Dear Users,

DXP COMPUTING POWER FOUNDATION PTE.LTD. (“DXP” or “we”) respects and protects the privacy of Users (“you” or “Users”). DXP will collect and use your Personal Information, generated from your use of FxWallet in accordance with this Privacy Policy (“Policy”).

DXP recommends that you shall carefully read and understand the whole contents of this Policy before your use of the product (FxWallet). Additionally, significant information, including the Disclaimer, is in bold form in this Policy. Definitions of key words in this Policy are consistent with those in the FxWallet Terms of Service of DXP.

DXP reserves the right to update this Policy online from time to time, and the new policy will immediately replace the older one once posted. In particular, if you do not accept the revised policies, please immediately stop using FxWallet. Your continuous use of FxWallet will be regarded as your acceptance of the revised policies. Furthermore, the revised policies will take effect immediately upon being posted on FxWallet.

You acknowledge and accept that this Policy and other relevant rules apply to FxWallet and the DApps owned by DXP on FxWallet.

Information We Collect

We collect your information in order to provide the services you requested on FxWallet, and we highly value the protection of your privacy. When collecting your information, we strictly abide by the principle of “lawful, justifiable and necessary”. You acknowledge that, if you do not provide us with necessary information, your user experiences on FxWallet may be affected.

We may collect your Personal Information, including but not limited to your mobile device information, operation records, transaction records and wallet addresses.

Confirm that your Wallet Password, Private Key, Mnemonic Words, Keystore on FxWallet (the decentralized solution) are not stored or synchronized on DXP’s servers. DXP does not offer the service to restore your Wallet Password, Private Key, Mnemonic Words or Keystore.
Apart from the foregoing provisions, when you are using a specific function of FxWallet, we may provide you with special notification to ask for more personal information.
After linking to the third-party-developed DApps from FxWallet, your Personal Information will be collected and held by the third-party-developed DApps rather than by FxWallet. When you fill in your Personal Information on a third-party-developed DApp, you should review the Terms of Use and Privacy Policy of the third-party-developed DApp. We are not accountable for any losses caused by your operation on the third-party-developed DApp.
We may collect your location information. For instance, when you utilize services related to location, we may record the location of your device to provide you with relevant services. GPS location information is considered sensitive personal data. If you decline to provide this information, it will not affect your use of other functions of this product or service, it will only affect functionalities related to geographical location.
To the extent permitted by laws and regulations, DXP may collect and use following Personal Information without your prior consent or authorization:
1. information related to national security and national defense;
2. information related to public security, public health and significant public interests;
3. information related to criminal investigation, prosecution, trial and enforcement;
4. the Personal Information collected is made public by yourself;
5. the Personal Information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
6. the Personal Information is necessary to ensure the security and compliance of services, such as to detect or to resolve the malfunction of products and services;
7. other circumstances prescribed by laws and regulations. We collect information in the following ways:
  1. Information you give us. For example, you fill in your name, telephone number when submitting feedback, or you provide additional information to us when you use our specific services.
  2. We collect information during your use of FxWallet, including your mobile device information and your operation records on FxWallet, etc.

How We Use Your Information

We may associate you with your wallet by the unique serial number of your mobile device.
We may promptly send important notifications to you, such as software updates, updates of Terms of Service and this Policy.
We offer you the “Biometrics” option in the “Security” column of FxWallet to provide you with a convenient and safe way to manage your digital Tokens.
We deal with your feedback by using the Wallet Address and the mobile device information provided by you.
We may collect your Personal Information to conduct our internal audit, data analysis and research, etc. to enhance our services.
According to FxWallet Terms of Service and other rules of DXP, DXP will manage and handle the use behaviors of Users through Users’ information.
We may use your information in accordance with laws and regulations, and to cooperate with regulatory authorities.

How You Control Your Own Information

You are entitled to control your Personal Information provided to FxWallet:
1. You may import your other wallets into FxWallet through synchronization of wallets and you may export your wallets from FxWallet to other token management wallets.
2. FxWallet will display the information of imported wallets to you. You may add or delete Tokens, transfer and collect Tokens using the “Assets” column.
You understand that you may handle the following operations in the “Me” column on FxWallet:
1. In the “Address Book,” you can view and modify your “Wallet Addresses” at any time;
2. In “Security”, you can choose to enable the “Biometrics” option, which allows you to use biometric services to access FxWallet；
When we collect information from you for a specific purpose, we will ask for your consent in advance, which you are entitled to refuse. However, you understand that when you refuse to give such consent, you also give up the choice to use specific services provided by FxWallet.
You acknowledge that since blockchain is an open source system, your transaction records are automatically public and transparent throughout the whole blockchain.
You understand that after you link to the third-party-developed DApps from FxWallet, the FxWallet Terms of Service and FxWallet Privacy Policy will no longer apply. You are encouraged to carefully review its privacy policies and related terms of service before you start to use the third-party-developed DApps.
You are entitled to require us to update, revise, or delete your relevant information.
We reserve the right to collect your information without your prior authorization or consent in accordance with Article 6 of Section 1 of this Policy.

