Privacy Policy 2023/08/06

Article 1

Purpose and Basis. In order to provide the services of ThunderTrend to Users, we need to collect some of your personal information when you register with ThunderTrend, log in to ThunderTrend and/or use the services offered by ThunderTrend. This Privacy Policy, in combination with ThunderTrend’s other applicable policies, set out the rules as to the use and protection of the collected information in order to prevent misuse.

Article 2

Designation. For the convenience of wording in this agreement (the “Agreement”), ThunderTrend is referred to as “we”, “us” or “our”. Users of and other visitors to ThunderTrend are referred to as “you”, “your” or “User”. We and you are collectively referred to as “both parties” and as “a/one party” individually.

Article 3

Definition and Interpretation. The following terms or expressions shall have the meanings ascribed to them below, unless any other term or condition hereunder provides otherwise:

（1）Personal Information: all information that is recorded electronically or otherwise and can be used, whether independently or in combination with any other information, to identify any particular natural person or reflect the pattern of behaviour of a particular natural person, including, but not limited to, sensitive personal information;

（2）Sensitive Personal Information: including but not limited to identity card and other proof of identity documents details, personal biometric information, bank account details, registered address, whereabouts, transaction information, etc.;

（3）Deletion of personal information: the deletion of personal information from any system involved in carrying out routine business functions so that such personal information cannot be accessed or retrieved.

Article 4

Scope of Application. This Agreement shall apply to all Users interacting with ThunderTrend. Users shall comply with the terms and conditions of this Agreement, subject to and as permitted by any and all laws relating to the protection of personal information and data in the country or region where they are based.

Article 5

Invocation. Any code or statutory decree or administrative regulation referred to in this Agreement shall refer to the latest amended version thereof, regardless of whether such amendment is made before or after the signing of this Agreement.

Article 6

Headings. The headings used in this Agreement are for convenience only and shall not be used for the purpose of interpreting the terms and conditions of this Agreement. References herein to any statement, term, condition, annex, schedule shall refer to statements, terms, conditions, annexes and schedules hereunder.

Article 7

Use of the term "include". The term “include” used herein shall, under any and all circumstances always have the meaning of “include but not limited to”, unless this Agreement specifies otherwise.

Article 8

User Consent and Authorization. The Users acknowledge and understand that, at the point of logging into ThunderTrend, the User will be deemed to have expressed to us their acceptance, consent, undertaking and confirmation of the following, regardless of whether the User has completed their registration on ThunderTrend:

（1）that the User agrees, on a voluntary basis, to disclose personal information to us;

（2）the User will abide by all the terms and conditions of this Agreement;

（3）the User agrees and authorises ThunderTrend to collect the User’s personal information when the User registers with ThunderTrend, logs into ThunderTrend and/or uses ThunderTrend services;

（4）the User agrees to all the terms and conditions of this Agreement and agrees to accept any amendment that may subsequently be made to the Privacy Policy;

（5）the User agrees that any of our branch companies, subsidiary companies, or employees will contact the User in connection with any product and service that may be of interest to the User (unless the User has indicated that he or she does not wish to receive such information).

Article 9

Information Collected. The Users agree that ThunderTrend may use cookies to track the User’s actions in connection with their use of ThunderTrend and may collect and record all information left by Users, including but not limited to their IP address, geographical location and other data.

Personal data which we may collect include:

•Personal Identification Information: Full name, date of birth, nationality, gender, ethnicity, signature, facial data, utility bills, photographs, phone number, precise location, home address, and/or email.

• Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.

• Virtual Identity: ThunderTrend Account/ Password, ThunderTrend Nickname.

• Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.

• Financial Information: Bank account information, payment card primary account number (PAN), account assets, transaction history, trading data, and/or tax identification.

• Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.

• Message Content: Feedback, Email, SMS, App Rating, Comments.

• Application Activity: Browsers and tap records, search history, installed apps, user-generated content, favorites.

• Device Information: Carrier, brand, software version, model name, manufacturer, system language, network, OAID, IMEI, GUID, MAC address.

• Employment Information: Office location, job title, and/or description of role.

• Correspondence: Survey responses, information provided to our support team or user research team.

• Audio, electronic, visual and similar information, such as call and video recordings.

