This platform is a platform dedicated to users to trade digital assets and provide related services (hereinafter referred to as «the Service» or «the Service»).For the convenience of expression, the platform collectively called «we» or other first person name in this Agreement, as long as the natural persons or other entities landing on the platform are users of the platform, the following use «you» or other second person, we and you as «parties», we or you alone as «party».

We fully understand and respect the importance of your personal information to you, and we will take corresponding security protection measures to protect your personal information security.In view of this, develop this Privacy Policy (this Policy / this Privacy Policy «) and remind you that:

This policy applies to all of the products and services that we provide.If we have a separate privacy policy for your product or service, its separate privacy policy shall apply if we have no separate privacy policy.

In particular, this policy does not apply to other services provided to you, and the services provided to you shall apply to the privacy policy stated to you.

Before using our products or services, please must carefully read and thoroughly understand this policy, especially the terms marked in bold / bold underline, you should focus on reading, after confirming full understanding and consent.If you have any questions, comments or suggestions on this policy, you can contact us through various contact information provided by our officials.If you do not agree to any provision of this policy, you should immediately stop having access to the platform.


Part I: The Definition

Personal information: refers to various information recorded in electronic or other means that can identify the identity of a specific natural person or reflect the activities of a specific natural person alone or combine with the activities of a specific natural person.

Personal sensitive information: refers to personal information including ID certificate number, personal biometric information, bank account number, property information, whereabouts track, transaction information, information of children under the age of 14 (including), etc. (we will significantly identify the specific personal sensitive information in bold in this Privacy Policy).

Personal information deletion: refers to the behavior of removing personal information in the system involved in the realization of daily business functions, so that it cannot be retrieved and accessed.

Child: refers to a minor under the age of 14.


Part II, The Privacy Policy

This Privacy Policy section will help you understand the following:

Ⅰ. How do we collect and use your information

Ⅱ. How do we use Cookie and similar technologies

Ⅲ. How do we share, transfer, and publicly disclose your information

Ⅳ. How can we protect your information

Ⅴ. How do you manage your information

Ⅵ. How do we deal with the information of minors

Ⅶ. How to update this privacy policy

Ⅷ. How to contact us


Ⅰ. How Do We Collect And Use Your Information

When you use our products and / or services, your personal information we need / may collect and use includes:

1. Authorise us to provide you with our products and / or services.If you refuse to provide the appropriate information, you will not be able to use our products and / or services normally;

2. To implement additional functions to provide us with our products and / or services, you can choose to authorize the information we need to collect and use.If you refuse to provide it, you will not be able to use the relevant additional functions or achieve the functions that we plan to achieve normally, but it will not affect your normal use of the basic functions of our products and / or services.

You understand and agree that:

1. We are committed to creating a wide variety of products and services to meet your needs.Because there are many kinds of products and services we provide you, and the specific products / services that different users choose to use, the corresponding basic / additional functions and personal information collected and used will be different, please refer to the specific product / service functions;

2. In order to bring you a better product and service experience, we are strive to improve our technology, and we may introduce new or optimized features from time to time, which may need to collect, use new personal information or change the purpose or way personal information is used.In this regard, we will explain to you the collection purpose, scope and use method of the corresponding information by updating this policy, popup and page prompts, and provide you with a way to agree, and collect and use it after obtaining your express consent.In this process, if you have any questions, comments or suggestions, you can contact us through the various contact information provided by this platform, and we will answer them for you as soon as possible.

We will collect and use your personal information to implement the following functions described in this policy:

(I) Help you to register and provide you with the services provided by the platform; 1. Registration service

We provide you with basic membership services through our platform account.In order to register as a member and use our membership services, you will need to fill in and provide the following information when applying for registration:

(1) Identity information.This information can help us to verify whether you are eligible to register as a member of the Platform, including but not limited to your name, your residential address, other certificates issued by your country or government that prove your identity information, and the numbers involved and all other information that can help us to verify your identity (hereinafter referred to as the «Identity Information»).This identity information varies depending on whether you are an individual or an institutional user, and the information we collect for users from different countries or regions may vary according to the laws and regulations of different jurisdictions.The following information and data serve as an indicative example:

Individual users: nationality, legal full name (including name and local name), id number, email address, telephone number, social security number («SSN»), passport number or any id number issued by the government, date of birth, identification (such as passport, driver license or identification issued by the government).

