1. Introduction

1.1 HUOBI MENA FZE. (referred to as 'Company', 'we', 'us' or 'our') is a company incorporated under the laws of United Arab Emirates.

1.2 The Company is related to other companies and entities ('related entities'). This Privacy Policy applies to all Personal Information collected by the Company and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities. A reference in this Privacy Policy to 'Company', 'we', 'us' or 'our' is also a reference to those related entities.

1.3 Personal Information may be collected by us and by our third-party service providers who assist us in operating our website at https://www.huobimena.com  including its subdomains and any other website we operate from time to time (collectively, the 'Website'). The Website is a platform dedicated to the transaction of digital assets and the provision of related services ('Services').

1.4 All natural persons or other entities who view or log on to this Website are considered users of this Website. For convenience, the users are referred to as 'you'.

2. Personal Information

'Personal Information' is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

3. Purposes of the Privacy Policy

“DP Law” means data protection law applicable to HUOBI MENA FZE, its successors or implementing texts. This notice covers our use of your personal data arising from use of the HUOBI MENA FZE website as well as registering / subscribing / buying / using our products and services.

HUOBI MENA FZE is committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to inform you about the kinds of Personal Information that we may collect and retain about you by your use of this Website, how we collect, retain, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information

4. Your consent

4.1 To ensure that you have full confidence in our handling of Personal Information, you are advised to read and understand the terms of this Privacy Policy in detail. In particular, when you read, browse or download information from our Website, regardless of whether you register with this Website, you will be deemed to have provided your consent to the following:

4.1.1 You consent to us using your Personal Information as set out in this Privacy Policy;

4.1.2 You consent to the collection, use, storage and processing of your Personal Information through your use of this Website, your registration with this Website, and your use of the Services offered by us;

4.1.3 You agree to any changes and modifications that we may make to our Privacy Policy in the future; and

4.1.4 You consent to our branches, affiliates and employees using your Personal Information for sending you information, including promotional material, and that they may contact you in connection with our products and services that you may be interested in, now and in the future (unless you have indicated that you do not want to receive such information). You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.

5. Personal Information Collected

5.1 Personal Information we may collect about you may include (but is not limited to) the following:

5.1.1 Name, postal or email address, telephone numbers and date of birth;

5.1.2 Gender;

5.1.3 Identity information such as driving license, passport and visa details or any other valid ID as per the local regulatory requirements.

5.1.4 Payment details, such as your credit card or bank account details;

5.1.5 Your IP address, analytics and remarketing;

5.1.6 Your location; and

5.1.7          Any other information that we deem necessary.

5.2 If you are willing to use the services offered by this Website, you will be required to fill in and provide the following two categories of information:

5.2.1 IdentityInformation

Such information can help us verify whether you are eligible to be registered as a member of this Website. It includes but is not limited to your name, residence address, mailing address, other certificates and corresponding numbers thereof that are issued by your country or government to certify your identity information, as well as all other information that can help us to verify your identity ('identity information').

5.2.2 Service information

Such information helps us to contact you and provide you with the Services, including but not limited to your phone number, fax number, valid email address, mailing address, and information concerning your accounts ('service information').

5.3 When you use this Website or the Services, we may collect more information necessary in any manner that we consider as in compliance with relevant requirements, for the purpose of improving the functions of this Website, enhancing your experience of using this Website and its services as well as the security thereof, or as is required by any court order, any applicable law, administrative regulation or any order of any other competent government agency.

5.4 If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, we may not be able to provide you with the Services or to effectively conduct our relationship with you.

6. Information collected via our Website

6.1 We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the methods set out in this paragraph.

Cookies

6.2 When you visit our Website, we use third party cookies to record our performance and check the effect of online advertising. Cookies are a small amount of data that is sent to your browser and stored on your computer hard drive. Only when you use your computer to access our Website can the cookies be sent to your computer hard drive.

6.3 Cookies are usually used to record the habits and preferences of visitors in browsing the items on our Website. The information collected by cookies is non-registered and collective statistical data.

6.4 Cookies, which enable the Website or service provider system to recognize your browser and capture and recall information, cannot be used to obtain data on your hard drive, your email address, or your personal data. Most browsers are designed to accept cookies. You can opt to set your browser to reject cookies, or to notify you as soon as possible if you are loaded on cookies. However, if you set your browser to disable cookies, it is possible that you may not be able to launch or use some functions of our Website.

Third party content (eg social media links)

6.5 Some of the content on our Website includes applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

7. Use of Personal Information

7.1 We use the Personal Information we collect about you for our business functions and activities, in order to operate our business efficiently, and to market our products and services for the benefit of our customers.

7.2   We may collect, hold and use your information for the following purposes:

7.2.1 to provide you with our Services through our Website;

7.2.2 to identify and confirm your identity when you use our Website;

7.2.3 to alert you of new products or services, features, or enhancements;

7.2.4 to handle/route your customer service or technical support questions or issues;

7.2.5 to notify you of promotions and offers;

7.2.6 to help us manage our business operations;

7.2.7 for business support purposes including maintenance, backup and audit;

7.2.8 to improve our customer service - Information you provide helps us respond to your customer service requests and support needs more efficiently;

7.2.9 to collect and process payments - We may use the information you provide about yourself when placing an order only to provide services relating to that order. We do not share this information with outside parties except to the extent necessary to provide the service; and

7.2.10 to fulfil compliance requirements - We may use the information you provide in order to ensure that regulated companies which work with us are able to fulfil their obligations under legislation relating to money laundering, terrorist financing, and other forms of regulatory compliance. We only share this information with outside parties to the extent necessary to provide the service.