We will collect your personal data in accordance with the legislative purpose of the DPA. We may also collect and store certain information automatically when you visit the Site/APP. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites/APP or use the Services. This information helps us address customer support issues, improve the performance of our Sites/APP and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

Online Identifiers: Geolocation/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.

Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

For example, we may automatically receive and record the following information on our server logs:

(1) How you came to and use the Services;

(2) Device type and unique device identification numbers;

(3) Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);

How your device interacts with our Sites/APP and Services, including pages accessed and links clicked;

(4) Broad geographic location (e.g. country or city-level location); and Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

(5) Application checklist: For advertising and safety use and approval of service applications.

We may also use identifiers to recognize you when you access our Sites/APP via an external link, such as a link appearing on a third-party site.

Article 10

Application and Usage of Information Permission

Android Permission Description Application android.permission.INTERNET Network access permission Allows applications to be networked android.permission.ACCESS_NETWORK_STATE Get network status permission Allows applications to get the network status android.permission.CHANGE_NETWORK_STATE Change network status permission Allows applications to change the network status android.permission.ACCESS_WIFI_STATE Get WiFi status permission Allows applications to get the WiFi status android.permission.CHANGE_WIFI_STATE Change WiFi status permission Allows applications to change the WiFi status android.permission.FOREGROUND_SERVICE Frontend service start permission Allows market monitoring through the ticker widget android.permission.RECEIVE_BOOT_COMPLETED Boot broadcast monitoring permission Allows monitoring of background tasks in workmanager android.permission.USE_FINGERPRINT Touch ID permission Allows fingerprint login android.permission.VIBRATE Vibration permission Allows phone vibration android.permission.WAKE_LOCK Wake lock permission Allows keeping the screen in awake status for KYC android.permission.CAMERA Camera access permission Allows taking of photos and scanning of ID cards for KYC android.permission.ACCESS_COARSE_LOCATION Coarse location information access permission Allows push notifications for news and events android.permission.READ_PHONE_STATE Read local identification code permission Allows device fingerprinting, statistics, and facial recognition android.permission.READ_EXTERNAL_STORAGE android.permission.WRITE_EXTERNAL_STORAGE Read and write external storage permission Allows reading or writing of images, files, etc. to ensure stable app operation android.permission.WRITE_SETTINGS Read and write system settings permission Allows device fingerprint functionality android.permission.REQUEST_INSTALL_PACKAGES Unknown source installation permission Allows offline push notifications android.permission.SYSTEM_ALERT_WINDOW android.permission.SYSTEM_OVERLAY_WINDOW Hoverbox permission Allows floating window functionality ClipboardManager Clipboard access permission Used for 2FA login, red envelopes, and deposit and withdrawal services iOS Permission Description Application NSFaceIDUsageDescription Facial or fingerprint information access permission Login with Facial ID Camera Camera access permission Allows taking of photos and scanning of ID cards for KYC LocationServices Coarse location information access permission Allows push notifications for news and events Photos Read and write external storage permission Allows reading or writing of images Push Push permission Allows offline push notifications UIPasteboard Clipboard access permission Used for 2FA login, red envelopes, and deposit and withdrawal services

Article 11

Supply of Information. If Users voluntarily use the services provided by ThunderTrend, they will be required to fill in and/or provide the following two categories of information in accordance with the requirements of ThunderTrend:

（1）Identity Information: this category of the User information, which may help ThunderTrend verify whether the User is eligible to register on ThunderTrend, includes, but is not limited to: the User's full name, registered address, postal address, official proof of identity documents and the document numbers, as well as all other information that may assist ThunderTrend in verifying the User’s identity (hereinafter collectively referred to as "Identity Information");

（2）Service Information: this category of User information helps ThunderTrend to contact the User and to provide a smooth service experience It includes, but is not limited to, the User’s telephone number, fax number, valid email address, postal address, and debit card information and/or other account information (hereinafter collectively referred to as "Service Information").

Article 12

Changes in the Method of Information Collection. When a User uses ThunderTrend, ThunderTrend may collect additional necessary information by an email box that is exclusively owned by ThunderTrend and released to the public via ThunderTrend or by any other method that is deemed as in compliance with relevant laws and regulations, so as to improve the functionality of ThunderTrend and enhance the Users' experience of using ThunderTrend services and the security thereof, or as is required by any order of a court, any applicable law or regulation, or any other competent government agency.

