隐私政策

This privacy policy ("Policy") explains how lianbit.com (collectively "Lianbit", "we", or "us", and any Lianbit group entity whose services you register for, "Lianbit Entities") collects, uses, and discloses personal information through the website, mobile applications, and other online products and services that link to this Policy, including the products and services detailed in the following paragraphs (collectively, the "Services"), or when you interact with us in other ways.

These services include the provision of

Lianbit's social trading platform for investing in stocks, Currency, and trading Cryptocurrency where users can register an account on Lianbit.

Lianbit's system facilitates Lianbit Payment electronic money services (handling payments and debit cards) and Crypto services for various trading activities.

Websites, web platforms, or other services facilitated by any Lianbit Entity (any accounts described in trading activities).

We encourage you to read this Policy carefully as it is part of the relevant Lianbit Entity's terms and conditions, business terms, agreements with you, and/or terms of use, whichever is applicable.

If you accept or agree to this Policy on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind such company or legal entity to this Privacy Policy, and, in such event, "you" and "your" will refer and apply to such other company or legal entity.

Application of this Policy

For the purposes of applicable state and/or international data protection laws, the relevant Lianbit Entity you register with is the "controller" of personal information collected through www.lianbit.com, other Lianbit group entity websites (including Lianbit financial systems), and other platforms (collectively, the "Site"), and is the company to contact if you have questions about the use of your personal information (see the "Contact us" section below). This Policy also applies to personal data about any authorized representative of clients and about individuals or legal entities from which this personal data is collected in providing the Services (such as clients' company directors).

Information Collection

We collect information you provide directly to us. For example, we collect information when you create a Lianbit Account, participate in any interactive features of the Services, fill out forms, participate in contests or promotions, make a purchase, communicate with us through third-party social networking sites, request customer support, or otherwise communicate with us.

When You Register or Sign Up for a Lianbit Account or Service

If you register a Lianbit Account or another Service, we will collect basic information about you, including your name, email address, and phone number. You may provide this information to us directly or by logging into your account/service with third parties, including but not limited to Facebook or Google (see "Information We Collect from Other Sources" below). We will use the information we collect about you to:

• Create and maintain your Lianbit Account.

• Allow you to log into Lianbit.

• Contact you about your Lianbit Account and/or our Services (this may include marketing emails).

When You Provide Information to Build Your Profile

Once you create a Lianbit Account, we will ask you to provide additional information so that you can take advantage of specific features. We will ask you to provide copies of identification documents, country of identity, proof of address, and other documents that may be required by us to comply with our regulatory obligations and to verify your identity. Further details about the identification process can be found in the relevant Lianbit Entity's terms and conditions, business terms, and/or terms of use or client/customer agreements, as applicable.

Please note that if you choose to provide additional information about yourself to complete your "Profile", the information we request may include types of address, citizenship status, residence, and information about trading experience, investment portfolios, total cash and liquid assets, and other details or questions as required in creating a Profile, and this process may be amended by us from time to time.

It is optional for you to do so, but for legal and regulatory reasons, you will not be able to continue to use certain features unless you provide additional information.

We will use the information you provide in your Profile to

• verify your identity and conduct checks required by applicable laws and regulations, including but not limited to, "know your customer" (KYC), anti-money laundering, fraud, sanctions, and politically exposed person checks.

• contact you about matters related to your Lianbit Account, including requesting additional information or documentation.

• provide you with notices related to your Lianbit Account, general updates, market updates, and other marketing materials, including about the Services offered by Lianbit group members.

• customize products and services offered through the Site to you, including but not limited to, assessing any suitability or appropriateness for using our services and/or products, such as our high leverage trading services and Social Trading Feature.

• assess your credit risk.

• assess your risk score according to parameters determined by Lianbit.

• assess whether you qualify as a professional client, wholesale client, or other specific client category.

• maintain administrative records related to our business.

• implement security measures to secure your account, including but not limited to, two-factor authentication ("2FA"); and provide Services.

