1. Overview

 

The Privacy Policy, or Personal Information Collection Statement (“PICS”) below is issued by One Satoshi Technology Limited (“One Satoshi” or the “Company”). 

 

This Personal Information Collection Statement (“PICS”) explains the types of Personal Data we collect from customers (“you”) and how we process and protect that data. This PICS is governed by and observes the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the "PDPO").

 

2. Definitions

 

“Address”, if under cryptocurrency contexts, means any cryptocurrency addresses existed on any blockchains that are used to receive cryptocurrencies.

 

“AI Service” means the OpenAI services provided by OpenAI Global, LLC, a company incorporated in the United States.

 

“API” means Application Programming Interfaces, the set of protocols for building applications, web services, systems, and application software.

 

“Company”, or “One Satoshi” means the incorporated company in Hong Kong with registration number 3007468.

 

“Customers”, “User”, or “You” means the subscribers who used our Services and Product, both including paid Users and free Users.

 

“Personal Information Collection Statement” means the issued full text of this privacy policy.

 

“Product” means the whole product of CrimeLess which is the compliance solution developed by the Company.

 

“Risk Event” means any transferal or transaction events published on the blockchains that are defined or determined to be risky by any of the vendors, service providers and us.

 

“Risk Score” means the quantitative measures of the Risk Events associated with the Address.

 

“Service” means all the relevant services with the Product, including all underlying services that give functionality to the Product, including but not limited to risks event checking services, risks summarization services, address risk scoring services, etc.

 

“Personal Data” means any information of a natural person or an entity, which either caused an identification directly or indirectly, including but not limited to name, username, posting address, cryptocurrency address, driving licenses, locations, IP address, identity documents, device or machine identification.

 

3. Storage, Processing, Deletion of Your Data

 

3.1 Your data will be securely stored by us in accordance with our IT policy, including but not limited to our cloud servers at service providers, data centers of the service providers, our physical servers at designated premises, physical computer and storage devices etc. The jurisdiction of the data center may be outside of the Hong Kong Special Administrative Region.

 

3.2 Your data will be processed by our System at run time by our servers. During the processing, your data may be transferred to and disclosed according to clause 4.1.

 

3.3 Your data will be deleted no later than seven (7) years from the date of obtaining it. Our IT policy would allow us to delete them earlier than seven (7) years due to a bucket of other factors such as costs.

 

3.4 Your data may be stored by third party channels and companies including but not limited to Whatsapp, Telegram etc.

 

4. Disclosure of Your Data

 

4.1 We may disclose your Data to the following parties:-

• our affiliated companies, including to our holding companies, sister companies, subsidiaries, etc, further including their respective affiliates, representatives, employees etc.,

• our service providers, and their holding companies, sister companies, subsidiaries, etc,

• government entities of any jurisdictions, including but not limited to their law enforcement authorities, regulatory authorities and courts etc.

• industry practitioners, industry associations, legal, compliance, accounting professionals and research institutes etc. that have agreements with us,

• any other parties that we are morally required to comply with,

• any other parties that we are legally obligated to, and

• any parties with your prior consent,

 

4.2 Upon the disclosure of your Data to the parties, you will not be notified.

 

5. Marketing

 

5.1 You are defaulted to receive marketing emails and SMS. 

 

5.2 You have legal rights to unsubscribe from commercial electronic messages (e.g. faxes, emails, short messages, pre-recorded telephone messages, etc), according to Cap. 593 Unsolicited Electronic Messages Ordinance ("UEMO").

 

5.3 You can opt out of receiving marketing information by 

• contacting us at our official channels requesting to “STOP RECEIVING”, or

• contacting us through the methods specified in the commercial electronic messages according to UEMO

 

5.4 We may use and analyze your Data to market our other products and services.

 

6. Security

 

6.1 We are committed to maintain our highest standards for data security. 

 

6.2 You have obligations to ensure your account security, including but not limited to detecting suspicious, irregular, or potentially fraudulent account activities.

 

6.3 You have to contact us for termination of your accounts or sessions if there are any account security incidents. 

 

6.4 If any security breaches are detected, we will notify you in reasonable time.

 

6.5 We will not be legally responsible for any security breaches, or any loss caused directly or indirectly. You agree that under all circumstances, no compensation will be offered to You, regardless of the nature of the negligence.

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7. Indemnity and Disclaimer

 

7.1 We would not be held legally responsible for any failure or delay to act caused by circumstances beyond its reasonable control, including but not limited to acts of God, wars, riots, labour strikes, natural disasters, earthquakes, fire, floods, criminal acts, robbery, burglary, unforeseeable and/or unpredictable legislation announcement, government policy changes etc.

 

7.2 No refund will be offered under circumstances in clauses 7.1.

 

7.3 We do not constitute any solicitation or investment advice in any of its contents, including in the websites, official channels, applications etc.

 

7.4 We do not guarantee data correctness of this Product. The data produced is for your reference only. Any use of data is at your own risk.

 

7.5 We are not legally or contractually responsible for any incorrect data produced. You agree that under all circumstances, no compensation will be offered to You due to data incorrectness.

 

8. Amendment

 

8.1 We reserve full rights to modify the privacy policy (“PP”). The new PP would take effect on the specified effective date when it is issued. When you use the Product, you agree to the latest PP.

 

8.2 The meanings of terms, representations, conditions in English language prevail in case of any conflicts between translations. Translations in other languages are non-contractual that are subject to definitions and interpretations.