Privacy Policy – VOOX

1. INTRODUCTION

VOOX (hereinafter referred to as “the Company”) is committed to safeguarding the security of users’ personal information at all times. When the Company provides services to registered users, we need to collect and maintain personal information, utilizing your personal data to offer access and application services through our digital asset trading platform, software, APIs (Application Programming Interfaces), products, and/or features (“Services”). Therefore, the Company discloses how personal information is used and the measures taken to protect it through this Privacy Policy.

Our privacy policy is subject to change due to changes in laws or guidelines related to the protection of personal information or changes in our policies, so please check with us whenever you visit our site.

2. PURPOSE

The personal data collected, processed, and stored by the company is obtained through your use of our services and with your consent. This personal data may include your contact details, copies of identity information you have provided or obtained from publicly accessible databases, your government-issued identification number, passport number, email address to verify your identity and confirm your customer status, or any information related to your device or internet service (such as IP address and MAC number). The company uses personal data to communicate with you and to manage, fulfill, improve, and personalize the services provided to you.

3. CONTROLLER AND CONTACT DETAILS

According to relevant regulations, the following technical and management protection measures are implemented to ensure security：

Minimization and training of staff handling personal information
We designate employees who handle personal information and limit them to the person in charge, and implement measures to manage personal information.
Regular self-audit conducted: We conduct our own audits on a regular basis (quarterly basis) to ensure the safety of handling personal information.
Establishment and implementation of internal management plan: We have established and implemented an internal management plan for the safe handling of personal information.
Encryption of personal information: The personal information of the user is encrypted and stored and managed so that only the user can know it, and the important data uses separate security functions such as encrypting the file and transmission data or using the file lock function.
Technical measures against hacking: The company installs security programs, periodically updates and checks, installs systems from outside controlled areas, and technically and physically monitors and blocks them to prevent leakage and damage of personal information caused by hacking or computer viruses.
Restrict access to personal information: We take necessary measures to control access to personal information through granting, modifying, and deleting access to the database system that handles personal information, and we control unauthorized access from outside by using an intrusion prevention system.
Keeping connection logs and preventing forgery: We keep and manage the records of access to the personal information processing system for at least six months, and we use security features to prevent forgery, theft and loss of access records.
Using a lock for document security: We keep the documents containing personal information and the auxiliary storage medium in a safe place with a lock.
Access control to unauthorized persons: We keep separate physical storage places for personal information and set up access control procedures for them.

4. WHAT PERSONAL DATA WE COLLECT AND HOLD, AND HOW WE COLLECT IT

VOOX collects, processes, and stores Personal Data via your use of the Service or where you have given your consent. This Personal Data may include contact details, copies of identification documentation provided by you or derived from publicly accessible databases, your government identification number as well as information relating to your device or internet service (such as an IP address and a MAC number).

We collect information you provide during the VOOX Platform on-boarding process, which may be a completed, incomplete, or abandoned process. We also collect Personal Data when you communicate with us through customer support, subscribe to marketing communications, correspond with us by phone, email, or other communication channels, or when you conduct a transaction on the VOOX Platform. We may actively or automatically collect, use, store, or transfer your Personal Data, which may include, without limitation, the following:

Personal identification information such as name, email, phone number, nationality, date of birth, face data, address, and government identification information;
Institutional details such as corporate legal name, corporate registration information, government identification number, proof of identity and legal existence, address, business description, and beneficial owner information;
Commercial information such as data related to transactions conducted on the VOOX Platform;
Financial information such as credit/debit card numbers and bank account information;
Correspondence Information such as communication with our Customer Support team and response to user survey;
Information required by regulatory agencies such as state and federal licensing authorities and consumer protection agencies; and
Other identifiers such as device fingerprint data, IP address, and geolocation information.

We may also collect Personal Data about you from third parties, such as electronic verification services, referrers, marketing agencies or liquidity providers. If so, we will take reasonable steps to ensure that they are made aware of applicable privacy laws. We may also use third parties to analyze traffic on our website, which may involve the use of cookies. Information collected through such analysis is not anonymous.

We will not collect sensitive information about you without your consent, unless an exemption or exception applies. These exemptions or exceptions include if the collection is required or authorized by law, or if it is necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.

If the Personal Data we request is not provided by you, we may not be able to provide you with the benefit of our Services or meet your needs appropriately. Accordingly, we do not give you the option of dealing with us anonymously or under a pseudonym.

