2024/08/17
1. Introduction
1.1 Who We Are
RWA Exchange is the world's first comprehensive trading service platform for real-world assets based on blockchain technology. It is dedicated to building a bridge between the trading of real-world asset tokens and digital currencies.
We deeply understand the importance of privacy and are committed to taking stringent measures to protect the security of your data and prevent data misuse. RWA Exchange provides services such as carbon asset Web3 tokenization and trading, AI computing power asset Web3 tokenization and trading, and real estate Web3 tokenization and trading. At the same time, we uphold our commitment to protecting user data privacy, confidentiality, and security.
1.2 Scope of the Privacy Policy
This privacy policy details the types of data we will collect, how it is used, shared, and protected, as well as your rights regarding your data, including the right to access and correct it. This policy applies to all individuals who have business dealings with us, including but not limited to investors, job applicants, and website visitors. Whether you interact with us through the website, phone, email, or other means, your data will be processed in accordance with the provisions of this privacy policy.
1.3 Policy Changes
We reserve the right to revise this privacy policy at any time. In the event of significant changes, we will notify you through the contact information you have provided or by posting updates on our website. It is recommended that you regularly review changes to this privacy policy. We will endeavor to notify you of important changes in advance to ensure that you fully understand and consent to the new policy. Any changes will take effect immediately upon publication, unless otherwise stated. If you continue to use our services after the policy changes, it indicates your acceptance of the new privacy policy.
1.4 Data Security
We will take reasonable measures to protect the security of user data and prevent unauthorized access, deletion, or use for other purposes. Our data security measures include, but are not limited to, encryption, access control, and regular security audits. We also require all employees to undergo data protection training and sign confidentiality agreements. We employ industry-standard security technologies and procedures to protect your data, including firewalls, data encryption, and access controls. Additionally, we regularly review our security policies and procedures to ensure their ongoing effectiveness.
1.5 Necessity of Data Provision
If you do not provide the necessary data, we may not be able to provide you with the required information, products, or services. For example, if you do not provide contact information, we will not be able to send you notifications or process your requests. We will clearly indicate the necessity of the required data at each step of data collection. Your data is essential for us to provide you with high-quality services. If you choose not to provide certain information, we may not be able to offer you complete services or meet your needs.
1.6 Acceptance of Policy
By accessing or using the RWA Exchange website and related applications, you acknowledge that you have read, understood, and agreed to the contents of this Privacy Policy. You have the right to withdraw your consent at any time, but this may affect the services we provide to you. We encourage you to read this Privacy Policy carefully before using our services to understand our data processing practices. If you do not agree with this Privacy Policy, please do not use our services.
1.7 Rejection of Policy
If you do not agree with this Privacy Policy, please do not use the RWA Exchange platform and the services it provides. We respect your choice and will endeavor to provide alternatives to ensure that you can still access some services. We understand the importance of privacy protection and are committed to offering flexible options to meet your privacy needs. If you have any questions or concerns about our Privacy Policy, please contact us at any time.
2. Data Collection
2.1 Personal Investor Data
When you apply for, subscribe to, and register for RWA Exchange’s products and services or consult with RWA Exchange, we will collect your personal information, including but not limited to: name, telephone number, mobile phone number, address, email address, fax number, gender, date of birth, age, job position, and interests. We may also collect financial information related to investments, such as bank accounts and transaction records. We may use various methods to collect this information, including online forms, phone calls, mail, and face-to-face interactions. The primary purpose of collecting this information is to ensure that we can provide you with personalized services and support.
2.2 Institutional Investor Data
When you apply for, subscribe to, or register for RWA Exchange’s products and services on behalf of an institution, or consult with us on related matters, we will collect the necessary institutional information, including but not limited to the following:
2.2.1 Institutional Contact Information:
Institution name, contact phone number, email address, fax number, and mailing address.
2.2.2 Institutional Representative Information:
Representative's name, position, gender, date of birth, and age.
2.2.3 Institutional Business Information:
Business scope, professional field, and service interests.
2.2.4 Financial Investment Information:
Bank account details and transaction records related to investments.
We collect this information through various methods, including online application forms, phone communications, email exchanges, and face-to-face meetings. The primary purpose of collecting this information is to ensure that we can provide you with customized services and professional support to meet the specific needs of your institution.
2.3 Job Applicant Data
To process your job application, we will collect the following information: name, telephone number, mobile phone number, address, email address, fax number, educational background, resume, transcripts, recommendation letters, etc. We may also conduct background checks to collect your employment history and other relevant information. We collect applicant data through various channels such as job websites, job fairs, and direct applications. We use this information to evaluate your qualifications, schedule interviews, and make hiring decisions.
