track information,
such as the number and
frequency of use of users,
user distribution, and
users' online preferences.
Cookies do not capture
information that can
identify you, but the
information they collect can
help us analyze the usage of
the application to improve
your experience. You can
turn off cookies in your
browser settings. However,
this may affect the
functionality of the
application.
b.
network analysis. Web
analytics is a method of
collecting and evaluating
the operation of visitors to
web pages and mobile
applications. This includes
analyzing traffic patterns,
such as determining the
frequency of visits to
certain functions of a
website or mobile
application, or to
understand the information
or services that visitors
are most interested in. We
use network analysis
services provided by
third-party
tools.
6.1
If TPGL terminates
operation, TPGL will stop
the collection of your
Personal Information in
time, post the announcement
on TokenPocket and delete
or anonymize your Personal
Information held by us
within a reasonable period.
6.2
To protect your Personal
Information, TPGL 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.
6.3
We will send you messages
about information security
in the “Wallet Guide” column
and update articles
concerning the use of
wallets and information
protection in the “Wallet
Guide” column on TokenPocket
for your
reference.
The
following special provisions
apply to minors who are
under the age of 18 years
old:
7.1
The minors shall not use
TokenPocket without the
guidance from their parents
or guardians.
7.2
The parents and guardians of
the minors shall provide
guidance to the minors on
using TokenPocket after
they read this Policy,
TokenPocket Terms of
Service and other relevant
rules.
7.3
TokenPocket will ensure
the confidentiality and
security of the minors’
Personal Information in
accordance with national
laws and
regulations.
8.1
After you link to the
third-party-developed DApps
from TokenPocket, the
privacy policies of the
third-party-developed DApps
will apply. The collection
and use of your Personal
Information by the
third-party-developed DApps
will be controlled neither
by TPGL, nor by this Policy.
8.2
You shall carefully select
and use the
third-party-developed DApps
and protect your Personal
Information. TPGL shall not
be held liable for the
privacy protection
obligation of any
third-party-developed DApps.
8.3
You acknowledge and accept
that, to the maximum extent
permitted by applicable law,
TPGL 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
TPGL transfers data
wirelessly, TPGL makes no
guarantee on the privacy and
security of wireless
internet data
transferring.
9.1
As a company that provides
services to you, we will not
actively provide your
Personal Information to
third parties other than the
agreement, unless we obtain
your consent and inform the
other party's identity,
contact information,
processing purpose,
processing method, etc. If
there is service demand of
processing your personal
sensitive information in the
future, we will ask your
opinions once again, and use
it after obtaining your
consent.
9.2
If you are a user outside of
Singapore, you shall fully
understand and conform to
the laws, regulations and
rules in your jurisdictions
which are relevant to use of
TPGL.
9.3
During your use of TPGL
services, if you come across
any problems related to your
Personal Information use,
you may contact us through
the submission of your
feedbacks on TokenPocket.
9.4
You may access this Policy
and other service rules of
TPGL on TokenPocket. We
encourage you to check the
Terms of Service and Privacy
Policy of TPGL each time you
log into TokenPocket.
9.5
This English version and
other translated versions of
this Policy are provided for
the convenience of Users,
and are not intended to
revise the original Chinese
version of this Policy. If
there is any discrepancy
between the Chinese version
and non-Chinese version of
this Policy, the Chinese
version shall
prevail.
This
Policy shall become
effective on January 1st,
2018.
As
for any issues not covered
in this Policy, you shall
comply with the
announcements and relevant
rules as updated by TPGL
from time to
time.
TP
Global Ltd.