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Cobo Accounts Privacy Policy


By visiting, accessing, or using our services, content, technologies, or features through related website(s) and all associated mobile applications ("Cobo Platform"), you consent to the policies and practices of our privacy policy (the "Privacy Policy"). This Privacy Policy outlines how Cobo (defined below) will collect, use, maintain, share, and store your Personal Information (defined below) as we provide you with access and utility to our services, content, technologies, or features through Cobo Platform ("Services").We are committed to protecting your Personal Information and this relates to where data is gathered and handled in accordance with the relevant applicable data protection law. 

"Personal Information" refers to information relating to an identified or identifiable individual and does not include de-identified or aggregated information. Additionally, to the extent permitted by law, Personal Information does not include information that is legally available to the public or legally available in government or public records.

Data Controller

Cobo is made up of different legal entities, details of which can be found below ("Cobo", "we", "us" or "ours"). Cobo acts as a controller of your Personal Information where we determine how and why Personal Information can be used, and the Cobo entity is the primary controller of your Personal Information. The legal entities include [Cobo Technologies Limited, Cobo HK Global Limited, Cobo Global Limited].  

I. Use of Personal Information Collected

1.1 In order to provide you with better Services, we will collect your Personal Information from your computer and/or mobile device, including but not limited to the following:

(1) Individual(s): Email address; Mobile phone number; Full legal name (including former name, and names in local language); Nationality; Passport number, or any government issued ID number; Date of birth;  Proof of identity (e.g. passport, driver's license, or government-issued ID); Residential address; Proof of residency; Additional Personal Information or documentation at the discretion of our Compliance Team. 

(2) Corporate(s): Corporate legal name (including the legal name in local language); Incorporation/registration Information; Full legal name of all beneficial owners, directors, and legal representatives; Address (principal place of business and/or other physical locations); Proof of legal existence; Description of the business; Percentage of ownership for Individual/corporate owners; Contact information of owners, principals, and executive management (as applicable); Proof of identity (e.g., passport, driver's license, or government-issued ID) for significant individual beneficial owner of the institutional customer entity; Personal Information for each entity's significant beneficial owner of the institutional customer entity (see the "Individual Customer" section above for details on what Personal Information we collect for individuals); Source of wealth. 

1.2 By sending us any Personal Information about a third party (such as details about your spouse, kids, parents, and/or employees), you certify to us that you have obtained the consent of the third party to provide us with their Personal Information for the respective purposes.

1.3 You must ensure that all Personal Information you provide to us is accurate, true, complete, and current. Your failure to comply with this request may prevent us from offering you the Services.

II. Use of Personal Information Collected

2.1 We will use your Personal Information in the following ways:

(1) to provide you with the Services and user support;

(2) to verify your identity;

(3) to fulfill our obligations to comply with the relevant applicable laws and regulations;

(4) verify and establish your account;

(5) process and fulfill your purchases of our Services;

(6) protect against or deter fraudulent, illegal or harmful actions;

(7) identify trends and other statistical information that may be useful to our business;

(8) respond to user inquiries and fulfill user requests;

(9) the Personal Information to perform any binding agreement with you, including (a) account information that you provide us; (b) information that you provide us when purchasing our Services; and (c)information that you provide us when making a request or inquiry with our representatives;

(10) the Personal Information we collect and process for the legitimate purposes, including (a) account information that you provide us; (b) usage data we collect in connection with your use of our Services; (c) handling with respect to protection from fraud or security threats; (d) operation, maintenance and improvement of our business, products and Services; (e) user support; and (f) compliance with legal, compliance and contractual obligations and to protect vital interests of you and us.

2.2 For the Personal Information we collect and use beyond the purpose specified in this Privacy Policy, we will seek your explicit consent separately. You may withdraw consent and request us to stop using and/or disclosing your Personal Information. But please be aware that it could take reasonable time for your withdrawal to appear in our systems once we get confirmation that you want to stop receiving marketing or promotional materials or communications. As a result, during this time you might still get marketing or promotional materials or communications.