2.4 Website Visitor Data
When you visit the RWA Exchange website, we automatically collect the following information: IP address, login information, browser type and version, geographic location, time zone setting, device type, operating system, browsing history, etc. This information helps us understand website usage and improve the user experience. We may use third-party analytics tools to collect and analyze this data to better understand user behavior and needs. By analyzing this information, we can optimize website content and structure to provide a better browsing experience for users.
2.5 Customer Support Data
When you contact our customer support team, we may collect additional information you provide, including your problem description, communication records, and any other relevant information. This data helps us better understand and resolve your issues and improve our products and services.
2.6 Social Media Data
If you interact with us through social media, we may collect your social media account information, publicly posted content, and other relevant data. We use this data to understand customer feedback, provide support, and conduct marketing.
2.7 Market Research Data
We may conduct market research and surveys to collect your feedback on our products and services. Participation in these surveys is voluntary, and we will collect and use this information only with your consent.
3. Data Usage
3.1 Usage of Personal Investor Data
We will use the collected personal information of investors to process applications, subscriptions, and registrations, manage accounts, provide products and services, register for relevant activities, design and use application software, respond to inquiries, conduct market research, and improve service experiences. We may also use your data for risk assessments and compliance checks. By analyzing this data, we can better understand investor needs and provide personalized advice and support.
3.2 Usage of Institutional Investor Data
We will use the collected institutional information to perform the following tasks:
3.2.1 Process institutional applications, subscriptions, and registration procedures.
3.2.2 Manage institutional accounts to ensure smooth and secure account operations.
3.2.3 Provide customized products and services to meet the specific needs of institutions.
3.2.4 Organize and register relevant activities to strengthen interaction and cooperation with institutions.
3.2.5 Design and optimize application software to suit institutional business processes and enhance user experience.
3.2.6 Respond promptly to institutional inquiries, providing professional answers and support.
3.2.7 Conduct market research to collect institutional feedback, guiding the continuous improvement of our services.
3.2.8 Utilize data analysis for risk assessment to ensure business compliance and stability.
By deeply analyzing this data, we can more accurately grasp the needs of institutions, providing more precise and personalized advice and support. We are committed to continuously improving service quality through these measures, offering institutions a more excellent cooperation experience.
3.3 Usage of Job Applicant Data
We will use the collected personal information of job applicants to evaluate and process job applications, keep application records, assess candidate qualifications, communicate employment opportunities, and fulfill human resource management functions. We may also use this information for internal audits and reporting to ensure the fairness and transparency of the recruitment process. We are committed to protecting the privacy of job applicants and will only use the data for legitimate and specified recruitment purposes.
3.4 Usage of Website Visitor Data
We will use the collected website visitor data to analyze user behavior, improve website functionality, customize content and advertisements, and enhance user experience. We may also use this data for website security monitoring to prevent fraud and abuse. By understanding user browsing behavior, we can optimize the website structure and content to increase user satisfaction.
3.5 Usage of Customer Support Data
We will use customer support data to process your requests, provide technical support, and resolve issues. We may record communication content to improve our customer support services and ensure that issues are effectively resolved.
3.6 Usage of Market Research Data
We will use market research data to analyze customer feedback, improve products and services, and formulate market strategies. Data collected from research participants will be anonymized to ensure your privacy.
3.7 Usage of Other Third-Party Data
In accordance with legal requirements and business needs, we may use data to fulfill contractual obligations, ensure legal compliance, conduct marketing, and provide customer service. We will ensure that all data usage complies with applicable laws and seek your consent when necessary. We will make every effort to ensure the lawful and transparent use of data while respecting your privacy rights.
3.8 Data Analysis and Improvement
We may use collected data for data analysis to improve our products and services. This includes identifying trends, formulating business strategies, and optimizing operational processes. Through data analysis, we can better understand customer needs and improve service quality.
4. Transmission of data
4.1 Transfers to Third Parties
We may transfer your data to agents, contractors or other third party service providers in order to provide you with the requested products and services. For example, we may share your data with payment processing companies, logistics companies and market research companies. We will ensure that these third parties comply with strict data protection standards. All cooperation with third parties will be based on clear contractual terms that ensure the security of your data.
4.2 Sharing Within the Group
We may share your data within our group in order to provide the products and services you have requested. This includes our parent company, subsidiaries and associated companies. We will ensure that all data shared within the Group is used only for legitimate and necessary purposes. Data sharing within the group will follow a uniform data protection policy to ensure that your data is equally protected across the group.
