Privacy Policy

Last updated on: 19 July 2021

Dear KeyPal Hardware Wallet User

KEYPAL ("the Company" or "we") respects and protects the privacy of our users ("you" or "the User"). "), we collect, use, disclose and process your personal information in accordance with this Privacy Policy ("Policy") and maintain strict confidentiality of the personal information you provide when you.

(1) use our website, products or services.

(2) Provide us with your personal information, regardless of the medium through which it is provided.

You are advised to read and understand this policy in its entirety before using our website, products or services, and important information, including disclaimers and other terms, will be bolded. The definitions of keywords in this policy are consistent with our KEYPAL User Agreement. If a definition or term used in this policy is inconsistent with that in the KEYPAL User Agreement, this policy will prevail.

When you provide us with personal information, you consent to the collection, use, disclosure (including transfer) and processing of your personal information in accordance with this policy. If you do not accept this policy, please do not provide us with any personal information.

This policy may be updated by us online at any time without notice. The updated policy will be effective upon posting on our website notice and will be subject to the latest posted policy. The revised policy will apply immediately to the use of the personal information you provide to us. If you do not accept the revised terms, please stop using our website, products or services immediately; your continued use of our website, products or services will be deemed to be acceptance of the revised policy.

1. What information we collect about you

1.1 When you use our website or purchase our products or services by way of links from our affiliates DApp, we will collect identifying information about you, including but not limited to your name, delivery address, telephone number, email address, location information, etc.

1.2 When you choose a payment method provided by us, we may obtain information about your WeChat account, Alipay account and other payments from third parties.

1.3 When you use our customer service, we may ask you to provide your name, telephone number, order number, waybill number, recipient, delivery address, payment method, enquiry questions and other information for the purpose of selling the service.

1.4 To meet legal and regulatory requirements and your specific needs, we may ask to collect more personal information from you to enable you to use certain features of our website, products or services. If you do not agree to provide such personal information, you will be deemed to have waived the use of that particular feature.

1.5 To the extent permitted by law or regulation, we may collect and use your personal information without your authorised consent in the following circumstances.

1.5.1 in connection with national security or defence security.

1.5.2 in connection with public safety, public health or significant public interest.

1.5.3 in connection with the investigation, prosecution, trial and execution of judgments in relation to a crime

1.5.4 where the personal information collected is in the public domain.

1.5.5 where your personal information is collected from information that is lawfully and publicly disclosed, such as lawful news reports, government information disclosure and other sources.

1.5.6 as necessary to maintain the security and compliance of the Services, for example, to detect and deal with faults in products and services.

1.5.7 in other circumstances as permitted by law and regulation.

1.6 We collect information in the following ways.

1.6.1 when you voluntarily provide information to us, for whatever reason.

1.6.2 When you authorise us to obtain information about you from a third party.

1.6.3 when you use our website, products and services.

1.6.4 when you contact or interact with our employees through various communication channels, including but not limited to through social networking platforms, communication platforms, in-person meetings, telephone calls, emails, faxes and letters.

1.6.5 when you have a transaction with us, contact us or ask us to contact you.

1.6.6 when you ask to subscribe to our mailing service.

1.6.7 when we are informed of all or part of your records through the blockchain system, whichever is recorded in the blockchain system.

1.7 Our website may contain technologies that collect information in ways that are described in this policy (see section 5 below) or in the applicable terms and conditions.

1.8 Your provision of personal information to us is your own initiative and you may withdraw your consent at any time. However, if you choose to refuse to provide us with the personal information we request in connection with a legally authorised licence, you may not be able to use certain features of our website, products or services and we may not be able to contact you or provide you with the products or services you require.

1.9 In some cases, you may provide us with personal information that is not your own. If you provide information about another person, you shall ensure and provide that you have obtained the consent of that data subject for the relevant information and that you allow us to collect personal information from that data subject and that the data subject consents to your disclosure of his or her personal information to us. You agree to indemnify us and hold us harmless from any claims that such data subjects may have against us in relation to our collection, use and disclosure of their personal information in accordance with the terms of this policy.

1.10 You shall ensure that the information you provide to us is true, accurate and complete. You should notify us of any changes to the information you have provided; otherwise you will be personally liable for any related losses.

2. How we use your information

2.1 We will collect, use or disclose your personal information for one or more of the following purposes.

2.1.1 to provide you with the products and/or services you have requested.

2.1.2 To manage your relationship with us.

2.1.3 facilitating your experience of using it.

2.1.4 sending you timely and important notices, such as changes to the terms of the User Agreement and this Policy.

2.1.5 to assist you with your questions, feedback, complaints and requests through the wallet address and mobile device information provided.

2.1.6 to inform you of our products, services, programs and events.

2.1.7 to resolve disputes, investigate any complaints, claims or disputes, or any actual or suspected unlawful conduct.

2.1.8 to conduct our internal audits, data analysis and research.