Furthermore, we conduct business and collect Personal Data from individuals and entities located in various jurisdictions in accordance with data protection laws. Where applicable, we are required to protect Personal Data processed in such jurisdictions in accordance with the applicable data protection laws. To understand more about how we protect the data collected from individuals and entities located within such jurisdictions.

5. UNSOLICITED PERSONAL DATA

When a user joins a customer to use customer service, the company receives online information that is essential for providing the service. The essential information you receive when you sign up is your name, email address, and so on. Also, in order to provide high quality service, users can input optional phone numbers and bank account number And we can also request personal information for statistical analysis or offers of prizes during surveys or events at the exchange.

We do not collect sensitive personal information that violates human rights. If it is necessary to collect such information, we will seek your prior consent. In any case, the information you provide will not be used for any other purpose and will not be disclosed.

6. WHO WE COLLECT PERSONAL DATA ABOUT

The Personal Data we may collect and hold includes (but is not limited to) Personal Data about users, potential users, service providers or suppliers of the VOOX Platform or our Services, prospective employees, employees and contractors and other third parties with whom we come into contact.

7. HOW WE USE YOUR PERSONAL DATA

VOOX uses Personal Data to administer, deliver, improve, and personalize the Services for you and to comply with our legal and regulatory obligations. We may also use such data to communicate with you in relation to other products or services offered by its partners to consider any concerns or complaints you may have.

We may use and disclose your Personal Data for any of these purposes. We may also use and disclose Personal Data for secondary purposes that are related to the primary purposes set out in this section, or in other circumstances authorized by the law.

Sensitive Information will be used and disclosed for the purpose for which it was provided (or a directly related secondary purpose), unless you explicitly consent otherwise, or an exemption under law applies.

We will use your Personal Data that we collect for the following purposes or in the following ways:

To provide you with our Services through our Sites pursuant to our User Agreement;
To identify and confirm your identity when you use our Sites and/or Services;
To improve and enhance the Services and/or Sites (your information and feedback received by us can help us improve the Services and the functions and performances of the Sites, so that we can more effectively respond to your enquiries and other needs);
To keep statistics relating to the use of our Sites and to be used for data analysis carried out in cooperation with government agencies and/or public affairs institutions;
To better understand how users access and use the Sites in order to personalize your experience (your information will help us to better respond to your personalized needs);
To facilitate transactions (your information, whether public or private, will not be sold, exchanged, transferred, or otherwise provided to any other company on any grounds without your consent, except for where doing so is expressly for the purpose of completing the transaction you require);
To carry out product marketing including newsletters, updates, related products or Services information (you can opt out at anytime if you do not wish to receive marketing communications from us);
To communicate with you about your account, activities on our Services, and policy changes including but not limited to requesting for any additional information or documentation;
To maintain the security of your account and the Sites, including without limitation, to carry out two-factor authentication;
To assess your credit risk;
To assess your risk score according to parameters determined by us;
To detect and reduce risks of fraud;
To enforce/defend our rights, agreements and/or policies;
To satisfy additional purposes with your consent;
To comply with applicable laws, regulations and/or orders required by competent authorities; and
To meet other purposes as specified in the User Agreement of the Sites, or other reasonably expected business purposes as permitted by law or when required to comply with legal obligations.

We do not sell, trade, or otherwise transfer your Personal Data or allow third parties to collect, access or use your Personal Data; however, you agree that we may disclose and transfer your Personal Data in the following circumstances:

To our affiliates (includes subsidiaries, holding companies and companies under common control including their respective contractors, affiliates, employees or representatives);
To service providers and other trusted third parties who assist us in operating our Sites, manage our business, or provide Services to you, provided that such parties agree and have adopted appropriate measures to keep such information confidential;
To our professional advisors, including accounting, legal or other consulting services for purposes of complying with our legal obligations or audits;
To entities in connection with any corporate financing, merger, acquisition, due diligence, reorganization, receivership, or dissolution proceedings which involve disclosing certain portion or all of our business or assets;
When we believe that relevant information disclosure is appropriate, or it is required by any applicable laws, regulations, rules, requests, subpoenas or order of courts, law enforcement agencies or other competent authorities, and is necessary for uting the strategy of our Sites and ensuring the proper functioning of the Sites, or as may be necessary to provide Services, or for the protection of the rights, property or safety of us or other persons.

If we disclose your Personal Data to service providers or third parties that perform business activities for us, they may only use your Personal Data for the specific purpose for which we supply it.

