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PRIVACY POLICY

This Privacy Policy describes the policies and procedures of Loopring Technology Limited (“ we ”, “ our ”, “ us ” or “ Loopring ”) regarding the collection, retention, use, management and protection of user information on applications and products offered by Loopring (including Loopring Smart Wallet (the “ Wallet ” or “ Loopring Wallet”)) and Loopring Exchange, collectively, “ Services ” or “ Loopring Services ”)). This Privacy Policy applies to all functions of Loopring Wallet and Loopring Exchange operated by Loopring, including but not limited to services such as wallet creation, transfer, wire, transaction, deposit and withdrawal, guardian management and reward collection. We recommend that you carefully read and understand the entire content of this Privacy Policy before using Loopring Services.

1. OVERVIEW

The applications provided by Loopring are decentralized wallets and non-custodial exchanges. In general, Loopring's collection of user information is very limited. Nevertheless, when you use the Loopring app and related services (for example, when you fill in the information as prompted by the page information, complete the creation or restore the wallet address), in order to ensure your normal use of our services, Loopring will also collect and use your personal information. We will strictly abide by the principles of openness, legality, legitimacy and necessity to collect your personal information. We will not share your information with third parties except to provide you with our services and products, to comply with the law or to protect our rights. By using our Loopring Services, including downloading one of our mobile applications and visiting our website, you agree to the collection, retention, use, management and protection of information outlined in this Privacy Policy.

2. INFORMATION COLLECTION

2.1. In order to provide you with the wallet service, we need to collect the following basic user information (“ User Information ”) that must be collected to provide you with the service:

  • (a) Account information: When you create and restore a Wallet, we need your email address or mobile phone number. This information will be used when performing guardian-related operations and will also be used by us for user modeling to provide better services.
  • (b) Wallet information: When you use the Wallet service, we will automatically collect the version information of your Wallet.
  • (c) Device information: We will collect the relevant information of your device using our services, including device ID, version information of the mobile device operating system, mobile device platform type (iOS or Android), phone language, channel information (e.g., GooglePlay, Apple App Store), IP address in order to provide statistical analysis services, and calibrate the accuracy of report data through geographic location to provide basic anti-fraud function.
  • (d) KYC (Know Your Customer) information: Loopring may provide some centralized services in the future. At that time, your identity, address and other information will be collected. Also loopring integrates services from 3rd party vendors (e.g., Ramp, BanXa) for fiat on-ramp and off-ramp solution, which will redirect user to 3rd party website. And user will need to fill in the KYC information in those web sites to receive services. This information is only used for compliance purposes. 2.2. Loopring uses a second layer account based on the Ethereum blockchain. When you use the Loopring account, the wallet address, ENS name, and all first-level transaction records related to the address (ENS name) (including but not limited to transfer, transaction, deposit, and withdrawal, etc.) will be stored on the Ethereum blockchain. You and we have no control over the disclosure, modification and deletion of your transaction records on the Ethereum blockchain. 2.3. When you are re-directed to a third-party DApp through Loopring Wallet, the third-party DApp may collect your personal information. If you refuse the third-party DApp to collect such information when providing services, you may not be able to use such third-party DApp in the Loopring Wallet. We do not retain your personal information collected by third-party DApps.

3. INFORMATION RETENTION

3.1. According to the laws of the Hong Kong Special Administrative Region of the People's Republic of China (Applicable Laws") and commercial purposes, we will collect your personal information and continue to store your personal information as we deem necessary. We usually keep your personal information permanently in the cloud to ensure that any contractual disputes can be resolved. If the laws of user data management at your location are different from the Applicable Laws, you agree that receiving our Wallet service is governed by Applicable Laws, and you agree that we transfer your personal information to the country and territory of our designated cloud service provider.

3.2. We provide products and services through resources and servers all over the world. This means that after obtaining your consent, your personal information may be transferred to the country/region where you use the product or service (“ Jurisdiction ”), or be accessed from these Jurisdictions. The Jurisdictions may have different data protection laws, or the Jurisdictions may not have the laws that provide adequate protection for your personal information. In such cases, we will ensure that your personal information will be equally protected in accordance with the provisions of this Privacy Policy.

3.3. When our products or services cease to operate, we will notify you in the form of an announcement, and delete your personal information or anonymize them within a reasonable period of time.

4. USE OF THE INFORMATION

4.1. We will use the User Information collected during the course of providing services to you for the following purposes:

  • (a) Provide you with basic Wallet services; for the information collected on various devices that you log in with the same wallet address, we may associate them so that we can provide you with consistent Wallet services on these devices.
  • (b) Certify application or manage application upgrade;
  • (c) Other purposes: When we use User Information for other purposes not specified in this Privacy Policy or use information collected for a specific purpose for other purposes, we will ask for your consent in advance. 4.2. You agree that when you use your Wallet or accept our Services, we have the rights to use your User Information to make models, trends, knowledge, metadata and other observations (collectively, the “ Derivative Data ”), provided that we have (a) anonymized the User Information; and/or (b) mixed the User Information with other data. Derivative Data should consist of anonymized data and must not contain data that can determine the identity of the user or confirm the identity of other natural persons. Anonymized data means that any information that can distinguish users or other natural persons should be completely removed, and we or any third person cannot distinguish users or other natural persons from some of the retained data in any way. You agree that the Derivative Data belongs to us, and we can use the Derivative Data for legitimate business purposes (including but not limited to developing, providing, operating, maintaining and improving our products and services).

