I. The Parties
1. GoBuyCoins Ltd. (hereinafter referred to as "the Company"), a company incorporated under the laws of the Malaysia, operates the website https://www.gobuycoins.com (hereinafter referred to as “this Website” or “the Website”), which is a Platform that is exclusively used by users to trade digital assets and provides them with related Services (hereinafter referred to as "the Services"). For the convenience of wording in this Agreement, the Company and the Website are collectively referred to as “we” or other appropriate forms of the first-person pronouns.
1.2 All natural persons or other subjects who log onto this Platform shall be users of this Platform. For the convenience of wording in this Agreement, the users are referred to as "you" or any other applicable forms of the second-person pronouns.
1.3 For the convenience of wording in this Agreement, you and us are collectively referred to as “both parties”, and individually as “a party”.
II. Purposes of the Privacy Policy
This Privacy Policy stipulates the types of information of yours that we may collect through your log into this Platform, your registration with this Platform, and/or your use the Services we offer, as well as how we shall use, protect, and store such information as well as how we shall provide such information externally.
III. Your Consent
To ensure that you will have full confidence in our handling of personal data, you are hereby kindly advised to carefully read and fully understand the terms and conditions of this Privacy Policy. In particular, upon your log into our Platform, regardless of whether you register with this Platform, you shall be deemed to have accepted, agreed, undertaken and confirmed that:
3.1 You, on the basis of your own free will and the requisite consent of yours, agree to disclose your personal information to us;
3.2 You will comply with all the terms and restrictions under this Privacy Policy;
3.3 You agree that we may collect your information through your log into this Platform, your registration with this Platform, and/or your use of the Services offered by us; you agree to any changes and modifications that we may make to our Privacy Policy in the future;
3.4 You agree that our branches, affiliates and employees may contact you in connection with the products and Services that you may be interested in (unless you have indicated in express terms that you do not want to receive information on such products and Services).
IV. Information Collected
4.1 When you use this Platform, you agree to permit us to use cookies to track each of your actions and collect and keep all the information that you leave on this Platform, including but not limited to your IP address, geographic location, and other information.
4.2 If you are willing to use the Services offered by this Website in connection with different modes of trading between digital assets, you will be required to fill in and provide the following two categories of information:
4.2.1 Identity Information. Such information can help us verify whether you are eligible to be registered as a member of this Website. Such information includes but is not limited to your name, residence address, mailing address, other certificates and corresponding numbers thereof that are issued by your country or government to certify your identity information, as well as all other information that can help us to verify your identity (hereinafter referred to as "identity information"). Such identity information may vary depending whether you are an individual user or institutional user. Furthermore, according to the laws and regulations of different jurisdictions, the information collected by the Platform from users from different countries or regions may be different. The following information and data are intended to serve as an indicative example:
An individual user: nationality, legal full name (including former names, if any, as well as name in the local language of such individual user), ID number, email address, telephone number, social security number ("SSN"), passport number or any government-issued identity card number, date of birth, proof of identity (e.g. passport, driver's license or other identity certificates issued by the government), personal photo of the user taken within six(6) months prior to the user’s registration with the Platform as well as other information or documents required by the Platform.
An institutional user: its legal corporation name (including the legal corporation name in the local language), registration information, business telephone number, personal information on the authorized representative and authorized users, primary business premises, and personal information of all beneficial owners, identity documents (passports or government-issued identity cards) of shareholders/beneficial owners each holding 25% or more of the shares of the institutional user, the corporate structure of the institutional structure, documents relating to the formation of the institutional user, resolutions of the board of directors, declaration of sources of funding, risk and compliance control instructions and other information or documents as may be required by the Platform.
4.2.2 Service information. Such information helps us to contact you and successfully provide you with different forms of digital asset trading Services. Such information includes but is not limited to, your personal identity information, contact information, transaction information, as well as your debit card information and/or other account information (hereinafter collectively referred to as "Service Information"). Furthermore, let it be understood that the Services we provide to you are subject to constant update and development. If you choose to use any other service that is not covered in the above description, and therefore it is necessary for us to collect additional information of yours based on such service, we will explain to you the scope and purpose of such information collection through page prompts, interactive processes, agreement, and pop-up prompts, among others, to obtain your consent.
