📙Privacy Policy

1. Both parties

1.1 HKD.com (hereinafter referred to as the "Company") operates the website https://www.hkd.com/global (hereinafter referred to as "this website" or "the website"). This website is a platform dedicated to users' digital asset transactions and the provision of related services (hereinafter referred to as "the service" or "service"). For the convenience of expression in this agreement, the company and this website collectively use "we" or other first-person pronouns in this agreement.

1.2 As long as the natural person or other subject who logs on this website is a user of this website, for the convenience of expression in this agreement, "you" or other second-person pronouns will be used below.

1.3 For the convenience of expression in this Agreement, we and you are collectively referred to as the "Parties" in this Agreement, and we or you are individually referred to as the "Party".

2. Purpose of Privacy Policy

The Privacy Policy specifies the types of information we collect from you only when you log in to this website, register on this website and/or use the services we provide, and how we use, protect, store and provide such collected information.

3. your consent

To ensure that you have full confidence in our handling of personal data, you must read and understand the terms of the Privacy Policy in detail. In particular, once you log on to our website, whether or not you are registered on the website, you indicate to us your acceptance, agreement, commitment and confirmation:

3.1 You disclose personal data to us voluntarily together with the required consent;

3.2 You will comply with all terms and limitations of this Privacy Policy;

3.3 You agree that we collect your information through your login to this website, registration on this website and/or use of the services we provide; you agree to any future revisions to our Privacy Policy;

3.4 You consent to our subsidiaries, affiliates, and employees to contact you about products and services that may be of interest to you (unless you have indicated that you do not wish to receive such communications).

4. Information collected

4.1 When you use this website, you agree that we will start using cookies to track your every movement and collect and remember all the information you leave, including but not limited to your IP address, geographic location and other information.

4.2 If you are willing to use the services provided by this website, you need to fill in and provide the following two kinds of information:

• 4.2.1 Identity Information. This information can help us to verify your eligibility to register as a member of this website, including but not limited to your name, your residential address, mailing address, other certificates issued by your country or government with information to prove your identity and The numbers involved and all other information that helps us verify your identity (collectively, "Identification Information"). The identity information varies depending on whether you are an individual user or an institutional user. According to the laws and regulations of different jurisdictions, the information collected by the platform for users from different countries or regions may be different. The following information and data serve as an indicative example: Individual users: Nationality, full legal name (including previous and local language names), ID number, email address, phone number, Social Security Number (“SSN”), passport number or any government-issued ID number, birth Date, identification (such as passport, driver’s license, or government-issued identification), user’s personal photo taken within six months of the platform’s registration date, and other information or documents required by the platform. Institutional users: Company legal name (including legal name in local language), registration information, business phone number, authorized representative and authorized user personal information, principal place of business, personal information of all beneficial owners), holding 25% or more Identification documents of shareholders/beneficial owners of shares (passports or government-issued ID cards), corporate structure, documents related to company establishment, board resolutions, declaration of funding sources, risk and compliance control descriptions, and other information or documents required by the platform .

• 4.2.2 Service Information. This information helps us to contact you and provide you with different modes of transaction services between digital assets, including but not limited to your personally identifiable information, contact information, transaction information, and your debit card information and/or other account information (hereinafter collectively referred to as "Service Information"). At the same time, please understand that the services we provide to you are constantly updated and developed. If you choose to use other services that are not covered in the preceding description, and we need to collect additional information from you based on this service, we will explain the scope of information collection to you through page prompts, interactive processes, agreement agreements, and pop-up prompts. with the purpose and with your consent.

4.3 Security Management. When you use the services provided by this website or visit this website, in order to ensure the security of your transactions and the safe and stable operation of services, we need to automatically receive and record your web browser information, the type of device you use to log in to your account, Device information such as device identification symbols such as model version, IP address and records on the webpage you request to visit, location, network environment, device fingerprint information, service log information, software information, location information, etc.

