Dear Users,

 

Walton Chain (HK) Development Co., Ltd. (“Walton Chain (HK) Development” or “we”) respects and protects the privacy of Users (“you” or “Users”). Walton Chain (HK) Development will collect and use your Personal Information, generated from your use of Waltonchain wallets, in accordance with this Privacy Policy (“Policy”).

 

Walton Chain (HK) Development recommends that you carefully read and understand the contents of this Policy before your use of the product (“Waltonchain wallets”). Additionally, significant information including the Disclaimer is in bold form in this Policy. Definitions of key terms in this Policy are consistent with those in the Waltonchain wallets Terms of Service of Walton Chain (HK) Development.

 

Walton Chain (HK) Development reserves the right to update this Policy online from time to time, and the new policy will immediately replace the previous one once posted.

 

You acknowledge and accept that this Policy and other relevant rules apply to Waltonchain wallets.

 

1. Information We Collect

 

We collect your information in order to provide the services you request on the Site, and we value the protection of 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 all information we request, your user experiences on Waltonchain wallets may be adversely affected.

 

1.1 We may collect your personal information, including but not limited to your mobile device information, operating records, transaction records and wallet addresses.

 

1.2 In order to satisfy your needs for specific services, we may collect your name, bank card number, telephone number, email address, etc.

 

1.3 You agree and understand that your Wallet Password, Private Key, Mnemonic Words, and Keystore on Waltonchain wallets are not stored or synchronized on Walton Chain (HK) Development’s servers. Walton Chain (HK) Development does not offer any services to restore your Wallet Password, Private Key, Mnemonic Words or Keystore. You will have sole responsibility and control over these items, and Walton Chain (HK) Development disclaims all liability for the safety, storage, control, or use of these items.

 

1.4 Apart from the foregoing provisions, when you are using specific functions of Waltonchain wallets, we may request additional personal information. Your objection to providing such additional information will be deemed as your election not to use that specific function of Waltonchain wallets.

 

1.5 In the event you use any third-party-developed applications on the Waltonchain wallets platform, your personal information will be collected and held by the third-party-developed applications instead of being collected and stored by Waltonchain wallets. It is your responsibility to become familiar with such third-party-developed applications’ privacy policies and personal information storage and safekeeping terms before you use any such applications. Walton Chain (HK) Development shall have no liability or obligation of any kind to you for the actions or policies of such third-party-developed applications.

 

1.6 To the extent permitted by laws and regulations, Walton Chain (HK) Development 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. any personal information collected is publicized by you;

 

e. the personal information is collected from legally publicly disclosed information, such as 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.

 

1.7 We collect information in the following ways:

 

a. We automatically collect and store your general internet usage information as and when you use our platform (including your IP address, browsing habits, click patterns, version of software installed, device type, system type, screen resolutions, plug-ins, language settings, the content and pages that you access in the Waltonchain wallets, the dates and times that you visit, paths taken, and time spent on pages within the Waltonchain wallets), using various types of tracking technology we send to your device, including cookies and web beacons. The use of cookies (being small text files containing a string of alphanumeric characters), is standard and many major websites, mobile sites and mobile applications use them. Web beacons (being electronic image requests also known as “single-pixel gif” requests) allow us to count page views and to access cookies. These can take the form of any electronic image viewed as part of a web page (typically 1-by-1 pixel files) and/or in HTML-formatted broadcasts that we send to opt-in subscribers in order to count how many people opened and read the broadcast. Our web beacons do not collect, gather, monitor or share any personally identifiable information. They are just the technique we use to compile anonymous information about the Waltonchain wallet and your service usage.

 

b. we may collect information during your use of Waltonchain wallets, including your mobile device’s information, location, and your operating records on Waltonchain wallets.

 

c. we retain all or part of your transaction records on the blockchain. However, Users shall refer to the blockchain ledger for the latest transaction records.

 

2. How We Use Your Information

 

2.1 We may use your usage details described above to: (a) automatically provide you with the latest version of the Waltonchain wallets on your device; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access the Waltonchain wallets; (c) monitor aggregate Waltonchain wallets usage metrics such as total number of visitors and pages/services accessed; and (d) track your entries, submissions, and status in any purchases or other activities in connection with your usage of the Waltonchain wallets.

 

2.2 We may promptly push important notifications to you, such as software update(s), update of Terms of Service and this Policy.

 

2.3 We store your feedback by using the wallet address and the mobile device information provided by you.

 

2.4 We may collect your personal information to conduct an internal audit, data analysis and research to enhance our services.

 

2.5 According to Waltonchain wallets Terms of Use and other rules of Walton Chain (HK) Development, Walton Chain (HK) Development may manage and track the use behaviors of Users through Users’ personal information.

 

2.6 We may use your personal information in accordance with our jurisdiction’s laws, regulations and to cooperate with regulatory authorities. We are not responsible for compliance with your jurisdiction’s laws with respect to data storage, safe-keeping, and use.