Information We may Share or Transfer

The Personal Information collected by DXP for business and legal purposes.
Personal Information will not be sold, traded or transferred to third parties without your consent.
The Personal Information may be disclosed to these entities if you agree to our disclosure of your personal information to strategic partners or related parties. These entities will only use your personal information for the purposes you have agreed to.
You agree that we may disclose or share your personal information with the following third parties:
1. service providers and data processors who represent us and provide services to us, such as KYC inspections, accounting, data processing or management services, website hosting, maintenance and operation services, mail information services, analysis services, and payment transaction processing, marketing, etc.;
2. DXP consultants and professional consultants (such as accountants, lawyers, auditors).
Personal Information may be transferred to any other country for purposes mentioned above. DXP will obtain your consent and ensure that the recipient of your personal information has the same level of personal information protection measures as DXP. If there is no personal information protection law applicable to the relationship between DXP and you in these countries or regions, we will sign a legally enforceable agreement with the receivers of your personal information.
DXP will not share with or transfer your Personal Information to any third party without your prior consent, except for the following circumstances:
1. The collected personal information is made public by yourself;
2. The Personal Information is collected from public information which was legally disclosed, such as news (lawfully reported), government information disclosure and other channels;
3. We may share your Personal Information with our affiliates only when necessary and to the extent permitted by this Policy;
4. In order to abide by applicable laws, regulations, legal procedures, and administrative or judiciary authorities, DXP will provide or implement this Policy to protect our or other parties’ rights, assets or security;
5. In the case of mergers and acquisitions, if the transfer of Personal Information is involved, DXP may require the receivers of Personal Information to be continuously bound by this Policy.

How We Collect Data Automatically

We use automatic data collection technology in the application. e.g:
1. Cookies (or browser cookies). Cookies are small text files set by the operator of a website or application to identify your browser or device. We may use cookies on our apps to store and track information, such as the number and frequency of use of users, user distribution, and users’ online preferences. Cookies do not capture information that can identify you, but the information they collect can help us analyze the usage of the application to improve your experience. You can turn off cookies in your browser settings. However, this may affect the functionality of the application.
2. Network analysis. Web analytics is a method for collecting and evaluating the behavior of visitors to web pages and mobile applications. This includes analyzing traffic patterns, such as determining the frequency of visits to certain functions of a website or mobile application, or understanding the information or services that visitors are most interested in. We use network analysis services provided by third-party tools.
We use third-party SDK in the application. e.g:
- SDK name: OneSignal
- Service Type: In-App Message Notifications
- Type: Web Activity Information (may involve device ID, transaction information. We will request your authorization before collecting this information)
- Privacy Policy Link: https://onesignal.com/privacy_policy

How We Protect Your Information

If DXP terminates operation, DXP will stop the collection of your Personal Information in a timely manner, and post the announcement on FxWallet and delete or anonymize your Personal Information held by us within a reasonable period.
To protect your Personal Information, DXP may adopt data security techniques, improve internal compliance levels, provide security training for our staff, and set security permission for access to relevant data to protect your Personal Information.
We will send you messages about information security in the “Wallet Guide” column and update articles concerning the use of wallets and information protection in the “Wallet Guide” column on FxWallet for your reference.

Protection for the Minors

The following special provisions apply to minors who are under the age of 18:

The minors shall not use FxWallet without the guidance from their parents or legal guardians.
The parents and legal guardians of the minors shall provide guidance to the minors on using FxWallet after they read this Policy, FxWallet Terms of Service and other relevant rules.
FxWallet will ensure the confidentiality and security of the minors’ Personal Information in accordance with national laws and regulations.

Disclaimer

After you link to the third-party-developed DApps from FxWallet, the privacy policies of the third-party-developed DApps will apply. The collection and use of your Personal Information by the third-party-developed DApps will be controlled by neither DXP nor this Policy.
You should carefully select and use the third-party-developed DApps and protect your Personal Information. DXP shall not be held liable for the privacy protection obligation of any third-party-developed DApps.
You acknowledge and accept that, to the maximum extent permitted by applicable law, DXP will adopt measures as reasonable as possible to protect your Personal Information under current techniques on an “as is”, “as available” and “with all faults” basis, to avoid the disclosure, tampering or damage of information. Since DXP transfers data wirelessly, DXP makes no guarantee on the privacy and security of wireless internet data transferring.

Miscellaneous

As a company that provides services to you, we will not actively provide your Personal Information to third parties other than as agreed, unless we obtain your consent and inform the other party’s identity, contact information, processing purpose, processing method, etc. If there is service demand for processing your personal sensitive information in the future, we will ask for your permission once again, and use it after obtaining your consent.
If you are a user outside of Singapore, you shall fully understand and conform to the laws, regulations and rules in your jurisdiction which are relevant to use of DXP.
During your use of DXP services, if you come across any problems related to the usage of your Personal Information, you may contact us by submitting your feedback on FxWallet.
You may access this Policy and other service rules of DXP on FxWallet. We encourage you to check the Terms of Service and Privacy Policy of DXP each time you log into FxWallet.
This English version and other translated versions of this Policy are provided for the convenience of users, and are not intended to revise or replace the original Chinese version of this Policy. If there is any discrepancy between the Chinese version and non-Chinese version of this Policy, the Chinese version shall prevail.

This Policy shall become effective on January 1, 2025.

As for any issues not covered in this Policy, you shall comply with the announcements and relevant rules as updated by DXP from time to time.

DXP COMPUTING POWER FOUNDATION PTE.LTD.