2.1.9 to carry out analysis of user behaviour by tracking users' use of the Website.

2.1.10 to comply with the provisions of laws and regulations and with the requirements of regulatory bodies.

2.1.11 to comply with the requirements of international laws and regulations regarding security and anti-money laundering or counter-terrorism.

2.1.12 to comply with our statutory obligations and contractual terms and conditions; and/or

2.1.13 any reasonable purpose in connection with the foregoing.

2.2 With your prior consent, we may from time to time use your personal information for other purposes, such as to inform you of the latest events, offers and promotions from our strategic partners or affiliates.

3. How you control your information

You have the following autonomous control over your personal information when using our website, products and services.

3.1 You can update, change and delete your name, delivery address, contact number, email address and other information by accessing the KEYPAL website purchase interface via our website or through our affiliates' DApp links. We may ask you to verify your identity to keep your information secure.

3.2 You are aware that we have no control over whether or not your transaction records are public, as your transaction records are public and transparent across the blockchain system due to the open source nature of the blockchain trading system.

3.3 Our website will contain links to other websites, products, services or smart contracts that are not owned, operated, developed or maintained by us. These links are provided as a convenience to you. This policy applies only to our website, products or services. When you visit such third party websites or use third party products, services or smart contracts, you acknowledge that our KEYPAL User Agreement, KEYPAL Privacy Policy, KeyPal Usage License Agreement will no longer apply. We recommend that you read and understand their privacy rules and the relevant service agreements etc. We are not responsible for any damage caused by your actions on third party systems.

3.4 You have the right to ask us to update, change or delete your personal information and/or withdraw the consent you have given us. If you wish to withdraw the consent you have given us, or if you wish to update, change, delete or access the personal information we hold, or if you do not accept the changes we have made to this policy, you may contact

Customer Service email address: [e-mail]

3.5 In order to enable you to manage the personal information held by us, or to enable you to obtain information about the ways in which we have used (or may use) your personal information during the year preceding your request for such information, we may charge you a fee. If we do charge you, we will inform you of the amount of the charge in advance and will comply with your request once you have paid. We will endeavour to respond to your request within thirty (30) days of your request. If we are unable to respond within thirty (30) days, we will advise you of the exact timing of our response.

3.6 In many cases we will need to obtain your personal information in order to enable us to provide you with the products or services you have requested. If you choose to refuse to provide us with the personal information we have requested or withdraw the consent you have given us, we may not be able to continue to provide you with the products and services you have requested.

4. We may share or transfer your information

4.1 We will store your personal information for business and legal purposes.

4.2 We will not sell, trade or transfer your personal information to third parties without your consent.

4.3 If you have consented to us disclosing your personal information to strategic partners or affiliates, we may disclose your personal information to such entities. Such entities will only use your personal information for the purposes to which you have consented.

4.4 You agree that we may disclose or share your personal information with the following third parties.

4.4.1 Third parties with whom we have a partnership agreement to provide services to you, for example, after you have ordered a product from our website, we may disclose information about your purchase and the recipient of the product, etc. to an authorised distributor or logistics company with whom we have a partnership agreement, etc.

4.4.2 Service providers and data processors who provide services on our behalf and to us, such as KYC checks, accounting, data processing or management services, website hosting, maintenance and operation services, email messaging services, analytics services, payment transaction processing, marketing, etc. for us.

4.4.3 our consultants and professional advisers (e.g. accountants, lawyers, auditors).

4.5 If, for the purposes set out above, we need to transfer your personal information to any other country, we will obtain your consent and ensure that the recipient of the personal information has the same level of personal information protection as we do. If there are no personal information protection laws applicable to our relationship with you in such countries or territories, we will enter into legally enforceable agreements with the recipients of personal information.

4.6 We will not share or transfer your personal information to any third party without your prior consent, except in the following circumstances.

4.6.1 the personal information collected is disclosed to the public by you or provided to a third party.

4.6.2 the personal information collected is collected from information that is lawfully and publicly disclosed, such as lawful news reports, government information disclosure and other sources.

4.6.3 it is provided in accordance with applicable laws and regulations, the requirements of legal process, administrative or judicial authorities or the implementation of this policy to protect our or other parties' rights, property or safety.

4.6.4 where it is necessary to protect your or another individual's life, property or other significant legitimate interests but where it is difficult to obtain your consent.

4.6.5 in the event of a merger or acquisition involving the transfer of personal information, we will require the recipient of the personal information to continue to be bound by this policy.

5. Automated data collection techniques

5.1 We use automated data collection techniques in connection with our websites, products or services. Examples include

5.1.1 Cookies (or browser cookies). cookies are small text files set on a website or mobile device to identify your browser or device. We may use cookie technology on our websites, products or services to store and track information such as the number and frequency of users, user distribution and users' online preferences. cookies do not capture information that identifies you, but the information they collect assists us in analysing the use of our websites, products or services to improve your experience. You can turn off cookies in your browser settings, however, this may affect your ability to use our website, products or services.

