Updated on: April 7, 2020
Huobi Wallet APP attaches great importance to user information security and privacy protection, and exerts its best efforts to prevent your information from being leaked, damaged or lost by adopting appropriate and effective information security technology and management process; to provide you with convenient information management options to enhance your convenience in information management; to protect your communication secrets and ensure the security of your information and communications. Huobi Wallet APP strictly conforms to all applicable laws and regulations, collects information on an “as necessary” basis, and improves the transparency of information processing. In all aspects of product or service development, Huobi Wallet APP integrates legal, product, design and other factors into the concept of privacy protection, so as to provide you with more secure and reliable services.
• Information we collect;
• The purposes for which we collect information;
• How we share, transfer and publicly disclose your personal information;
• How we keep your personal information;
• How you manage your personal information;
• Protection of personal information of minors
• Notification and amendment
• How to contact us
I. Definition and Scope of Personal Information
Unless it is agreed otherwise, the terms used in this Policy shall be defined as follows:
1.2 Sensitive personal information: it refers to personal information whose leakage, illegal provision or misuse may endanger personal and property safety, and may easily result in damage to personal reputation or physical and mental health damage or discriminatory treatment. For example, sensitive personal information includes identity document number, personal biometric information, bank account number, communication content, health & physiological information, among others. Therefore, you are advised to prudently judge and determine the authenticity, legality and validity of the relevant digital assets and/or information, and bear the responsibility and losses arising therefrom.
1.3 Anonymized information: it refers to personal information that has undergone proper technical processing, after which it is impossible to identify the subject of such personal information, the subject cannot be recovered through processing. The anonymized information is not personal information.
1.4 Any other information that cannot be used to identify a particular natural person or reflect the activities of a particular natural person is not personal information.
Terms other than those defined above shall have the same meaning as that ascribed to them under the Huobi Wallet APP User Service Agreement. If you have any question, please contact us.
II. Information We Collect
2.1 Huobi Wallet is a digital asset wallet developed on the basis of blockchain, including other auxiliary tools developed to facilitate users in using the blockchain systems. The personal information collected by the Huobi Wallet APP includes:
2.1.1 The server data in your web browser that the APP automatically receives and records when you use or access the APP, including the model of the devices you use, your geographic location, IP address and other data, as well as the records on the web pages you request to access.
2.1.2 The data collected by the software about your transactions on the platform, including the wallet address and transaction records you created and imported.
2.1.3 When the APP collects any other user's personal information, it will expressly notify you and obtain your consent.
III. How We Use the Information Collected Hereunder
We strictly abide by all applicable laws and regulations as well as our agreements with the users, and will use the information collected hereunder for the following purposes. If we use your information beyond the following purposes, we will provide an explanation to you anew and obtain your consent.
3.1 To provide services to you.
3.2 To meet your personalized needs, e.g., language setting, location setting, personalized help service.
3.3 To develop products and optimize services. For example, when our system fails, we will record and analyze the information generated by the system failure and thereby optimize our services.
3.4 Security. For example, we will use your information for the purposes of identity authentication, security & prevention, fraud monitoring, archiving & backup, and customer security services, among others. the security software you download or install will detect malicious programs or viruses, or identify fraud information for you.
3.5 To evaluate and improve the effectiveness of our advertising and other marketing and promotional activities.
3.6 To manage software, e.g., software certification, software upgrading and so on.
3.7 To invite you to participate in our service surveys.
For the purposes of providing you with better experiences, improving our services or any other purposes that you approve, we may, on the precondition of complying with relevant laws and regulations, use the information collected through certain services for our other services. For example, your information relating to your use of one of our services may be used in another service to present you with personalized content or advertising, or for the purposes of such services as user research, analysis and statistics. In order to ensure the security of service and help us better understand the operation of our APP, we may record relevant information, for example, how often you use the APP, information on failures of the APP, your overall usage of the APP, performance data, and the source of the APP. We will not combine the information we store in the analysis software with the personally identifiable information you provide in the APP.
IV. How We Share, Transfer and Publicly Disclose Your Information
4.1 We will keep your personal information confidential in accordance with the relevant laws and regulations. We will not share your personal information with any other person, except for under any of the following circumstances:
A. Where we cannot provide you with the service you need unless we share your personal information.
B. In order to improve the quality of our products and services or provide you with new products and services, we may share your relevant information within our affiliated companies.