Your information will not be provided to other parties for marketing, advertising or other similar purposes. We have implemented international standards to prevent money laundering, terrorist financing and circumventing trade and economic sanctions, which requires us to undertake due diligence on our customers. This may include the use of third-party data and services providers which we will cross-reference with your Personal Data for detecting fraud, verifying identity, verifying credit risk and monitoring transactions.

8. REGARDING THE USER'S PERSONAL INFORMATION MANAGEMENT (READING, CORRECTING, DELETING, PROTECTING, ETC)

Users can log in to our website at any time and read or correct the user's personal information by changing the customer's information In addition, we will correct it if you request it by e-mail or in writing to the person in charge of personal information management on the company's homepage However, the customer ID and the name can not be corrected.

Users may terminate the Agreement at any time, stopping the use of your personal information by third parties who provide the Services, and may also terminate the Agreement by e-mail, telephone, fax or other means. In this case, the user must provide his or her ID and e-mail address for proof of identity.

We adopt appropriate physical, electronic, management and technical measures to protect and safeguard the security of your Personal Data. We will, to the greatest extent possible, ensure that any Personal Data collected through our Sites shall not be subject to nuisance by any third party unrelated to us. The security measures that we may implement include but are not limited to:

Physical measures: Records of your Personal Data will be stored in a properly locked and secure place.
Electronic measures: Electronic data that contains your Personal Data will be stored in computer s and storage medias that are subject to strict login restrictions.
Management measures: Only employees and vendors on a need-to-know basis duly authorized by us can access your Personal Data, and these employee and vendors shall be subject to strict contractual confidentiality obligations.
Technical measures: Encryption techniques such as Secure Socket Layer Encryption may be used to convey your Personal Data.
Other measures: “Firewall” are in place to protect our network servers.

If you are aware of any security flaws in our Sites, please contact us immediately so that we can take appropriate actions as soon as possible.

Despite the above-mentioned technical and security measures, since no system is 100% secure, we cannot guarantee that the information transmitted via the Sites is absolutely secure, so we cannot guarantee nor warrant that the Personal Data that you provide to us through our Sites will be safe at all times. To the fullest extent permitted by applicable laws, we will not be held liable for any losses or damages arising from or caused by any event that may occur in connection with unauthorized access to your Personal Data, and we shall not be held liable for compensation for such losses or damages.

9. DATA RETENTION

We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security.

We keep Personal Data only for as long as is reasonably necessary to provide Services to you, to fulfil the purpose(s) for which it was collected, to comply with any applicable legal or ethical reporting or document retention requirements, pursue legitimate business purposes, enforce our agreements and resolve disputes. We will not retain your Personal Data in a form that permits the identification of the data subject for longer than needed for the legitimate purpose or purposes for which we originally collected it, including for the purpose of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we will anonymize your personal information so that it can no longer be associated with you, in which case we will use such information without further notice to you.
At the end of the retention period, we will securely delete or destroy data retained, and require our sub-processors or third-party suppliers to do likewise.

10.Age Restrictions

Our Platform and Services are not intended for use by minors , and we do not knowingly gather personal information from those under 18 years of age ("Minor"). If you are under 18, please do not use our Services.

If we discover that we have accidentally collected personal data from a minor without appropriate consent, we will promptly remove the information and take steps to have the minors’ account closed on our Platform as quickly as possible.

11. MATTERS CONCERNING THE OPERATION OF COOKIES (COOKIES)

In order to provide customized services tailored to the customers, the company operates 'cookies'(cookies) to store and retrieve information from time to time. The company identifies your computer with respect to cookie management, but does not personally identify you.

The user has a choice of 'cookies' and the user can accept all cookies by selecting [Tools]> [Internet Options]> [Security]> [User Defined Level] in the web browser, check each time a cookie is saved, or refuse to store all cookies However, if you refuse to store all cookies, you will not be able to use the services provided by the company through cookies.

12. PERSONAL INFORMATION ADMINISTRATOR AND PERSON IN CHARGE

We are making every effort to ensure the security of users' personal information. If you notice any abnormal use of your information, please contact our customer support immediately.

The user ID password is privately managed by the user, and no one is allowed to request the user's password in any way. Users must always protect the security of their passwords and should not disclose them to others.

If your ID password is leaked, we can provide technical remedies. However, we are not liable for any accidents caused by basic network risks such as hacking.

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