5.1.2 Web Analytics. Web analytics is a method of collecting and evaluating the behaviour of visitors to web pages and mobile applications. This includes analysing traffic patterns, for example to determine how often a particular part of a website or mobile app feature is accessed, or to understand what information or services are of most interest to visitors. Our websites, products or services use web analytics services provided by third-party tools.

6. How we protect your information

6.1 We have implemented reasonable and practicable security measures in line with common industry solutions to protect the security of the personal information you provide against unauthorised access, public disclosure, use, modification, damage or loss of personal information, we use encryption technology to enhance the security of personal information; we use trusted protection mechanisms to prevent malicious attacks on personal information; we deploy access control We will use trusted protection mechanisms to prevent malicious attacks on personal information; and we will deploy access control mechanisms to ensure that only authorised personnel have access to personal information.

6.2 If we cease operations, we will cease any further collection of your personal information and take steps to delete or anonymise any personal information we hold about you within a reasonable period of time.

6.3 In order to protect your personal information, we will take technical measures for data security, improve internal compliance, increase internal staff training on information security and set security access rights to relevant data to safely protect your private information.

6.4 We will send you messages about information security on our website and update information on product and service usage and information protection from time to time for your reference.

6.5 The Internet is not an absolutely secure environment and we strongly recommend that you do not send personal information using communication methods other than those recommended by us. You can connect and share with each other through our Services. When you create a communication, transaction or share through our Services, you can independently choose who to communicate, trade or share with, as a third party who can see information related to the content of your transaction, contact details, communication information or sharing content.

6.6 Please note that the information you voluntarily share or even publicly share when using our services may involve personal information or even sensitive personal information about you or others, such as when you choose to upload images containing personal information when posting a dynamic or in a public forum such as a group chat or circle. Please consider more carefully whether to share or even publicly share such information when using our services.

Please help us to keep your account secure by using complex passwords. We will do our best to keep any information you send us secure.

7. Protection of minors

We make the following special agreements for the protection of minors under the age of 18.

7.1 Minors should use our relevant websites, products and services under the guidance of their parents or guardians.

7.2 We recommend that parents and guardians of minors should guide minors in their use of our websites, products or services, subject to reading this policy, the KEYPAL User Agreement, the KeyPal Usage License Agreement and our other relevant rules.

7.3 Our website, products or services will protect the confidentiality and security of minors' personal information in accordance with the provisions of applicable laws and regulations.

8. disclaimer of warranties

8.1 You acknowledge and agree that this Policy will no longer apply to the collection, use, disclosure and transmission of your personal information by third parties following your access to or use of such third party websites, products, services or smart contracts. We cannot guarantee that such third party websites, products, services or smart contracts will have reasonable security measures in place.

8.2 You acknowledge and agree that the definition of personal information varies from country to country and that we will protect your personal information in accordance with the applicable laws as set out in clause 9.2. In order to protect your personal information to the maximum extent permitted by law, we may treat some non-personal information in accordance with the protection standards for personal information; where non-personal information is intermingled with personal information, we will treat the non-personal information as personal information.

8.3 You will be solely responsible for your use of such third party websites, products, services or smart contracts and you agree that you shall not hold us liable for any loss or damage suffered by you as a result of the collection, use, disclosure and transmission of your personal information by such third party websites, products, services or smart contracts.

8.4 You acknowledge and accept that, to the fullest extent permitted by applicable law, we will take reasonable steps to ensure that your personal information is used in accordance with the current state of the art, on an "as is", "as available", "without warranty of non-defectiveness" basis. We will take reasonable security measures to protect your personal information from disclosure, falsification or destruction, to the extent possible, based on the principles of "as is", "as available" and "without warranty of defect". We transmit data by wireless means and therefore cannot ensure the privacy and security of data transmitted via wireless networks.

9. Other

9.1 You are required to fully understand and comply with all relevant laws, regulations and rules of your jurisdiction in relation to the use of our website, products and services.

9.2 The laws of the People's Republic of China shall apply to the validity, interpretation, variation, enforcement and dispute resolution of this Policy and its amendments, or in the absence of such laws, international business practices and/or industry practices shall apply. If any dispute or controversy arises between you and us in relation to this Policy, it shall first be settled amicably, and if consultation fails, either party may submit to the jurisdiction of the courts of the People's Republic of China in the mainland where its has jurisdiction.

9.3 You can view this policy and our other service rules (e.g. KEYPAL User Agreement, KeyPal Usage License Agreement) on our website. We encourage you to review our User Agreement and Privacy Policy each time you visit our website.

9.4 Any translated version of this policy is provided for the convenience of users only and is not intended to modify the terms of this policy. In the event of a conflict between the English version and a non-English version of this Policy, the English version shall prevail.

9.5 This Policy shall apply from 19 July 2021.

You are subject to the Company's announcements and related rules as updated from time to time for matters not covered by this Policy.

KEYPAL