Last updated: June 2023

This Privacy Notice describes how we collect and use your personal information in relation to VVWallet website, platform, applications, products, services, events, and experiences that reference this Privacy Notice (collectively, “VVWallet Offerings”).

This Privacy Notice does not apply to the cryptocurrencies uploaded, stored, and/or used by our customers using VVWallet Offerings in connection with a VVWallet account and license. For more information on how we handle cryptocurrencies and how our customers can control them through VVWallet Offerings, see VVWallet Terms of Use. This Privacy Notice does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy notice.

Collected personal information

We collect your personal information when providing VVWallet Offerings to you.

We gather the following:

• Information you give us: We collect any information you provide in relation to VVWallet Offerings. See examples of information you give us in the last section of this document.

• Automatic information: We automatically collect certain types of information when you interact with VVWallet Offerings. See examples of information we collect automatically in the last section of this document.

• Information from other sources: We might collect information about you from other sources, including service providers, partners, and publicly available sources. See examples of information we collect from other sources in the last section of this document.

Use of personal information

We use your personal information to operate, provide and improve VVWallet Offerings. Our purposes for using personal information include:

• Provide VVWallet Offerings: We use your personal information to provide and deliver VVWallet Offerings and process transactions related to VVWallet Offerings, including registrations, subscriptions, purchases, and payments.

• Measure, support and improve VVWallet Offerings: We use your personal information to measure use of, analyze performance of, fix errors in, provide support for, improve, and develop VVWallet Offerings.

• Recommendations and personalization: We use your personal information to recommend VVWallet Offerings that might be of interest to you, and to identify your preferences so we can personalize your experience with VVWallet Offerings.

• Comply with legal obligations: In certain cases, we have a legal obligation to collect, use, or retain your personal information.

• Communicate with you: We use your personal information to communicate with you in relation to VVWallet Offerings via different channels (e.g. phone, email, chat) and to respond to your requests.

• Marketing: We use your personal information to market and promote VVWallet Offerings. We might display interest-based ads for VVWallet Offerings.

• Fraud and abuse prevention and credit risks: We use your personal information to prevent and detect fraud and abuse in order to protect the security of our customers, VVWallet, and others. We may also use scoring methods to assess and manage credit risks.

• Purposes for which we seek your consent: We may ask for your consent to use your personal information for a specific purpose with prior notice.

Cookies

We use cookies to enable our systems to recognize your browser or device and to provide VVWallet Offerings more accurately.

How we share personal information

Information about our customers is an important part of our business, but we do not sell our customers’ personal information to others. We share personal information only as described below and with the subsidiaries that VVWallet company controls and that either are subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.

• Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include sending communications, processing payments, assessing credit and compliance risks, analyzing data, providing marketing and sales assistance (including advertising and event management) and conducting customer relationship management. Third party service providers have access to personal information needed to perform their functions, but shall not use it for other purposes. Moreover, they must process that information in accordance with this Privacy Notice and as permitted by applicable data protection law.

• Business transfers: As we continue to develop our business, we might sell or buy businesses or services. In such transactions, personal information is generally one of the transferred business assets, but it remains subject to any pre-existing Privacy Notice (unless the individual consents otherwise). In the unlikely event that VVWallet or substantially all of its assets are acquired, your information shall be one of the transferred assets.

• Protection: We release account and other personal information when we believe it is appropriate to comply with the law, enforce or apply our terms and other agreements, or protect the rights, property, or security of VVWallet, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.

• At your option: Except as set forth above, you shall receive notice when your personal information might be shared with third parties, and you shall get to choose if you don’t want to share that information.

Location of personal information

VVWallet company is located in Hong Kong, and our affiliated companies are located throughout the world. Depending on the scope of your interactions with VVWallet Offerings, your personal information may be stored in or accessed from multiple countries and regions, including Hong Kong. Whenever we transfer personal information to other jurisdictions, we shall ensure that the information is transferred in accordance with this Privacy Notice and as permitted by applicable data protection laws.

How we secure information

At VVWallet, we design our systems with your security and privacy in mind:

• We use ISO/IEC 27001 international security standards to maintain a wide variety of compliance programs that validate our security controls. We shall continue developing more security standards and they shall be described in this document.

• We protect the security of your information during transmission to or from VVWallet website, platform, applications, products, or services by using encryption protocols and software.

• We follow the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data.

• We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal information.

Our security procedures mean that we may request proof of identity before we disclose personal information to you.

Internet advertising and third parties

VVWallet Offerings may include third party advertising and links to other websites and applications. Third party advertising partners may collect information about your interaction with their content, advertising or services.