Institutional users: company legal name (including legal name of local language), registration information, business telephone number, authorized representatives and authorized user personal information, main place of business, personal information of all beneficial owners), beneficial owner shareholders / identity documents (passport or government issued id card), company structure, corporate documents, board resolution, funding sources, risk and compliance control instructions and other information or documents required by the platform.

(2) Service information.This information helps us to contact you and successfully provide you with different modes of digital interasset transaction services, including, but not limited to, your personally identifiable information, contact information, transaction information, and your debit card information and / or other account information (hereinafter referred to as the «Service Information»).At the same time, please understand that the service we provide to you is constantly updated and evolving.If you choose to use other services not covered in the above description, and we need to collect your additional information based on the service, we will explain the scope and purpose of information collection through page prompt, interaction process, agreement, pop-up prompt, etc., and obtain your consent.

If you only need to use the browsing service, you do not need to register as our member and provide the above information.

2. Other registration services

Real-name authentication: When you register and log in, you need to enter the «Personal Center» to complete the real-name authentication. You need to provide your real name, ID number or passport number to the platform during the process of using the real-name authentication.

Advanced certification: When your transaction volume in the platform exceeds a certain limit, the platform will require your advanced certification in order to maintain the security of your assets.In addition to the real-name authentication information, you recognize the platform to you «face recognition» advanced authentication, face recognition will involve the platform of your related video stream or face image collection.

Account information display: if you have this platform account, we may display your personal information in the service (real-name authentication only show authentication through the result), and you in the platform account related products and services, including through this platform account centralized display your personal data, transaction orders.We will respect your choice of platform account setting.

(Ⅱ) Security management services and service information push services When you use the services provided or access the platform, to ensure the security and safe operation of your services, we need to automatically receive and record your Web browser information, device information on your login account (IDFA, operating system, device model, equipment manufacturer, system version, Android ID s, IMEI, MAC address, etc.), IP address and records, region, network environment, device fingerprint information, service log information, software information, location information, etc.

Note that separate device information is information that cannot identify the identity of a specific natural person.If we will this kind of non-personal information and other information used to identify a specific natural person identity, or combined with personal information, during the combined use, this kind of personal information will be regarded as personal information, in addition to your authorization or laws and regulations, we will do this kind of information anonymity, identification processing.

To provide you with more convenient, more in line with your personalized needs of information display and push service, we may in the future according to your device information and your platform or client browsing use information, extract your preferences, and based on characteristic label output indirect crowd portrait, for display, push information and possible commercial advertising.If you do not agree to receive such push information or withdraw your consent to collect personal information, you may contact us in accordance with the contact information provided in this policy.

We strive to secure your browsing experience.If you do not want to accept the commercial advertisement we send you, you can unsubscribe or close by SMS prompt reply to unsubscribe or the other means we provide.

In addition, we will use your above information in order to continuously improve and optimize the above features.

(Ⅲ) Transaction record storage and inquiry service We collect relevant data on your exchanges on this platform, including but not limited to trading records.If you need to query your order transaction records, you can query your personal transaction details in the platform «Order Management», including: the counterparty nickname, order time, order number, transaction information, digital asset type and quantity, etc.

(Ⅳ) Customer service and dispute settlement When you contact us or apply for after-sale and dispute settlement, to secure your account and system, we need you to provide the necessary personal information to verify your membership.

In order to contact you, help you to record the problems and results, we may save you and our communication records and related content (including account information, order information, other information you provide to prove the relevant facts, or your contact information), if you consult, complaints or advice, we will use your account information and order information.

For a reasonable need to provide the service and improve the quality of the service, we may also use other information about you, including the relevant information you provide when you contact the customer service, and the questionnaire response information you send to us when you participate in the questionnaire survey.