4.4 When you use this website or the services it provides, we may improve your experience of using this website and the services it provides and its security in order to improve the use of this website, or to improve your experience with the use of this website and the services it provides, or in accordance with court or applicable laws and regulations. Applicable laws and regulations or orders of other government agencies with jurisdiction, collect more necessary information through the mailboxes dedicated to us published on this website or other methods that we deem compliant.

4.5 If you visit any links on this website to other third party websites or cooperating third parties, you agree to and abide by the separate and independent privacy policies of such third party websites. We are not responsible for the content and activities of these sites or partners.

5. Cookies

5.1 When you visit our website, we use Google Stats through cookies to record our performance and check the effectiveness of online advertising. A cookie is a small amount of data that is sent to your browser and stored on your computer's hard drive. Cookies can only be sent to your computer's hard drive when you use your computer to access our website.

5.2 Cookies are often used to record the habits and preferences of visitors when browsing various items on our website. The information collected by cookies is anonymous collective statistical data and does not contain personal data.

5.3 Cookies cannot be used to obtain data on your hard drive, your email address, and your private data, which enable this website or service provider system to recognize your browser and capture and remember information. Most browsers are preset to accept cookies. You can choose to set your browser not to accept cookies, or to notify you as soon as a cookie is loaded. However, if cookies are disabled, you may not be able to activate or use certain features of our website.

6. Information use

6.1 We use the information we collect about you for the following purposes or in the following ways:

• 6.1.1 to process your registration and provide you with the services provided by this website;

• 6.1.2 to notify you of any changes to our services;

• 6.1.3 According to the requirements of the competent authorities of the relevant sovereign countries or regions, report to the relevant regulatory authorities

• 6.1.4 When you use the services provided by this website, this website uses your information for legitimate purposes, such as identity verification, customer service, security, fraud monitoring, marketing and promotion, archiving and backup, or with the The three parties jointly promote this website to ensure the security of the products and services provided by this website to you;

• 6.1.5 Collect and process information to help this website design new products and services and to improve existing services provided by this website;

• 6.1.6 In order to enable you to understand the specific content of the services provided by this website, you agree to allow this website to send you from time to time relevant marketing activity information (company news, promotional information and information provided by HKD.com information about products and services), commercial electronic information and advertisements in lieu of generic, full-scale advertisements;

• 6.1.7 to invite you to participate in surveys related to the services offered on this website;

• 6.1.8 Data analysis in cooperation with government agencies, public affairs agencies, associations, etc.;

• 6.1.9 Process billing and collect any charges;

• 6.1.10 Personalize your experience (your information will help us better respond to your personalized needs);

• 6.1.11 We have adopted international standards to prevent money laundering, terrorist financing, evasion of trade and economic sanctions, and we will implement the final virtual asset terms and rules when they come into effect, which requires us to conduct due diligence on our customers. This may include cross-checking your personal information with their data using third-party data and service providers.

• 6.1.12 for all other lawful uses and other uses authorized by you.

6.2 We will not sell, trade or otherwise transfer information to or allow others to collect or use information, but does not include the following other parties and the following information: our affiliates, help us operate our website, conduct business, or trusted third parties who provide services to you, as long as those parties agree to keep the information confidential; when we believe the disclosure is appropriate, in compliance with laws, regulations, rules or regulations, or from a court or other Orders of competent authorities, to enforce our website policies, necessary for the proper functioning of the website, as necessary for affiliates to provide services, or to protect our or others' rights, property or safety.

6.3 After you terminate the use of the platform services, we will stop the collection and use of your information, unless otherwise stipulated by laws, regulations or regulatory authorities. If we stop operating, we will promptly stop the collection of your personal information, notify you of the cessation of operations in the form of one-by-one delivery or announcement, and delete or anonymize your personal information held.

7. Protection of personal data

7.1 We implement appropriate physical, electronic, managerial and technical measures to protect and secure your personal data. We endeavour to ensure that any personal data collected through our website is free from nuisance by any third party unrelated to us. The security measures we take include but are not limited to:

• 7.1.1 Physical Measures: Records containing your personal data will be kept in a locked area.