4.3 Cross-border Data Transfers
If your data needs to be transferred to another country or region, we will take appropriate measures to ensure that the data is transferred securely. This includes entering into a data protection agreement with the recipient and ensuring that it complies with protection standards equivalent to this Privacy Policy. Cross-border data transfers will be carried out in compliance with applicable laws and regulations and, where necessary, with your explicit consent.
4.4 Protection Measures
We will contractually or otherwise ensure that third parties take reasonable measures to protect your data. This includes requiring third parties to provide data protection assurances and conducting regular audits to verify compliance. We will continually monitor the data processing practices of third parties to ensure that they remain compliant with our data protection requirements.
4.5 Third party Data Processing
In some cases, third parties may process your data on our behalf. For example, we may commission external companies to carry out customer surveys or data analysis. We will ensure that all third party data processing activities comply with this Privacy Policy and protect your privacy.
5. Data Protection
5.1 Storage and Transmission
All data provided to us will be stored and transmitted securely. We will use encryption/security software to ensure data privacy and security against unauthorized access or disclosure. Our data centers use the latest security technology, including firewalls, intrusion detection and access control. We will also regularly update our security measures to address new security threats.
5.2 Access Restrictions
We will protect against unauthorized access, processing, deletion, loss or use by covenant or otherwise. We will only allow access to your data to employees who have a need to know the data and who are required to comply with strict confidentiality obligations. We will provide regular training to our employees to ensure that they understand and comply with the data protection policy.
5.3 Internet Transmissions
Although we will do our best to protect your data, we cannot guarantee the absolute security of information transmitted over the Internet. We recommend that you use a secure connection (e.g. HTTPS) when transmitting sensitive information and change your password regularly. We also recommend that you take additional security measures such as using strong passwords and enabling multi-factor authentication.
5.4 Data Backup and Recovery
We will back up data regularly to prevent data loss or corruption. Our data recovery plan ensures that normal operations can be resumed quickly in the event of an accident. We will periodically test our data recovery plan to ensure that it is effective in the event of an emergency.
5.5 Security Incident Response
We have established a security incident response program to respond to potential data breaches and other security incidents. We will take prompt action to mitigate the impact of the incident and notify affected and relevant regulatory agencies. We will also analyze the cause of the incident and take steps to prevent similar incidents from recurring.
6. Data Retention
6.1 Retention Period
We will retain your information for no longer than is necessary for the purposes for which it was collected, except where required by law. For different types of data, we will establish specific retention periods to ensure that the data is deleted or anonymized in due course.
6.2 Accuracy
We will take reasonable steps to ensure that the data we hold is accurate. We encourage you to regularly check and update your information to ensure that we are able to provide you with the best possible service. If your data is found to be inaccurate or incomplete, please let us know and we will correct it as soon as possible.
6.3 Retention of Recruitment Data
For information used for recruitment purposes, we will retain information for a maximum of two years from the date of rejection of an applicant, unless required by law or you agree to a longer retention period. We may retain your CV with your consent in order to contact you if a suitable position becomes available in the future. We will ensure that recruitment data retained is only used for lawful and defined purposes.
6.4 Data Destruction
At the end of the data retention period, we will securely destroy or anonymize your data to prevent unauthorized access or use. We will use secure data destruction techniques to ensure that the data cannot be recovered. We will also monitor the destruction process to ensure it complies with our data protection standards.
6.5 Data Backup Management
We will manage backup data appropriately to ensure that it is consistent with the master data and that it is securely deleted or anonymized at the end of the retention period. We will regularly review and update our backup management strategy to ensure it meets our data protection requirements.
7. Access and Correction of Data
7.1 Right of Access and Correction
In accordance with applicable law, you have the right to access, correct, delete or stop using your data. We will endeavor to ensure that your data is accurate, complete and up-to-date. You can exercise your data protection rights at any time by contacting us. Upon your request, we will take the necessary measures to protect your privacy.
7.2 Submission of Requests
Requests for access and correction of data should be made in writing and sent to our customer service e-mail address. We will ask you to provide identification to ensure that the request comes from the data subject. We may ask you to provide additional information to confirm your identity and process your request.
7.3 Reasonable Fees
We have the right to charge a reasonable fee for processing a data access request. We will inform you of the specific fee before we process the request and will begin processing the request upon receipt of the fee. We will ensure that the fee is reasonable and does not place an unreasonable burden on you to exercise your data protection rights.