C. When you access a third-party service through the Huobi Wallet software, Huobi Wallet will share your personal information with the third party providing the service to the extent of the content to be shared as is set out under the clause, "Collection of Personal Information".
D. In order to safeguard the legitimate rights and interests of users, we may, when assisting in handling controversies or disputes related to you, provide a third party who is an interested party of yours with the information necessary to resolve such controversies or disputes.
E. As is required by law, necessary personal information obtained by criminal investigation authorities in accordance with legal procedures in order to investigate crimes, or necessary personal information obtained by administrative organs and judicial organs in accordance with legal procedures and subject to authorization by you.
F. To the extent required or permitted by law, necessary information that is provided in order to protect public interest, property or security.
G. Where your express consent or authorization is obtained otherwise.
4.3 We will abide by the relevant laws and regulations and keep your personal information confidential. We will not publicly disclose your personal information unless with your prior express consent or authorization, or as is required by law.
4.4 Furthermore, in accordance with the relevant laws and regulations and state standards, we may share, transfer and publicly disclose personal information under the following circumstances without the prior authorization by the subject of such personal information:
A. Where state security and/or national defense security are involved;
B. Where public security, public health and/or major public interests are involved
C. Where criminal investigation, prosecution, trial and judgement enforcement are involved;
D. Where it is for the purpose of protecting the life, property and/or any other important legal rights and interests of the subject of personal information hereunder or any other person, yet it is difficult to obtain the consent of such subject or person, as the case may be;
E.Where such personal information is Your personal information that You disclose to the public by Yourself;
F. Where such personal information hereunder is collected from legally disclosed information, such as legal news reports and government information disclosures, inter alia.
V. How We Protect Your Personal Information
We provide appropriate security for your information, so as to prevent it against any loss, improper use, unauthorized access or disclosure.
5.1 We protect users' secrecy of communication in strict accordance with relevant laws and regulations.
5.2 We will adopt various security measures to ensure the security of information to a reasonable extent. For example, we will use encryption techniques (for example, TLS, SSL), and anonymization, among others, to protect your personal information.
5.3 We will establish specialized management systems, processes and organizations to ensure information security. For example, we strictly limit the range of people who can access information hereunder and require them to comply with confidentiality obligations, and subject such persons to proper supervision.
5.4 In the event of a security incident, such as the disclosure of personal information, we will launch an emergency response plan to prevent the worsening of the security incident and inform you in the form of push notices, announcements, etc.
5.6 Given the fact that the Internet is not an absolutely secure environment, and that it is impossible to determine whether the ways in which you communicate with other users, such as by email, instant messaging, social software, etc., are fully encrypted, we hereby recommend that you use sophisticated passwords and pay proper attention to protecting your personal information when you use such communication tools.
5.7 Given the fact the Internet environment is not 100% secure, we will exert our best efforts to ensure or guarantee the security of any information you send to us. Where any of your legitimate rights and interests sustains any damage due to any unauthorized access, public disclosure, tampering, or destruction of such information that arises because any of our physical, technical, or administrative protection facilities is compromised, we will bear the corresponding legal liability.
VI. How We Store Your Personal Information
6.1 We implement proper physical, electronic, management and technical measures to protect and safeguard Your personal data. We will exert our best efforts to ensure that any personal data collected through our Platform are free from any nuisance caused by any third party unrelated to us. The safety measures We adopt include but are not limited to:
6.1.1 Physical measures: Records containing Your personal data will be stored in a properly locked place.
6.1.2 Electronic measures: Computer data containing Your personal information will be stored in computer systems and storage media that are subject to strict log-in restriction.
6.1.3 Management measures: We have set up an internal safety defense department to protect the users' information, established relevant internal control systems, and adopted the principle of strict authorization for our employees who may come into contact with Your information; therefore, only properly authorized employees are permitted to come into contact with Your personal information and such employees must comply with our internal confidentiality rules for personal data. Furthermore, we provide sustained training to our staff on relevant laws and regulations, privacy and safety guidelines, enhance publicity and education on safety awareness, and organize our relevant internal personnel to carry out emergency response training and emergency drills on a regular basis, so as to enable them to fully understand their job duties and emergency response strategies and procedures.
6.1.4 Technical Measures: encryption technology such as Secure Socket Layer Encryption may be adopted to transfer Your personal data.