• 7.1.2 Electronic Measures: Computer data containing your personal data will be stored on computer systems and storage media with strict access restrictions.

• 7.1.3 Management measures: We have established relevant departments for the security protection of user information, and established relevant internal control systems. We adopt strict authorization principles for staff who may have access to your information. Only those authorized by us Access to your personal data is restricted to our staff, who are required to abide by our internal code of conduct for the confidentiality of personal data. In addition, we continue to strengthen publicity on relevant laws and regulations, privacy and security guidelines and security awareness for staff training, and regularly organize relevant internal personnel to conduct emergency response training and emergency drills, so that they can master job responsibilities and emergency response strategies and procedures

• 7.1.4 Technical measures: encryption technology such as Secure Socket Layer Encryption may be used to transmit your personal data.

• 7.1.5 Security measures: In order to ensure the security of your information, we are committed to using a variety of current general security technologies and supporting management systems to minimize your information being leaked, damaged, misused, unauthorized access, unauthorized Risk of Disclosure and Change. For example: encrypted transmission through network security layer software (SSL), encrypted storage of information, and strict restrictions on data center access. When transmitting and storing personal sensitive information (including personal biometric information), we will adopt security measures such as encryption, permission control, de-identification, and desensitization.

• 7.1.6 Additional measures: Regularly review our personal data collection, storage and processing procedures; and restrict access to your data by our employees and suppliers as necessary Adhere to strict contractual confidentiality obligations.

7.2 If you become aware of any security breach on our website, please contact us immediately so that we can take appropriate action as soon as possible.

7.3 Despite the implementation of the above technical and security measures, we cannot guarantee the absolute security of the transmission of data over the Internet, therefore we cannot absolutely guarantee that the personal data you provide to us through our website will be safe at all times. We are not responsible for any incidents arising from unauthorised access to your personal data, and we are not responsible for any loss or damage incurred or caused in this regard.

8. Revision of Privacy Policy

Wereserves the right to modify this Privacy Policy at any time. We notify you that we have revised the Privacy Policy by updating and publishing the effective date of the new version, and sometimes we will post a notice to let you know that the Privacy Policy has been revised, but this is not our obligation. You should periodically review the Privacy Policy and pay attention to its revisions, and if you do not agree with the revisions, you should stop accessing this website immediately. When an updated version of the Privacy Policy is posted, your continued access to this website shows and indicates that you agree to the updated content and agree to abide by the updated Privacy Policy.

9. Access, Correction and Deletion of Your Personal Data

You have the right to obtain a copy of your personal data upon request and to ascertain whether the information we hold about you is accurate and up-to-date. If any of your personal data is inaccurate, you can request that your information be updated. You can also request deletion of your personal data, but we may deny your deletion request in certain circumstances, such as for legal requirements or other legal purposes. For data access, correction or deletion requests, please contact [e-mail]. In response to data access, correction or deletion requests, we will verify the identity of the requesting party to ensure that he/she is legally entitled to make such requests. While it is our goal to respond to these requests free of charge, we reserve the right to charge you a reasonable fee if your request is repetitive or burdensome. If you confirm to terminate the use of the services of this platform and need to cancel your account, you can cancel it through the relevant function interface or directly communicate with our customer service. When you meet the agreed account cancellation conditions and cancel your account on this website, all the information in your account will be cleared, and we will no longer collect, use or provide external personal information related to the account, but you We still need to save the information provided or generated during the use of the services of this website for the time required by the supervision, and cooperate with the inquiries of the competent authorities in accordance with the law within the storage time.

10. Communication with us

10.1 If you have any requests and comments, you can email [e-mail], this is the only valid and official email for us to communicate with you, so we do not use valid contact information for you, any No responsibility for actions or omissions.

10.2 We only publish announcements and information through valid contact information on this website or post announcements on this website, so we are not responsible for any loss arising from your trust in information not obtained through the above methods.

10.3 If you have any questions about our Privacy Policy, please feel free to contact us.