You can update your Profile at any time by visiting the "Account" page in the Settings menu when logged into your Lianbit Account. We recommend that you update your Profile periodically to ensure that Lianbit's functionality offered to you is in line with your current circumstances. You further agree to update such information upon request by Lianbit, if Lianbit deems the information provided to be inaccurate, incomplete, and/or inconsistent with other information provided by you at any time. You acknowledge that we may rely on such information and that you are responsible for any damage or loss that may result from inaccuracies, including but not limited to, the incompatibility of our Services with your Profile. You are not obliged to complete your Profile and, therefore, are not required to provide such information; however, if you choose not to do so, we may not be able to offer the full functionality of Lianbit to you.

When You Contact Us

If you contact us via phone, ticket, or use other features offered by Lianbit, such as chat features, we will collect any information about the communication and any additional information you choose to provide us. We will use this information to review, investigate, and respond to any comments or questions you pose. Please note that we record and store all phone calls and other communications with us and may use them in our dealings with you, including dispute resolution or any legal proceedings.

When Lianbit Users Invite You to Use Lianbit

Lianbit users may invite their contacts to register an account with us. We only collect the individual email addresses selected by the user to be invited to join Lianbit, and Lianbit only uses the email address to send an invitation to the individual at the request of the existing Lianbit user.

Information About Your Use of Lianbit Services

When you access or use our Services, we automatically collect information about you (the type of information depends on the Site you are using), including:

• Financial Information: We collect financial information related to your use of the Services, including information you provide to us or that we collect from public sources.

• Log Information: We collect log information about your use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, other network identifiers, and the pages you visited before navigating to our Services.

• Device Information: We collect information about the computer or mobile device you use to access our Services, including hardware model, operating system and version, unique device identifiers, and mobile network information.

• Site Activity: We collect records of activity on the Site, including any content you post, details of your Lianbit Account, timing, value, and currency of any deposits, withdrawals, or transactions made, and payment method.

• Location Information: Subject to your device permissions, we may collect information about your device's geolocation.

• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. You can learn more about the use of cookies and similar technologies by Lianbit in our Cookie Policy.

Information We Collect from Other Sources

We may collect personal information about you from third-party entities when we seek to verify your identity as part of our regulatory requirements. This may include, for example, identity verification agencies, credit reference agencies, and similar bodies.

We may also collect information about you from third parties when you use or connect to Lianbit.

Information We Collect from Other Sources

We may also collect information about you from third parties when you use or connect to Lianbit through or via third-party platforms, such as Facebook, Google, or other sites. By using or connecting to Lianbit through these third-party platforms, you allow us to access and/or collect certain information from your third-party platform profile/account as permitted by the terms of agreement and privacy settings you have with the third-party platform. We will share this information with third-party platforms for their use.

Some of the information we collect from you during the installation of the mobile application will be shared by us with vendors and other service providers employed by, or cooperating with, us in connection with the operation and analysis of the Services we provide to you.

Unsolicited Information

If you provide us with personal information that we did not request, we will endeavor to store only information that is rightfully or legally ours to hold due to the products and services we provide. However, if this additional information is excessive for our requirements but is provided to us in a manner where it is combined with information we are obligated or entitled to hold, then you acknowledge that this unsolicited information may be stored by us in the same way as other personal information.

Use of Information

We use the information we collect to provide, maintain, and improve the Services, such as managing, verifying, and maintaining your account, providing the Services you request, and customizing your experience with us. We also use the information we collect to:

• Fulfill our obligations to you.

• Comply with our regulatory and legal obligations.

• Monitor/access any content you post.

• Administer transactions, including deposits, subscriptions, and other payments.

• Monitor trading activities on Lianbit, including by detecting inconsistencies in payments and trades and searching for possible illegal activities.

• Determine if payment methods are being misused.

• Compile statistical analyses of our platform and website pages.

• Monitor and analyze our business.

• Investigate and manage inquiries, disputes, and legal processes, as well as to comply with court orders, mandatory dispute settlement decisions, and government or law enforcement orders or directives.

• Provide information about you and your trades with us to credit reference/reporting agencies.

• Participate in crime prevention, legal compliance and regulations, and assist regulatory bodies, cybercrime, data protection and information, as well as law enforcement with inquiries and law enforcement efforts, even if not compelled to do so.

• Develop and market other products and services. and

• Transfer, assign, or allocate the rights or obligations of any Lianbit entity.