III. Sharing and Transfer of Personal Information

3.1. Sharing

We will not share your Personal Information with any third parties except for the following:

(1) Sharing with explicit consent. We may share your information with other parties only if we obtain your explicit consent unless provided otherwise under clause 3.1.2.

(2) Sharing under legal circumstances. We may share your information in order to report illegal activities or investigate possible violation of any agreements, to settle a litigation or arbitration, or as requested by administrative or judicial authorities in accordance with the relevant applicable laws and regulations.

3.2. Transfer

We will not transfer your information to any third parties except for the following:

(1) Transferring to the server. Personal Information we collect and use will be stored in your place of residence. However, we may transfer and store your Personal Information on a server if it meets the requirements of relevant applicable laws and regulations.

(2) Transferring with explicit consent. We may transfer your information to other parties only if we obtain your explicit consent unless provided otherwise hereunder.

3.3. Exceptions for sharing and transferring user information with prior written consent

Notwithstanding anything above in conflict, your prior written consent is not necessary to share or transfer your user information in the following cases:

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

(2) Related to public safety, public health, and significant public interest.

(3) Related to crime investigation, prosecution, trial and sentence enforcement, etc.

(4) In order to safeguard yours or another individual's significant legal rights and interests, such as life or property, including when it is hard to obtain your prior consent.

(5) Personal information that you disclose to the public by yourself.

IV. Protecting Your Personal Information

We shall use our best efforts to protect the security of the user data we collect from loss, unauthorized access, misuse, and modification.

(1) To secure information with a sufficient level of security, we shall utilize a variety of security measures. 

(2) In the unlikely event that there is a Personal Information leak, we will immediately let you know by email, push notification, and other channels of communication. In the interim, we will also take the initiative to report the incident's resolution in accordance with the regulatory authorities' ", “, ", ” regulations.

(3) We shall make every effort to ensure that only pertinent Personal Information is gathered. Unless a longer retention period is required or permitted by the relevant applicable laws and regulations, we will only keep your Personal Information for as long as it takes to accomplish the goals of this Privacy Policy.

V. Your Rights

You are entitled to certain rights in relation to your Personal Information.

(1) If you believe that the Personal Information we have collected is inaccurate, you may request us to correct such information collected.

(2) To restrict or object to the processing of your Personal Information for compelling and legitimate reasons related to your situation, unless such processing is expressly provided for by law.

(3) You may request us to delete Personal Information in the following circumstances: (a) If our handling of Personal Information violates laws and regulations; (b) If we collect and use your Personal Information without your consent when the explicit consent is required; (c) If our processing of Personal Information constitutes a breach of our agreement with you; (d) If you no longer use our products or Services, or if you wish to terminate your account; or (e) If we no longer provide products or Services to you. 

VI. Minors

6.1. The Services are only intended for adults and do not offer to any minors or collect information from minors.

6.2. Under this Privacy Policy, we consider everybody under the age of 18 to be a minor, regardless of how other laws and traditions define minors.

VII. How Long We Retain Your Personal Information

We will keep your Personal Information to the extent necessary or authorized by law and in accordance with the retention guidelines that we may amend from time to time. 

VIII. Cross-Border Transmission

We take the necessary steps to guarantee that the cross-border data transfer complies with relevant data protection laws and regulations. If we transmit data from the European Economic Area to countries with insufficient levels of data protection, we may do so using standard contractual agreements. Your consent shall be the basis for such transfers if an appropriate decision, ordinary contractual conditions, or any other right to transfer your data are missing.

IX. Opt Out

By getting in touch with us, you can choose at any time to stop receiving marketing and promotional messages from us. Please be aware that even if you opt not to receive the aforementioned emails, we will still respond to you if you contact us for any other issues relating to your use of Services

X. Update of Privacy Policy

We may add, remove, modify, or update this Privacy Policy from time to time. This Privacy Policy will be updated as needed and posted on our websites and/or mobile applications. Your continued use of the Services following the release of an upgraded version signifies your acceptance of the revised version. 

XI. Contact Us

Please get in touch with us at [[email protected]] if you have any questions about this Privacy Policy or our privacy practice. 

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