4.3 Security management. When you use the Services provided by this Website or visit this Website, this Website, for the purpose of ensuring the security of your transactions and the safe and stable operation of the Services, may need to automatically receive and record information on your web browser, your device information, such as device identification information, e.g., the type, version and model of your device, as well as the IP address and records on the web page you request to visit, as well as the location, network environment, device fingerprint information, service log information, software information, location information, etc.
4.4 When you use this Website or the Services this Website offers, we may collect additional necessary information through our special email box or in any other manner that we consider as in compliance with relevant requirements, for the purpose of improving the functions of this Website, optimizing your experience of using this Website and its Services as well as the security thereof, or as is required by any court order, any applicable law, administrative regulation or any order of any other competent government agency.
4.5 If you visit any of the links to third-party websites as are listed on this Website or any link to our third-party partners, you shall agree to and comply with the separate and independent Privacy Policy of such third party websites. We will not bear any liability for the content and activities of such Platforms or partners.
V. Cookies
• 5.1 When you visit our Website, we will use Google Stats via cookies to record our performance and verify the effect of online advertising. Cookies are a small amount of data that are sent to your browser and stored on your computer hard drive. Only when you use your computer to access our Website can the cookies be sent to your computer hard drive.
5.2 Cookies are usually used to record the habits and preferences of visitors in browsing the items on our Website. The information collected by cookies is non-registered and collective statistical data and does not involve any personal data.
5.3 Cookies, which enable the Website or service provider system to recognize your browser and capture and recall information, cannot be used to obtain data on your hard drive, your email address, or your personal data. Most browsers are preset to accept cookies. You can choose to set your browser to reject cookies, or to notify you as soon as possible if cookies are loaded into your browser. However, if you set your browser to disable cookies, it is possible that you may not be able to launch or use some functions of our Website.
VI. Use of Information
6.1 We will use your information that we collect, for the following purposes or in the following ways:
6.1.1 Processing your registration and providing you with the Services offered by this Website;
6.1.2 Notifying you of any change to our Services;
6.1.3 Reporting to relevant regulatory authorities, as is required by relevant regulatory authority in the sovereign country or region concerned;
6.1.4 When you use the Services provided by this Website, this Website will use your information for legitimate purposes, such as identity authentication, customer service, security, fraud monitoring, marketing and promotion, archiving and backup, or jointly promoting this Website in conjunction with third parties, so as to ensure the safety of the products and services provided by this Website to you.
6.1.5 Collecting and processing information, so as to help this Website to design new products and services, as well as to improve the existing Services offered by this Website;
6.1.6 In order to enable you to know the details of the Services provided by this Website, you agree to allow this Website to send you with information on relevant marketing events (including corporate news, promotion information and information in connection with products and services provided by GoBuyCoins), commercial electronic information and advertisements from time to time in replacement of general and comprehensive advertisements.
6.1.7 Inviting you to participate in surveys relating to the Services offered by this Website;
6.1.8 Data analysis jointly carried out with governmental agencies, public institutions and associations, among others;
6.1.9 Book-keeping and collecting any fee;
6.1.10 Personalizing your experience (your information will help us make better response to your personalized need);
6.1.11 We have adopted international standards to prevent money laundering, terrorist financing, and evasion of trade and economic sanctions. When the final virtual asset clauses and rules come into effect, we will implement them, which requires us to conduct due diligence on our customers. This may include cross-referencing your personal information with your data provided by third-party data and service providers.
6.1.12 Other legal purposes as well as other purposes authorized by you.
6.2 We do not sell, trade, or otherwise transfer information to any other party, or permit any other party to collect or use information, with the exception, however, of the following other parties and information: our related parties, our trusted third parties who help us operate our Website, manage our business, or provide Services to you, provided that such third parties agree to keep such information confidential; when we believe that information disclosure is appropriate, or it is required by any of the applicable laws, regulations, rules or by any order of courts or other competent authorities, and is necessary for executing the strategy of our Website and ensuring the proper functioning of this Website, or as may be necessary for the protection of the rights, property or safety of us or other persons.
6.3 After you stop using the Services provided by this Platform, we will stop collecting and using your information, unless otherwise required by any of the applicable laws and regulations or any of the competent regulatory authorities. If we cease our operation, we timely will stop collecting your personal information, and notify you of our cessation of operation by delivering a notice to each of you or via a public announcement, and we shall delete or anonymize your personal information held by us.