6.1.5 Security Measures: In order to ensure Your information security, we are committed to using various currently available general security technologies and supporting management systems to minimize the risks that Your information may be disclosed, damaged, misused, accessed without authorization, disclosed without authorization or altered. For example, the Secure Socket Layer (SSL) software is used for encrypted transmission, encrypted information storage and strict restriction of data center access. When transmitting and storing sensitive personal information (including personal biometric information), we will adopt security measures such as encryption, authority control, removal of identification marks, and de-sensitization, inter alia.
6.1.6 Other measures: We regularly review our personal data collection, storage and processing procedures; furthermore, we limit the access of our employees and suppliers to Your data in accordance with the principle of “as necessary”, and our employees and suppliers must abide by strict contractual confidentiality obligations.
6.2 If You become aware of any security vulnerability of our Platform, please contact us promptly so that We can adopt appropriate actions as soon as possible.
6.3 Despite the above-mentioned technical and security measures, We cannot guarantee the absolute safety of data transmission on the Internet, so We cannot absolutely guarantee that the personal data You provide to us through our Platform are safe at all times. We will not regularly update and make public security risks and personal information security impact assessment reports, inter alia, which You can obtain through announcements made by this Platform.
VII. How You Manage Your Own Information
7.1 Creation of Wallet
Before using the APP services, you must first create a wallet on the platform. An individual user who creates a wallet shall be a natural person who has reached the age of 18 or has full capacities for civil rights and civil conducts in accordance with the laws of the country in which such user is located, and shall be able to bear civil liability independently. A legal person, organization or any other institution user that intends to create a wallet shall designate a natural person who has reached the age of 18 or has full capacities for civil rights and civil conducts in accordance with the laws of the country where such person is located, and is capable of independently bearing civil liability, as the representative of such legal person, to complete the creation of the wallet.
7.2 Setting the Password, Private Key, Mnemonic or Keystore of the Wallet
On the basis of the decentralized nature of blockchain, and in order to protect the security of users' digital tokens, the APP, different from banking financial institutions, provides decentralized services. Therefore, you need to remember your wallet password (that is, the password set by the user when creating/importing the wallet), private key, mnemonic or Keystore; we cannot provide you with services relating to recovering your password, private key, mnemonic or Keystore, freezing your wallet, reporting the loss of your wallet, restoring your wallet, or transaction rollback.
7.3 Inquiry, correction and deletion of your information
You have the right to inquire, correct or supplement your information. If any of your personal data is inaccurate, you can apply to update your information accordingly.
You can apply to us to delete your personal information under any of the following circumstances:
A. Where our processing of personal information violates any of the laws and regulations;
B. Where we collect and use your personal information without your explicit consent;
C. Where our processing of personal information seriously violates any of our agreements with you;
D. Where you cease to use our products or services, or where you cancel your account with us on the basis of your free will;
E. Where we permanently decide not to provide you with our products or services.
If we decide to respond to your application for deletion, we will, to the greatest extent possible, also notify the subjects who obtain your personal information from us, and require them to delete your personal information in a timely manner (unless any of the applicable laws and regulations requires otherwise, or such subjects obtain your authorization independently).
When you delete or we assist you in deleting the relevant information, it is possible that we are unable to delete the relevant information from the backup system immediately on account of any of the applicable laws and security technologies, and in this case, we will securely store your personal information and isolate it from any further processing until the backup information can be cleared or anonymized.
7.4 Properly Keep Your Information
You must properly take care of the mobile device containing your Huobi Wallet, back up your Huobi Wallet information, as well as your Huobi Wallet password, mnemonic, private key and Keystore. If you lose your mobile device, or delete your Huobi Wallet information without any backup thereof, delete your Huobi Wallet without any backup thereof, or your wallet password, private key, mnemonics or Keystore is stolen or forgotten, then on account of the decentralized features of the services hereunder, you will not be able to restore or retrieve Your Huobi Wallet passwords, private keys, mnemonics or Keystore.
7.5 Constrain the Automatic Decision-making by Information Systems
In some business functions of the APP, we may make decisions exclusively based on non-manual automatic decision-making mechanisms, including information systems, algorithms, and so on. If such decisions significantly affect your legitimate rights and interests, you have the right to demand us to provide an explanation, in this case, and we will provide you with a method of complaint without infringing upon the commercial secrets of the Huobi Wallet or any other user’s rights and interests or social and public interest.