Sharing Information

We will not share personal information we hold about you except in the following circumstances:

• among and within Lianbit Entities, Lianbit, and our current and future parent companies, affiliates, subsidiaries, and other companies under common control and ownership. and

• with professional advisors, vendors, consultants, and other service providers, such as payment service providers, IT hosting companies, banks, other financial institutions, and credit reporting/reference agencies who need to access such information to perform work on our behalf.

• in connection with, or during negotiations for, any merger, sale of company assets, financing, or acquisition of all or part of Lianbit by another company.

• disclosure as required by, or mandated by, applicable law or legal process, including legitimate requests from public authorities to meet national security or law enforcement requirements.

• if we believe your actions are inconsistent with our user agreement or policies, or to protect the rights, property, and safety of Lianbit or others.

Social Sharing Features

If you have chosen to use one of our applications provided through social networks (such as Facebook, Twitter, etc.), our application will be granted access to your social network account information, including your name and username on the social network, profile picture, gender, network, user ID, friend list, and other information that you have allowed to be shared depending on the settings you have established with the entity providing the social sharing feature. For more information about the purposes and scope of data collection and processing related to social sharing features, visit the privacy policy of the entity providing this feature.

Your Choices and Rights

You may have certain rights and protections under the law regarding the processing of your personal data. For example, you also have the right to refuse, or request us to restrict, certain processing and, in some circumstances, to obtain a copy of your personal information in a machine-readable format. There are limitations to these rights where applicable, and in certain circumstances, we may not be required or able to fulfill your request, or we may only be able to fulfill your request in part.

Legal Basis for Processing

For transparency (where relevant under applicable data protection laws regarding the processing of your personal information), we process your personal information on the following legal bases:

Entering and Performing a Contract with You: If you have a Lianbit Account or have registered on the Site or for Services, our legal basis for processing your personal information is that it is necessary for the performance of the relevant Lianbit Entity's terms and conditions, business terms, and/or terms of use, and to provide the requested services to you. Concerning the Lianbit Account, this includes facilitating access to our platform, processing payments, and executing trades.

Other Legitimate Reasons, Including Legal Obligation and Legitimate Interests: We process your personal information where necessary for Lianbit to comply with legal obligations and regulations in the jurisdictions where we operate and also where necessary for our legitimate interests in conducting our business (or the legitimate interests of our partners in fulfilling their legal obligations), balanced against the rights of our customers, such as yourself. This includes, but is not limited to:

• Learning about your interests and preferences to contact you with information relevant to you and helping us target marketing communications and advertisements for our products and services to make them more relevant to you.

• Using your pseudonymous details to display advertisements for our products and services on social media platforms, such as Facebook, or through other third-party advertisements that may appear on other websites you visit. The information shared with these platforms is anonymized to protect your personal data.

• Analyzing and continuously improving the Site and Services and helping us internally test new Site versions to develop new features and ensure the efficient operation of Lianbit services.

• Detecting and reducing fraud and credit risk.

Subject Access Requests:

You may have the right to access the personal data we hold about you and request your personal data to be updated, corrected, deleted, or transferred. You may also have the right to refuse, or request us to restrict, certain processing. If you wish to exercise any of these rights, you can log in to your account or contact us via this link. Alternatively, you can contact us via email at [email protected]. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also keep cached or archived copies of information about you for a certain period.

Questions or Complaints:

If you are interested in exercising any of these rights (or confirming if they apply to our processing of personal data), you can log in to your account or contact us. Such requests should be communicated in writing to www.lianbit.com/contact-us/. If you have concerns about our processing of personal data that we cannot resolve, you may have the right to lodge a complaint with the relevant data protection supervisory authority where you reside. As mentioned above, even where these rights apply, they are subject to limitations. This means that, in certain circumstances, we may not be required or able to fulfill your request, or we may only be able to fulfill your request in part.

Promotional Communications

You can unsubscribe from promotional emails or text messages from Lianbit by following the instructions in the email or text message or by visiting the "Notifications" tab in the "Settings" menu on our platform. If you unsubscribe, we may still send you non-promotional emails, such as service messages about your Lianbit Account or our ongoing business relationship.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications/alerts to your mobile device. You can disable these messages at any time by adjusting the notification settings on your mobile device.