VII Protection of Personal Data
7.1 We adopt appropriate physical, electronic, managerial 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 Platform shall be free from being subject to nuisance by any third party unrelated to us. The security measures that we may take include but are not limited to:
7.1.1 Physical measures: records of your personal data will be stored in a properly locked place.
7.1.2 Electronic measures: the computer data that contain your personal information will be stored in computer systems and storage medias that are subject to strict login restrictions.
7.1.3 Managerial Measures: We have set up a department specially to protect the user's information, and have established relevant internal control regimes. Strict authorization principles are adopted for staff who may come into contact with your information. Only staff authorized by us can access your personal data. Such staff are required to abide by our internal code of confidentiality of personal data. In addition, we strengthen on an on-going basis education and training of staff in connection with relevant laws and regulations, privacy and safety guidelines and safety awareness, and regularly organize relevant internal personnel to carry out emergency response training and emergency drills, so as to enable them to master their duties and emergency response strategies and procedures.
7.1.4 Technical Measures: Such encryption techniques as Secure Socket Layer Encryption may be used to convey your personal data.
7.1.5 Security Measures: In order to ensure your information security, we are committed to using various current common security technologies and supporting management systems to minimize the risks of your information being disclosed, damaged, misused, unauthorized access, unauthorized disclosure and alteration. For example, the network security layer software (SSL) is used for encrypted transmission, information encrypted storage and strict restriction of data center access. When transmitting and storing personal sensitive information (including personal biometric information), we will adopt security measures such as encryption, authority control, de-identification, de-sensitization, etc.
7.16 Other measures: regularly review our personal data collection, storage and processing processes; And according to the necessary principles to limit our employees and suppliers access to your data, and our employees and suppliers must abide by strict contractual confidentiality obligations.
7.2 If you are aware of any security flaws in our Platform, please don’t hesitate to contact us immediately so that we can take appropriate action as soon as possible.
7.3 Despite the above-mentioned technical and security measures, we cannot guarantee that the information transmitted via the Internet is absolutely safe, so we cannot absolutely guarantee that the personal data that you provide to us through our Platform will be safe at any time. We will not be held liable for any loss or damage 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 loss or damage.
VIII. Modification to the Privacy Policy
We reserve the right to modify the Privacy Policy from time to time and at any time. We will inform you of the modifications made to the Privacy Policy by updating and publishing the effective date of the release of new versions hereof and highlighting the modifications made thereto. Sometimes, we may issue a notice to inform you of the modification made to the Privacy Policy, which, however, is not an obligation on the part of us. You shall regularly review the Privacy Policy and pay attention to the modifications thereto, and if you do not agree to such modifications, you shall immediately stop accessing this Platform. When an updated version of this Privacy Policy is released, your continued access to this Platform shall indicate and show that you agree to the update and agree to comply with the updated Privacy Policy.
IX. Access, Correction and Deletion of Your Personal Data
You have the right to obtain a copy of your personal data upon your request and make sure that the information we hold about you is accurate and up to date. If any of your personal data is inaccurate, you can request to update such data. You can also request to delete your personal data, provided, however, we may refuse to comply with your request for deletion under certain circumstances, e.g., to comply with legal requirements or for any other legal purposes. If you want to access, update or delete your data, please contact us at [email protected].
In order to respond to requests for data access, correction or deletion, we will verify the identity of the applicant for such access, correction or deletion, so as to ensure that the applicant is legally entitled to make such requests. Although our goal is to reply to these requests free of charge, we reserve the right to charge you a reasonable fee if your requests are repeated or costly.
If you confirm to terminate your use of the Services provided by this Platform and need to cancel your account, you can cancel your account through the relevant function interface or directly communicate with our customer service staff. When you meet the agreed account cancellation conditions and cancel your account with this Website, all information in your account will be cleared, and we will not collect, use or provide personal information related to the account to any external party, provided, however, the information you provide or generate during the use of Services provided by this Website shall nonetheless be saved for the period of time specified under the regulatory requirements, and we shall cooperate with the inquiry of such information by the competent authority during the said period of time.
X. Communication with Us
10.1 If you have any request and suggestion, you can contact us at [email protected], which is the only valid and official email address through which we communicate with you. We will not bear any liability for your omission or action that is not based on such valid contact information.
10.2 We only publish announcements and information on the basis of the Valid Contact Information on this Platform or post announcements on this Platform; therefore, we shall not be held liable for any loss arising from your trust in the information that is not obtained through the above-mentioned means.
10.3 If you have any question regarding our Privacy Policy, you are welcome to contact us at any time.