7.4 Processing Time
We will endeavor to process your request within a reasonable period of time, usually no more than 30 days. If the request is complex or requires more time, we will notify you promptly. We will take all necessary steps to ensure that your request is dealt with promptly and fairly.
7.5 Rejection of Requests
In certain circumstances, we may deny your request for access or correction, such as when the request is unreasonable, abusive, or violates the law. We will provide you with the reasons for the denial of the request and inform you how to file a complaint or make further inquiries.
8. Transfer of Data
In the event of a business reorganization or change of control, your data may be transferred to a third party. We will ensure that the new data controller continues to comply with the terms of this Privacy Policy and notifies you prior to the transfer. We will take the necessary steps to ensure that the data transfer process is transparent and secure. After the data transfer, you still have the right to access, correct or delete your data.
9. Termination or Cancellation of Data
In the event of cancellation or termination of your relationship with us, we will cease processing your data as far as reasonably practicable, but will retain copies of the data as necessary to comply with legal obligations and to protect rights and property. We will take steps to ensure that retained data is used only for lawful purposes. We will delete or anonymize data that is no longer required as soon as possible to ensure that your privacy is effectively protected.
10. Use of Cookies
Our website uses cookies to enhance functionality and facilitate navigation.Cookies are small text files that are stored on your device and are used to record your preferences and activities. We use the following types of cookies:
10.1 Essential Cookies
These cookies are necessary for the website to function properly, including authentication, accessing secure areas and remembering user sessions. Essential Cookies ensure that you are able to navigate the website and use basic features without any problems.
10.2 Performance Cookies
These cookies collect information about how you use our website, such as the pages visited and errors encountered. They help us to improve the performance and user experience of our website. By analyzing the data collected by Performance Cookies, we can identify and resolve website performance issues and provide a smoother browsing experience.
10.3 Functionality Cookies
These cookies allow us to remember your choices and preferences, such as language settings and login information, in order to provide a more personalized service. Functionality Cookies enable us to provide you with content and services that are more relevant to your needs.
10.4 Advertising Cookies
These Cookies are used to deliver advertising content that is relevant to you and to measure the effectiveness of advertising campaigns. Advertising Cookies help us understand the effectiveness of our advertisements and optimize our advertising strategies to ensure that the advertisements you see are relevant to your interests and needs.
10.5 Managing Cookies
You can manage and delete cookies through your browser settings.Please note that disabling cookies may affect the functionality of the Website. We recommend that you enable or disable different types of cookies as necessary to ensure an optimal browsing experience.
11. Third-party websites
Our website may contain links to other websites whose content and privacy policies are not under our control. We recommend that you check the privacy policies of these third party websites to understand their data protection measures. We are not responsible for the privacy practices or the content of third party websites.
12. Children's Privacy
Our Services are not directed to children and we do not knowingly collect personal information from children under the age of 13. If we discover that we have collected personal information from a child without the consent of a parent or guardian, we will take steps to delete the information as quickly as possible. We encourage parents and guardians to monitor children's online activities and to inform children to obtain parental consent before providing personal information.
13. Language
In the event of any inconsistency between the English and Chinese versions of this Privacy Policy, the English version shall prevail. We will endeavor to provide an accurate translation, but in the event of ambiguity, the English version shall prevail. We want to ensure that all users have a clear understanding of our Privacy Policy, so we recommend that you refer to the English version when reading this Policy.
14. Contact US
If you have any questions about this Privacy Policy, please contact us via the following methods
Email: [email protected]
Address: MOULK CENTER,GABODE3-DJBOUTI
15. Disclaimer
The contents of this Privacy Policy are for information purposes only and do not constitute legal, financial or other professional advice. Whilst we endeavor to ensure the accuracy and completeness of the information, we cannot be held responsible for any errors, omissions or the currency of the information. To the fullest extent permitted by law, we will not be liable for any loss or damage arising directly or indirectly from the use of, or inability to use, the information contained in this Privacy Policy.
The use of the RWA Exchange Platform and the services it provides is at the user's own risk. We are not responsible for any data leakage or loss due to internet transmission problems, unauthorized access by third parties or other events beyond our reasonable control.
This disclaimer does not affect any of your statutory rights under applicable law. In the event of a conflict between this disclaimer and the applicable law, the applicable law shall prevail.
SUMMARY
This Privacy Policy details how we collect, use, share and protect your data and describes your rights in relation to that data. We are committed to protecting your privacy and take strict measures to ensure the security of your data. If you have any questions or need further information about our privacy policy, please feel free to contact us. We will endeavor to provide you with a transparent and reliable data protection service to ensure that your privacy is fully respected and protected.
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