5. INFORMATION DISCLOSURE

5.1. Currently, we will not actively share or transfer your personal information to third parties. If there are other situations of sharing or transferring your personal information, we will obtain your prior authorization or consent, or anonymize your personal information so that it cannot identify a specific person and cannot be restored.

5.2. We will not publicly disclose your personal information. If public disclosure is necessary, we will inform you of the purpose of this public disclosure, the type of information disclosed, and the sensitive information that may be involved, and obtain your express consent.

5.3. You understand that in the following situations, we do not need to obtain your prior authorization to share, transfer, and publicly disclose your personal information:

  • (a) Directly related to national security and national defense security;
  • (b) It is directly related to public safety, public health, and major public interests;
  • (c) Directly related to criminal investigation, prosecution, trial and execution of judgments;
  • (d) It is difficult to obtain the consent of the person in order to protect the life, property and other major legal rights of you or other individuals;
  • (e) You have disclosed your personal information to the public on your own;
  • (f) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
  • (g) Necessary for maintaining the safe and stable operation of the Wallet, for example, discovering and disposing of the failure of the Wallet; and
  • (h) Other circumstances stipulated by laws and regulations.

6. INFORMATION MANAGEMENT

6.1. In accordance with Applicable Laws, we guarantee that you have the following autonomous control rights over your personal information in your Wallet:

  • (a) You acknowledge that in the \"My\" section, you can freely choose to perform the following operations: In \"Settings\"-\"Security\", you can choose not to turn on the \"Fingerprint Login\" option, that is, you can choose not to use the Touch provided by your mobile phone ID verification service.
  • (b) You acknowledge that when we collect information from you for a specific purpose, we will notify you in advance and you have the right to refuse. Meanwhile, you acknowledge that when you choose to refuse to provide the user information described in Section 2.1 (a) of this Privacy Policy, it means that you give up using the relevant services of the Wallet. 6.2. You understand that based on the open-source properties of the blockchain trading system, your transaction records will be automatically disclosed in the entire blockchain system, and you and we have no control over such disclosure. 6.3. You understand that this Privacy Policy will no longer apply when you are re-directed to a third-party DApp through the link of your Wallet. Regarding your control over your personal information on a third-party DApp, we recommend that you read and understand its privacy rules and related user service agreements before using the third-party DApp.

7. INFORMATION PROTECTION

7.1. If the Wallet ceases to operate, we will promptly stop collecting your personal information. We will post a notice to cease operations on the Wallet, and will delete or anonymize the personal information we hold within a reasonable period of time.

7.2. In order to protect your personal information, we will adopt technical measures of data security to improve internal compliance, increase the training of internal employee information security, and set security access permissions for relevant data to protect your private information.

7.3. In the event of personal information breach and other security incidents, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the measures you can take to prevent and reduce risks, and your remedies, etc. We will promptly inform you about the incident by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information individually, we will adopt a reasonable and effective way to issue an announcement.

7.4. We will proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

8. DISCLAIMER

8.1. Please note that after you access a third-party DApp through your Wallet, the privacy policy issued by the third-party DApp will apply. The collection and use of your personal information by third-party DApps are not under our control, and this Privacy Policy does not apply to the foregoing circumstances. Please carefully select and use third-party DApps and properly protect your personal information. We are not responsible for the privacy protection of other third-party DApps.

8.2. You understand and agree: We will take reasonable security measures to protect your personal information as far as possible under the current technical level to avoid information leakage, tampering or damage. However, the Wallet uses wireless network to transmit data. To our best to effort of data security, we cannot always guarantee the 100% security of the personal information. If you use a wireless network to transfer data of a Wallet, privacy and security of the data may be breached due to the factors out of our control, and this cannot be regarded as our fault. Therefore, when the above-mentioned breach occurs, we will make all reasonable efforts to reduce your loss; but if any loss is incurred, we will only bear the reasonable liability for the part of the loss caused by our fault.

8.3. Loopring Wallet has a guardian function. All your operations on the first layer of the network, i.e., Ethereum blockchain, is visible and open to your guardian. Loopring is not responsible for any of the privacy breach caused by the information disclosure to the guardian.

9. POLICY UPDATE

We reserve the right to update and revise this Privacy Policy at any time. We occasionally review this Privacy Policy to make sure it complies with Applicable Laws and conforms to the changes in our business. Without your consent, we will not reduce your right under this Privacy Policy. If we do revise this Privacy Policy, we will notify you the change of this Privacy Policy via Wallet. Regarding major changes, we will also provide more noticeable notices, including page prompts and other methods, to explain the specific changes to this Privacy Policy. The major changes of this Privacy Policy include, without limitation:

  • (a) A major change in our service model, such as the purpose of processing user information, the type of personal information processed, and the way in which personal information is used.
  • (b) Significant changes have taken place in our ownership structure and organizational structure, such as changes of ownership via business adjustments, bankruptcy mergers, etc.
  • (c) The main objects of personal information sharing, transfer or public disclosure have changed.
  • (d) Your right to participate in the processing of personal information and how to exercise it has undergone major changes.
  • (e) When our department responsible for handling user information security, contact information and complaint channels change.
  • (f) When the information security impact assessment report shows that there is a high risk. Please review this Privacy Policy regularly to ensure that you are aware of its terms. Any use of Loopring Service after an amendment to our Privacy Policy constitutes your acceptance to the revised Privacy Policy.

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Last Updated: August 4, 2022.