(Ⅴ) Other 1. If the information you provide contains the personal information of other users, you need to ensure that you have obtained the legal authorization before providing such personal information to the platform.If the child's personal information is involved, you need to obtain the consent of the corresponding child guardian before the release. Under the aforementioned circumstances, the guardian has the right to contact us through Article 9 of this policy to correct or delete the content involving the child's personal information.

2. If we use the information for other purposes not specified in this policy, or if we use the information collected for a specific purpose for other purposes, or if we voluntarily obtain your personal information from a third party, you will obtain your prior consent.

If we indirectly obtain your information from a third party, we will require the third party to collect personal information after obtaining your consent and inform you of the shared information, and the third party, we will reinforce the personal information (including sensitive information reporting, encryption storage, access control, etc.).We will use equal protection for our own personal information and measures to protect indirectly obtained personal information.

3. Exceptions to authorized consent

You fully understand and agree that we do not require your authorized consent to collect and use your personal information and we may not respond to your requests for correction / modification, deletion, write-out, withdraw consent, or request information if:

(1) Related to national security and national defense security;

(2) Related to public safety, public health and major public interests;

(3) Related to judicial or administrative law enforcement such as crime investigation, prosecution, trial and judgment execution;

(4) Due to protect your major legitimate rights and interests but it is difficult to obtain your consent;

(5) Your personal information that you will disclose to the public;

(6) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

(7) It is necessary to sign into and perform the relevant agreements or other written documents with you;

(8) necessary to maintain the safe and stable operation of the products and / or services provided, such as the discovery and disposal of faults of the products and / or services;

(9) necessary for legal news reporting;

(10) Deidentifying the results obtained when an academic research institution is necessary to conduct statistical or academic research institutes based on the public interest, and provides the personal information contained in the results;

(11) Other circumstances as stipulated by laws and regulations.

Be aware that any technical and other necessary measures to process personal information to reidentify, or may deidentify the collected information for research, statistical analysis, and prediction to improve the content and layout of the platform, provide product or service support for business decisions, and improve our products and services, including machine learning or model algorithms).

4. If we stop operating the products or services of the platform, we will timely stop the activity of further collecting your personal information, notify you of the notice of stopping the operation in one by one service or announcement, and delete or anonymize the personal information we hold related to the closed business.

Ⅱ. How Do We Use Cookie

You can modify your acceptance of Cookie or reject our Cookie s if you allow your browser or browser add-on services.But if you do so, in some cases, it may affect your secure access to our platform, and you may need to change the user settings every time you visit our platform.You understand and agree that:

1. When you visit our platform, we use Google Stats to record our performance and check the effectiveness of online advertising.Cookie is a small amount of data sent to your browser and stored on your computer's hard drive.Cookie can only be sent to your computer's hard drive when you use your computer into our platform.

2. Cookies is often used to record visitors' habits and preferences when browsing various projects on our platform.The data collected by Cookies is anonymous collective statistics and does not contain personal data.

3. Cookies cannot be used to obtain the data on your hard disk, your email address, and your private data. It enables the platform or service provider system to identify your browser and capture and remember the information.Most browsers are preset to accept the Cookies.You can choose to set your browser not to accept Cookies, or notify you as soon as Cookies is installed.However, if set to ban Cookies, you may not be able to start or use some features of our platform.

Ⅲ. How Do We Share, Transfer, And Publicly Disclose Your Information

(Ⅰ) Sharing We do not share your personal information with companies, organizations, and individuals other than the platform service provider, except where:

1. Sharing under legal circumstances: We may share your personal information in accordance with the provisions of laws and regulations, litigation, dispute resolution needs, or the requirements of administrative and judicial organs.

2. Share with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

3. Share under your active choice: We will share the necessary information related to the transaction with the counterparties of digital assets according to your choice, so as to realize your transaction and after-sales service needs.

4. Share with authorized partners: Our related parties, trusted third parties who help us operate our platform, conduct business, or provide services to you, so long as they agree to keep this information confidential, when we believe that laws, regulations, regulations or from the court or other authorities, or protect the rights, property or security of us or others.