Transfer of Information to Other Countries

When using the Services, your data is processed and stored in China and other countries, including the UK. We and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide a level of data protection equivalent to the jurisdiction where you are located.

Where we transfer personal data from China or from the UK to a country outside China or the UK that is not recognized as providing adequate data protection, we provide adequate protection in the form of inter-company agreements based on Standard Contractual Clauses sanctioned under Chinese law or UK law (as applicable). For more information, please contact us at [email protected].

Lianbit Social Trading Platform

Lianbit provides a real-time social trading platform that integrates community and social characteristics into the trading platform. As part of the Lianbit trader network, traders who choose to be part of the community share their strategies and performance with the community. The amount traded is never disclosed publicly, and all these traders have explicitly agreed to be part of the network and share their strategies and performance.

Downloading, installing, and accessing Lianbit Services in connection with the trading platform is your agreement and acknowledgment that the following information and content will be considered as non-confidential and non-proprietary (except for your personal data as described below), collectively, "Content", and will be displayed publicly on the Site: your username and full name, your photo/avatar (if provided), the state of residence, gender, network, list of users following you, users mimicking you, trade-related statistics, etc., the list of users you follow or copy, and other content options that allow our users to interact with each other, including, without limitation, content and information you post in the Lianbit community, comments, feedback, posts, "likes", blogs, and/or any information you provide to us through the Site, and/or via email, chat, fax, or phone, and/or any other means.

Lianbit Payment

If you are an active Lianbit customer, in addition to the use of personal data described in other sections of this Policy, the information in this section also applies.

lianbit.com is a regulated entity that provides Lianbit Payment products and services and is the relevant Lianbit Entity for these Services. Lianbit provides and operates the relevant IT infrastructure (including the Lianbit Payment System) on behalf of Lianbit Payment.

Sharing Your Personal Data

To provide Lianbit payment products and services, Lianbit will share your personal data with third parties, including: agency banks that provide banking services, including issuing sort codes for UK clients, card networks, such as VISA, issuing processors, card processors, and related service providers supporting secure online payments and payment providers available in your country.

Storage of Personal Information

We store information that we collect about you for as long as necessary for the purposes for which the information was collected, or for other legitimate business purposes, including fulfilling legal obligations, regulations, or compliance. The period during which we will store personal information will vary depending on the purpose for which the information was collected, as well as the legal requirements or regulations that apply. For example, if you are invited to use Lianbit by another user, we will store the personal information about you provided by that other user for six months to send you an invitation via email.

If you have a Lianbit Account, we will store your personal information for as long as you maintain the account, and after you cease to hold the account, as long as required by the applicable law and regulations for us.

Security and Integrity of Information

We protect your personal information using data security technology and tools such as firewalls and data encryption. We also require you to use a username and personal password each time you access your account online. As stated in the relevant Lianbit Entity's terms and conditions, business terms, and/or terms of use, you should not share your password with anyone. We recommend that you do not reuse passwords previously used for other platforms/services. We strongly advise you to enable Two-Factor Authentication ("2FA") on your account. 2FA requires you to enter a verification code sent to your mobile device via SMS to access your account.

We limit access to personal information in our office so that only officers and/or employees with legitimate business purposes can access it.

Minors

Lianbit is not available to users under the age of 18 (or the legal consent age for the jurisdiction where the user is located) ("Minors"). We do not intentionally collect personal information from or about Minors. If you are a Minor, you should not download or use our services or provide any personal information to us. If we learn that a Minor has shared any information with us, we will delete that information. If you have any reason to believe that a Minor has shared any information with us, please contact us at www.lianbit.com/contact-us/.

Important Notice for California Residents:

Residents of the State of California should also review the California Resident Notice. You may have additional rights under California law.

For Nevada Users

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties intending to license or sell that personal information. You can exercise this right by contacting us using the contact details provided below with the subject line "Nevada Do Not Sell Request" and providing us with the name and email address associated with your account. Please note that we currently do not sell your personal information as defined in the Nevada Revised Statutes Chapter 603A.