Article 13

Third-party Websites. If a User visits any link on this APP that leads to a third-party website or to a third-party partner’s website, the User agrees to and shall comply with the separate and independent privacy policies of such third-party websites. The User understands and acknowledges that ThunderTrend is not responsible for the content or activities of such third-party websites or partners.

These sources may include:

(1) Our ThunderTrend Family of Companies: Our “family of companies” is the group of companies related to us by common control or ownership (“Affiliates”). In accordance with applicable law, we may obtain information about you from our Affiliates as a normal part of conducting business, if you link your various ThunderTrend accounts (e.g., ThunderTrend Wallet account or ThunderTrend Commerce account in order to convert cryptocurrency into fiat and make withdrawals into your bank account), so that we may offer our Affiliates’ Services to you.

(2) Public Databases, Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law

. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contract with you and others.

(3) Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you.

(4) Social Media Platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect some information about you through cookies they place on your device and other tracking mechanisms. In some cases, the social media company may recognize you through its digital cookies even when you do not interact with their application. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and the controls they make available to you.

(5) Other Third Parties: We may receive information about you from third-party partners such as marketing partners when we jointly offer Services or from an advertiser about your experiences or interactions with them.

Article 14

Use of Information. ThunderTrend may use the information collected from Users for any of the following purposes:

(1) To provide, maintain, improve, and enhance our Services;

(2) To understand and analyze how you use our Services and develop new products, services, features, and functionality;

(3) To communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to our Services, and for marketing and promotional purposes;

(4) For our internal analytics and tracking purposes;

(5) To find and prevent fraud, and respond to trust and safety issues that may arise;

(6) For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

(7) For other purposes for which we provide specific notice at the time the information is collected.

Article 15

Disclosure of Information. ThunderTrend will not disclose any User's personal information to any third party, unless such disclosure is:

(1) Required by applicable laws or regulations or by any order of a court or other competent government agency;

(2) Required by ThunderTrend’s business (including but not limited to providing services to the User, settling disputes, resolving problems, and enforcing any agreement between ThunderTrend and the User);

(3) For the purpose of preventing imminent harm to the public or the interest of the public;

(4) ThunderTrend deems it necessary or appropriate to provide such information to any other third party with the User's prior consent.

Article 16

Protection of Information. ThunderTrend will take reasonable measures to protect the User's personal information from any unauthorized access, alteration, disclosure or destruction. ThunderTrend will take reasonable measures to ensure the reliability of any employees who may have access to the User's personal information, and to ensure that such employees comply with the principle of confidentiality.

Article 17

Amendments. ThunderTrend reserves the right to amend this Agreement from time to time and will post the updated Agreement on ThunderTrend. The User agrees to review the Agreement periodically to be aware of such modifications. The User's continued use of ThunderTrend shall be deemed to be the User's conclusive acceptance of the modified Agreement.

Article 18

Contact Us. If you have any questions about this Privacy Policy, please contact us at: [insert contact email]

Article 19

Governing Law. This Agreement shall be governed by and construed in accordance with the laws of [insert jurisdiction], without regard to its conflict of law provisions.

Article 20

Dispute Resolution. Any dispute, controversy or claim arising out of or in connection with this Agreement, or the breach, termination or invalidity thereof, shall be finally settled by arbitration in [insert jurisdiction] in accordance with the Arbitration Rules of the [insert arbitration institution] in force on the date when the Notice of Arbitration is submitted in accordance with these Rules. The arbitral tribunal shall consist of [one or three] arbitrator(s). The language of the arbitration shall be English.

Article 21

Severability. If any provision of this Agreement is held to be invalid or unenforceable, such provision shall be struck and the remaining provisions shall be enforced to the fullest extent under law.

Article 22

Entire Agreement. This Agreement constitutes the entire agreement between you and ThunderTrend and governs your use of ThunderTrend, superseding any prior agreements between you and ThunderTrend.

Article 23

Waiver. The failure of ThunderTrend to exercise or enforce any right or provision of this Agreement shall not constitute a waiver of such right or provision. If any provision of this Agreement is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties' intentions as reflected in the provision, and the other provisions of this Agreement remain in full force and effect.

Article 24

Statute of Limitations. You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of ThunderTrend or this Agreement must be filed within one (1) year after such claim or cause of action arose or be forever barred.

Article 25

The section titles in this Agreement are for convenience only and have no legal or contractual effect.