(Ⅱ) Transfer We will not transfer your personal information to any company, organization or individual, except where:

1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

2. In the platform of merger, acquisition or bankruptcy liquidation, or other involving merger, acquisition or bankruptcy liquidation, such as involves personal information transfer, we will require new hold your personal information company, organization will continue to be subject to this policy, otherwise we will require the company, organizations and individuals to ask your authorization consent.

(Ⅲ) Public disclosure We will publicly disclose your personal information only if:

1. We may publicly disclose your personal information based on your express consent or based on your active choice;

2. If we determine that you violate laws and regulations or serious violation of the platform related agreements and rules, or to protect the platform users or the public, we may according to laws and regulations or with your consent about your personal information, including related violations and the platform has taken measures to you.

(Ⅳ) Exceptions to prior authorization for sharing, transferring or public disclosure of personal information You are required to share, transfer or publicly disclose your personal information without:

1. Related to national security and national defense security;

2. Related to public safety, public health and major public interests;

3. Related to judicial or administrative law enforcement such as crime investigation, prosecution, trial and judgment execution;

4. Due to protect your major legitimate rights and interests but it is difficult to get my consent;

5. Your personal information you disclose to the public;

6. Collect personal information from legally and publicly disclosed information, such as legal news reports, government information disclosure and other channels.

Please be aware that if we take technical and other necessary processing of personal information to prevent the data recipient from re-identifying a specific individual and cannot recover, the sharing, transfer and public disclosure of such processed data.

Ⅳ. How Can We Protect Your Information

1. We implement proper physical, electronic, management and technical measures to protect and secure your personal data.We try to ensure that any personal information collected through our platform is free from any third party nuisance unrelated to us.The safety measures we take include, but are not limited to:

(1) Physical measures: The records of your personal data will be stored in a locked place.

(2) Electronic measures: Computer data with your personal data will be stored on computer systems and storage media subject to strict login restrictions.

(3) Management measures: we set up internal security protection of user information, and established the relevant internal control system, to possible access to your information staff adopt strict authorization principle, only our authorized staff to your personal data, the staff need to abide by our personal internal rules of data confidentiality.In addition, we continue to strengthen the publicity of relevant laws and regulations on staff training, privacy and safety standards and safety awareness, and regularly organize internal relevant personnel to conduct emergency response training and emergency drills, so that they can master the job responsibilities and emergency response strategies and procedures

(4) Technical measures: An encryption technology such as Secure Socket Layer Encryption may be used to deliver your personal data.

(5) Security measures: In order to ensure your information security, we are committed to using a variety of current general security technologies and supporting management systems to minimize the risk of your information disclosure, damage, misuse, unauthorized access, unauthorized disclosure and change.For example, through the network security layer software (SSL) encryption transmission, information encryption storage, strictly limit the access to the data center.When transmitting and storing personal sensitive information (including personal biometric information), we will adopt security measures such as encryption, permission control, deidentification and desensitization.

(6) Other measures: Regularly review our personal data collection, storage and processing process; and restrict our employees and suppliers' access to your data according to the necessary principles, and our employees and suppliers shall observe strict contract confidentiality obligations.

2. If you know of any security vulnerabilities on our platform, please contact us immediately, so that we can take appropriate action as soon as possible.

3. Despite the implementation of the above technical and security measures, we cannot guarantee the absolute safety of the information on the Internet, so we cannot absolutely guarantee that the personal information you provide to us through our platform is safe at all times.We will update and disclose the security risks, personal information security impact assessment reports and other related content from time to time, which you can obtain through the announcement on this platform.

Ⅴ. How Do You Manage Your Information

You can access and manage your information by:

(Ⅰ) Query, correct, and delete your information You are entitled to obtain a copy of your profile upon request and to determine whether the information we have about you is accurate and up to date.If any of your personal data are inaccurate, you can request updates to your information.You may also request that your personal data be deleted, but we may deny your deletion request in some cases, for example for legal requirements or other legal purposes.For data access, correction or deletion requests, you can contact us through the contact information in Article 8.

In response to data access, correct or delete requests, we will verify the identity of the requesting party to ensure that he / she is legally entitled to make such requests.While we aim to respond to these requests for free, we reserve the right to charge you a reasonable fee if your request is repeated or onerous.