7.6 Response to your above requests
To ensure security, it may be necessary for you to provide a written request or otherwise prove your identity. We may require you to verify your identity before processing your request.
We will reply within fifteen(15) days. If you are not satisfied, you can also lodge a complaint through the customer service email address.
we may, in accordance with the requirements of laws and regulations, be unable to respond to your requests under any of the following circumstances:
A. Where state security and/or national defense security are involved;
B. Where public security, public health and/or major public interests are involved;
C. Where criminal investigation, prosecution, trial and judgement enforcement are directly involved;
D. Where there is sufficient evidence proving subjective malice or abuse of power on your part;
E. Where responding to your request will result in any serious damage to the legitimate rights and interests of yours or any other individual or organization;
F. Where any trade secret of we is involved.
XIII. Information You Share
8.1 You can share your relevant information with others and social networks based on our services, which may contain sensitive information, such as your personal identity information, personal property information, and so on; you may, at your sole discretion, choose the persons you share information with as third parties who can access your information.
8.2 When you share your personal information with any other person, social network or third-party service provider, or when you use any third-party service, or any third-party service link, it is possible that you may disclose or make your personal information available to third parties.
8.3 We recommend that you check the privacy statements of the above-mentioned social networks or third-party service providers to verify how they handle your information. You shall bear any and all the consequences of providing or sharing your personal information with others when you use third-party services, and the corresponding responsible parties shall be held liable to the extent prescribed by law.
8.4 When you publicly share any information on the Huobi Wallet APP, anyone may view or access the information when using the Huobi Wallet platform. The information you voluntarily share when using our services may involve your personal information or that of others. Therefore, you should choose carefully and will assume the corresponding responsibilities on your own.
IX. Protection of Minors
9.1 We attach great importance to protecting the personal information of minors. According to the relevant laws and regulations, if you are a minor under the age of 18, you should obtain the consent of your parents or legal guardians before using the Huobi Wallet services. If you are a minor under the age of 14, your guardian should read this Policy carefully and agree that you may apply the Huobi Wallet APP in accordance with this Policy.
9.2 We will not take the initiative to collect personal information directly from minors. Where we collect any personal information of any minor with the consent of the guardian thereof, we will only use, share, transfer or disclose such information to the extent permitted by law, with the consent of the guardian, or as may be necessary for protecting the minor.
9.3 If it is proved that the minor has registered to use our products and/or services without the consent of the guardian thereof, we will consult with the guardian and seek to delete the relevant personal information as soon as possible.
X. Applicable Scope
This Policy applies to all our services. However, some services are subject to specific privacy guidelines/statements that more specifically describe how we handle your information in connection with such services. If there is any inconsistency between this Policy and such privacy guidelines/statements for specific services, the latter shall prevail.
Please note that this Policy does not apply to services provided by other companies or individuals, e.g., services provided by any other company or individual that you access by logging in with your Huobi Wallet account.
Your use of such third-party services is subject to the privacy policies thereof (instead of this Policy), and therefore you need to read such policies carefully.
XI. Notice and Amendment
11.2 For any major amendment hereto, we will also provide a more significant notice thereon (we will notify the details of such amendment hereto by a number of means, including but not limited to email, short text message or special pop-outs on web pages).
A. Significant changes in our service mode and business model, e.g., changes in the purpose of processing personal information, the types of personal information processed, the ways in which personal information is used, inter alia.
B. We have made great changes in ownership structure, organizational structure and so on. Such as the change of owners caused by business adjustment, bankruptcy mergers and acquisitions, etc.;
C. The main objects of personal information sharing, transfer or public disclosure have changed;
D.Any significant change in Your right to participate in personal information processing and the way You exercise such right;
E. Changes in the contact information of our department in charge of personal information security, or changes in the ways in which complaints hereunder are lodged; and
F.The security impact assessment report for personal information shows that there is a high degree of risks.
XII How to Contact Us
Official customer service email: firstname.lastname@example.org
12.2 In general, we will reply within fifteen(15) days. If you are not satisfied with our reply, especially if our personal information processing damages any of your legitimate rights and interests, you can also lodge a complaint or report to the competent regulatory authorities, such as those in charge of computer information network & internet security, telecommunications, public security and industry & commerce.