 

2.7 You may voluntarily provide additional information to us from time to time, such as demographic information or information related to your favorite social networking site, or your participation in competitions, promotions, surveys, and/or additional services. You may do this if you decide to upload or download certain content from/to the Waltonchain wallets, enter competitions, take advantage of promotions, respond to surveys, register and subscribe for certain additional services, or otherwise use the optional features and functionality of the Waltonchain wallets. We may use such optional details provided by you for such purposes as indicated to you at the time you agree to provide such optional details

 

3. How You Control Your Own Information

 

You are entitled to control the personal information provided to Waltonchain wallets:

 

3.1 You may send or receive coins and tokens, transfer and collect tokens by clicking the “Send” and “Receive” buttons.

 

3.2 You understand that you may initiate the following operations in the “Profile” column in WTCwallet:

 

a. in the “Contacts” column, you may view and edit your “Contacts”;

 

b. 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 such information;

 

3.3 When we collect information from you for a specific purpose, we will ask for your consent in advance, 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 Waltonchain wallets.

 

3.4 You acknowledge that since the blockchain ledger is an open source system, all your transaction records are automatically public and transparent on the open blockchain.

 

3.5 You understand that after you click any link to the third-party-developed apps from Waltonchain wallets, the Waltonchain wallets Terms of Use and Waltonchain wallets Privacy Policy will no longer apply. You are encouraged to carefully review the privacy policies and related terms of service documents before your use of such the third-party-developed apps.

 

3.6 You are entitled to request that we update, revise, and delete your relevant personal information, and we shall comply with such request unless such action would be in violation of applicable laws to which we are subject, in which case we may or may not inform you that we are unable to comply with your request.

 

4. Information We May Share or Transfer

 

4.1 The personal information collected and generated by Walton Chain (HK) Development during our operations shall be stored within the territory of the People’s Republic of China (PRC). If we decide, in our sole discretion, to transfer your personal Information abroad, we shall obtain your prior consent and conduct the cross-border data transfer in accordance with all laws, regulations and policies of the receiving jurisdiction, as well as undertake our present confidentiality obligations to protect your personal information.

 

4.2 Walton Chain (HK) Development will not share with or transfer your personal information to any third party without your prior consent, except for the following circumstances:

 

a. you have expressly provided your prior consent or authorization;

 

b. the collected personal information is publicized by you;

 

c. the personal information is collected from public information which had been lawfully disclosed, such as news, government information disclosure, and any other lawful channels;

 

d. we may share your personal information with our affiliates only when necessary and to the extent permitted by this Policy;

 

e. in order to comply with applicable laws, regulations, legal processes, and administrative or judicial authorities;

 

f. in the event of merger or acquisition, if the transfer of personal information is involved, Walton Chain (HK) Development shall do its utmost to require the acquiring party to continue to be bound by this Policy or a policy which is similar in scope and spirit.

 

5. How We Protect Your Information

 

5.1 By accepting this Policy, you consent to our collection, storage, processing and disclosure of your personal information as described in this Policy. Should you terminate your registration with us for any reason, you consent to our retention of the information we have already collected from you for record-keeping purposes only, for an indefinite period.

 

5.2 To protect your personal information, Walton Chain (HK) Development 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.

 

5.3 We will not sell or rent any of your personal information to third parties for their marketing purposes and only share your personal information with third parties as described in this Policy.

 

6. Protection for the Minors

 

The following special provisions apply to minors who are under the age of 18 years old:

 

6.1 Minors shall not use Waltonchain wallets without guidance from their parents or guardians.

 

6.2 Parents and guardians of minors shall provide guidance to such minors on using Waltonchain wallets after they read this Policy, Waltonchain wallets Terms of Use and other relevant documents.

 

6.3 Waltonchain wallets will ensure the confidentiality and security of the minors’ personal information in accordance with PRC laws and regulations.

 

7. Disclaimer

 

7.1 After you click on any third-party-developed apps from Waltonchain wallets, the privacy policies of the third-party-developed apps will apply. The collection and use of your personal information by the third-party-developed apps will be controlled neither by Walton Chain (HK) Development, nor by this Policy. Walton Chain (HK) Development is unable to guarantee that the third-party-developed apps will take any personal information protection measures to secure personal information and guard against data breaches; therefore, it your obligation to review each such third-party-developed apps’ privacy policy to decide whether you wish to continue your use of such apps.

 

7.2 You shall carefully select and use the third-party-developed apps and protect your Personal Information. Walton Chain (HK) Development shall not be held liable for the privacy protection obligations of any third-party-developed apps and you assume full responsibility for your use of such Apps.

 

7.3 YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, Walton Chain (HK) Development 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 DAMAGING YOUR PERSONAL INFORMATION. SINCE Walton Chain (HK) Development TRANSFERS DATA WIRELESSLY, Walton Chain (HK) Development MAKES NO GUARANTEE ON THE PRIVACY AND SECURITY OF WIRELESS INTERNET DATA TRANSFERS.

 

8. Miscellaneous

 

8.1 If you are a User outside of PRC, you fully understand and conform to the laws, regulations and rules in your jurisdiction that are relevant to your use of Walton Chain (HK) Development and Waltonchain wallets.

 

8.2 Throughout the term of your use of Walton Chain (HK) Development services or Waltonchain wallets, if you come across any issues related to the use of your Personal Information, then you may contact us and submit your comment through the Site.

 

8.3 We encourage you to check the Terms of Service and Privacy Policy of Walton Chain (HK) Development each time you log onto Waltonchain wallets.

 

8.4 This English version is the only version of this Policy.

 

8.5 As for any issues not covered in this Policy, you shall comply with the announcements and relevant rules as updated by Walton Chain (HK) Development from time to time.