(Ⅱ) Change the scope of your authorized consent Each business function requires some basic personal information to be completed (see Part I of this Privacy Policy).In addition to this, you can contact us to give or recover your authorized consent through the contact information in Article 8.

When you withdraw your consent, we will not process the corresponding personal information.However, your decision to withdraw your consent will not affect the prior processing of personal information based on your authorization.

(Ⅲ) Cancel your account You can contact us through the contact information in Article 8; after you cancel the account, we will stop providing you with products or services, delete your personal information or make anonymous by applicable law.

(Ⅳ) In response to your above request To be safe, you may need to provide a written request, or otherwise prove your identity.We may ask you to verify your identity before processing your request.

We will reply within 15 days.If you are not satisfied, you can also file a complaint through the contact information we provide.

We do not charge in principle for your reasonable request, but will charge for repeated requests.We may reject requests for information that is not directly related to your identity, unprovoked duplication, or excessive technical means (for example, developing new systems or fundamentally changing current practices), risks to the legitimate rights of others, or unrealistic.

We will not be able to respond to your request in the following circumstances:

1. Related to national security and national defense security;

2. Related to public safety, public health and major public interests;

3. Related to crime investigation, prosecution, trial and execution of judgment;

4. There is sufficient evidence to show that the subject of personal information has subjective malice or abuse of rights;

5. Responding to your request will seriously damage the legitimate rights and interests of you or other individuals and organizations;

6. Trade secrets are involved.

Ⅵ. How Do We Deal With The Information Of Minors

The platform is open to children, and if we find or suspect that the user is under the age of 14, we will ask the user to close his account and will not allow the user to continue using the platform products or services.We will delete the relevant information as soon as possible.If you know of anyone under 14 using our services, please inform us so that we can take action to prevent them from accessing our products or services.

For minors over the age of 14 but under the age of 18, we expect parents or guardians to guide minors in the use of our services.We will protect the confidentiality and security of minors' information in accordance with relevant laws and regulations.

If you are a minor, it is recommended that your parent or guardian read this policy and use our services or provide us with your information with the consent of your parents or guardian.To collecting your information with the consent of your parent or guardian, we will only use or publicly disclose this information if necessary by law, the express consent of the parent or guardian or the protection of your rights and interests.If your guardian does not agree that you use our services in accordance with this policy or provide us with information, please

If you are the parent or guardian of a minor, and when you have questions about the information processing of a minor in your custody, please contact us through the contact information published in this policy.

Ⅶ. How To Update This Privacy Policy

Our privacy policy may change.

We will not restrict your rights under this Privacy Policy without your express consent.We will post any changes to the privacy policy on the official channels.If you do not agree to the revision, you should stop having immediate access to the platform.When an updated version of the Privacy Policy is released, you continue access to this platform to display and indicate that you agree to the update and agree to comply with the updated Privacy Policy.

For major changes, we will also provide more significant notifications (including we will notify or even provide pop-up prompts on this platform).

Significant changes mentioned in this policy include, but are not limited to:

1. Our service model has changed significantly.Such as the purpose of processing personal information, the type of personal information processed, the use of personal information;

2. We have undergone major changes in our control rights.Such as the change of information controllers caused by mergers and acquisitions;

3. Changes in the main objects of personal information sharing, transfer or public disclosure;

4. Your rights to participate in personal information processing and their exercise methods have changed significantly;

5. We are responsible for handling the changes in the responsible departments, contact information and complaint channels for personal information security;

6. Personal information security impact assessment report indicates a high risk.

Ⅷ. How To Contact Us

1. If you have any requests and comments, you can email you at zhangtao@lianjingkeji.com, this is the only valid and official email we communicate with you, so we are not responsible for your not using valid contact information.

2. We only publish announcements and information through the effective contact information on the platform or post announcements on the platform, so we are not liable for any loss caused by your trust in the information not obtained through the above means.

3. If you have any questions about our privacy policy, please feel free to contact us.

4.If you have any questions and you wish to file a formal complaint, please contact us via customer_service@cpay.finance .Any dispute in the course of business which is not explicitly covered in our User Agreement will be governed by the laws of the relevant and applicable jurisdiction.

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