7.3 We reserve the right at all times to monitor, review, retain or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

7.4 We may occasionally hire other companies to provide services on our behalf, including but not limited to handling customer support enquiries, processing transactions or customer freight shipping. Those companies will be permitted to obtain only the Personal Information they need to deliver the service. We take reasonable steps to ensure that these organizations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

7.5 We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is in accordance with this Privacy Policy or any agreement you enter into with us, or required or authorized by law.

8. Disclosure of your Personal Information

8.1 We do not sell, trade, or rent your Personal Information to others. We may share generic aggregated demographic information not linked to any Personal Information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined below.

8.2 We may disclose your personal information to:

8.2.1 Any of the Company's internal divisions, business units or departments;

8.2.2 Financial institutions, payment processors, and identity service providers with which we operate;

8.2.3 Service providers under contract who help with parts of our business operations such as fraud prevention, compliance, marketing, and technology services. Our contracts dictate that these service providers only use your Personal Information in connection with the services they perform for us and not for their own benefit;

8.2.4 Law enforcement, government officials, or other third parties when:

8.2.5 We are compelled to do so by a subpoena, court order, or similar legal procedure; or

8.2.6 We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement; and

8.2.7 Other third parties with your consent or direction to do so.

9. Third party websites

You may find advertising or other content on our Website that link to the websites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from our Website. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Website, is subject to that website's own terms and policies.

10. International transfers of Personal data

We store and process your Personal Data in data centers around the world, wherever our facilities or service providers are located. As such, we may transfer your Personal Data outside of the United Arab Emirates. Some of the countries to which your personal data may be transferred for these purposes that are located United Arab Emirates do not benefit from an adequacy decision issued by the local law regarding protection afforded to personal data in that country.

11. Marketing

11.1 The Company will use your Personal Information for Direct Marketing purposes in accordance with paragraph 4.

11.2 If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:

11.3 clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us;

11.4 logging into your account on the Website and editing your communication preferences; or

11.5 contacting us using the contact details specified in paragraph 16.

12. Protection of Personal Information

12.1 We adopt appropriate electronic, management and technical measures so as to protect and safeguard the security of your personal data. We will, to the greatest extent possible, ensure that any Personal Information collected through our Website shall be free from being subject to nuisance by any third party unrelated to us. The security measures that we may take include but are not limited to:

12.2 Electronic measures: The computer data that contains your Personal Information will be stored in computer systems and storage media that are subject to strict login restrictions.

12.2.1 Management measures: only staff members duly authorized by us can access your Personal Information, and these staff members will comply with our internal code concerning Personal Information confidentiality.

12.2.2 Technical measures: such encryption techniques as Secure Socket Layer Encryption may be used to convey your Personal Information.

12.2.3 Other measures: our network servers are protected by proper 'firewall'.

12.2.4 If you are aware of any security flaws in our Website, please contact us immediately so that we can take appropriate action as soon as possible.

12.3 Despite of the above-mentioned technical and security measures, we cannot guarantee that information transmitted via the Internet is absolutely safe, so we cannot absolutely guarantee that the Personal Information that you provide to us through our Website will be safe at all times. We will not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to your personal data, and we shall not be held liable for compensation for such loss or damage.

12.4 If we find that we no longer require or have no further need for your Personal Information, we may de-identify it or remove it from our systems and destroy all record of it.

13. Deactivating your account

If you deactivate your account, we will mark your account in our database as "Deactivated", but will keep your account information in our database for a minimum of ten years. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. If you do deactivate your account, your Personal Information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

14. Modification to the Privacy Policy

We reserve the right to amend the Privacy Policy from time to time and at any time. We will inform you of the modifications made to the Privacy Policy by updating and publishing the effective date of the release of new versions hereof. We may issue a notice to inform you of any modifications made to the Privacy Policy, but we are not obliged to do so.

You are required to regularly review the Privacy Policy and focus on its modifications, and if you do not agree to such modifications, you shall immediately stop accessing this Website. When an updated version of this Privacy Policy is released, your continued visit to this Website will indicate and show that you agree to the update and agree to comply with the updated Privacy Policy.

15. Accessing/Updating your Personal Information and your statutory rights

You have certain rights concerning your Personal Data under DP Law as mentioned below, and can exercise them by contacting us.

Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it to check that we are lawfully processing it. We process a large quantity of information, and can thus request, in accordance with DP Law, that before the information is delivered, you specify the information or processing activities to which your request relates.

Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.

Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.

Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Transfer: you may request the transfer of certain of your personal data to another party.

Objection: where we are processing your personal data based on a legitimate interests (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal data for direct marketing purposes.

Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

If you have any requests, comments or complaints, please contact our compliance officer in charge of Privacy in any of the following ways: Email [email protected]

If you have any questions regarding our Privacy Policy, you are welcome to contact us at any time.

This Privacy Policy was last updated on 10^th of September 2018.