Access and choice

You can view, update, and delete certain information about your account and your interactions with VVWallet Offerings (see the examples of information that you can access in the last section of this document). If you cannot access or update your information yourself, you can always contact us for assistance. You have choices about the collection and use of your personal information. Many VVWallet Offerings include settings that provide you with options as to how your information is being used. You can choose not to provide certain information, but then you might not be able to take advantage of certain VVWallet Offerings.

• Account information: If you want to add, update or delete information related to your account, go to the “Me” section on the VVWallet app. When you update or delete any information, we usually keep a record of your previous version.

• Communications: If you do not want to receive promotional messages from us, unsubscribe or adjust your communication preferences in VVWallet Platform or VVWallet Email Preference Center. If you do not want to receive in-app notifications from us, adjust your notification settings in the app or in your device.

• Advertising: If you don’t want to see interest-based ads, adjust your Advertising Preferences.

• Browser and device: The “Help” feature on most browsers and devices helps you to prevent your browser or device from accepting new cookies, have the browser notify you when you receive a new cookie, and help you disable cookies altogether.

Retention of personal information

We keep your personal information to enable your continued use of VVWallet Offerings for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, as may be required by law (including for tax and accounting purposes), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we shall delete your personal information in accordance with applicable law.

Contacts, notices and revisions

If you have any concern about privacy at VVWallet or want to contact one of our data controllers, contact us with a thorough description of the issue and we shall try to resolve it for you.

If you interact with VVWallet Offerings on behalf of or through your organization, then your personal information may also be subject to your organization’s privacy practices, and you should direct privacy inquiries to your organization.

Our business changes constantly, and our Privacy Notice may change as well. You should visit our website regularly to check if there are any recent changes. You can see the date on which the latest version of this Privacy Notice was posted. Unless stated otherwise, our current Privacy Notice applies to all personal information we have about you and your account. We shall never materially change our policies and practices to make them less protective of personal information collected in the past without informing affected customers and giving them a choice.

Examples of information collected

Information you give us

You provide information to us when you:

• Search for, subscribe to, or purchase VVWallet Offerings

• Create or administer your VVWallet account

• Configure your settings for and interact with VVWallet Offerings

• Register for or attend a VVWallet event

• Offer your content, products, or services on or through VVWallet Offerings

• Communicate with us by phone, email, or otherwise

• Complete a questionnaire, a support ticket, or other information request forms

• Post on VVWallet website or participate in community features

• Employ notification services

Depending on your use of VVWallet Offerings, you might supply us with information such as:

• Your email address, phone number, and other similar contact information

• Payment information, including credit card and bank account information

• Information about your location

• Information about your organization and your contacts (e.g. colleagues or people within your organization)

• Username, alias, roles, and other authentication and security credential information

• Content of feedback, testimonials, inquiries, support tickets, and any phone conversations, chat sessions and emails with or to us

• Your image (still, video and, in some cases, 3D), voice, and other identifiers that are personal to you when you attend a VVWallet event or use certain VVWallet Offerings

• Corporate and financial information

• VAT numbers and other tax identifiers

Automatic information

We collect information automatically when you:

• Visit, interact with, or use VVWallet Offerings

• Open emails or click on links in emails from us

• Interact or communicate with us (e.g. when you attend a VVWallet event or when you request customer support)

Examples of the information we automatically collect include:

• Network and connection information, such as Internet protocol (IP) address used to connect your computer or other devices to the Internet and information about your internet service provider

• Computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting

• The location of your device or computer

• Authentication and security credential information

• VVWallet Offerings metrics, such as offering usage, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs

• The full Uniform Resource Locators (URL) clickstream to, through, and from our website (including date and time) and VVWallet Offerings, content you viewed or searched for, page response times, download errors, and page interaction information (such as scrolling, clicks, and mouse-overs)

• Email addresses and phone numbers used to contact us

• Identifiers and information contained in cookies

Information from other sources

Examples of information we receive from other sources include:

• Marketing, sales generation and recruitment information, including your name, email address, phone number, and other similar contact information

• Subscription, purchase, support, or other information about your interactions with products and services offered by us and our affiliates in relation to VVWallet Offerings

• Search results and links, including paid listings (such as sponsored links)

• Credit history information from credit bureaus

Information you can access

Examples of information you can access through VVWallet Offerings include:

• Your name, email address, physical address, phone number and other similar contact information

• Username, alias, roles and other authentication and security credential information

• Your subscription, purchase, usage, billing, and payment history

• Payment settings (e.g. payment instrument information and billing preferences)

• Email communication and notification settings

• Your account, your status, subscriptions and other information