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Safeheron User & Privacy Agreement

Safeheron User Agreement

LAST UPDATED: Nov 21, 2022
Changelog
Version
Updated Terms
Update Date
Effective Date
V1.0.0
Published Safeheron User Agreement
2022-05-16
2022-05-16
V1.0.1
Term Added:
XV. Protecting Your Personal Information
We use administrative, physical, and technical security protections to protect the personal information we collect and process. Our security protection is to maintain the confidentiality, integrity and availability of your personal information and protect against reasonably expected threats.
2022-11-11
2022-11-11
V1.0.2
Term Updated:
XV. Your Personal Information Protection
This term is changed to Your Personal Information Protection with description of data security and privacy added.
2022-11-21
2022-11-21
Thank you for choosing Safeheron service. This Safeheron User Agreement (“Agreement”) is made between you (“you” or “user”) and Safeheron PTE. LTD. (“Safeheron”, or “we”) and is legally binding between you and Safeheron.
Safeheronl hereby reminds you that you must carefully read the full content of this Agreement and other documents mentioned in this Agreement before using Safeheron (“Safeheron” or “App”). Particularly, you must carefully read the section of “Disclaimer and Limitation of Liability” and other sections which are displayed in bold. You must make sure that you fully understand the whole Agreement and evaluate the risks of using Safeheron on your own.

I. Confirmation and Acceptance of this Agreement

You understand that this Agreement and other relevant documents apply to Safeheron and the Decentralized Applications (“DApps”) which are developed and owned independently by Safeheron PTE. LTD. on Safeheron (and excluding DApps developed by third parties).
After you download Safeheron and start to create or join the team, you are deemed as having read and accepted this Agreement, which shall cause this Agreement to become effective and legally binding on both you and Safeheron immediately.
Safeheron may, at its sole discretion, modify or replace this Agreement at any time. The modified Agreement will automatically take effect once it is posted on Safeheron and you will not be notified separately. If you do not agree with the modifications, you shall cease to use Safeheron immediately. Use of Safeheron by you after any modification to this Agreement constitutes your acceptance of this Agreement as modified.
If you are under 18 years old or you are a person of no capacity for civil acts or a person of limited capacity for civil acts, please use Safeheron under the guidance of your parents or guardians.

II. Definition

1. Safeheron: means the MPC blockchain wallet developed by Safeheron based on Ethereum (and other blockchain systems which Safeheron may support in the future) and other supporting tools which are developed for the convenience of the Users when using blockchain systems.
2. User
a) a User must be a natural person who possesses the full capacity for civil acts;
b) if you are under 18 years old, please use Safeheron under the guidance of your parents or guardians. If any person of no capacity for civil acts conducts any transactions on Safeheron or any person of limited capacity for civil acts conducts any transaction which does not commensurate his/her civil rights or act capacity, the parents or guardians of the User shall be liable for the consequences of such transactions.
3. Excluded Person
a) except for natural persons, persons who have the legal and consciousness ability to conclude this Agreement; or
b) users who are prohibited, restricted, unauthorized, or unqualified to use the service (as defined in this Agreement) ) in any form or method (in whole or in part) due to this Agreement, laws, regulatory requirements, or the provisions of the jurisdiction applicable to the user. For the avoidance of doubt, Chinese Users are also regarded as "Excluded Persons".
4. Use
a) Create or join team: Use Safeheron to create or join a team after you accept this Agreement.
b) Wallet Password: The password that the software operation interface prompts you to fill in during the process of using Safeheron wallet, which is used to encrypt and protect the private key shards. As a decentralized application, the wallet password is not stored on Safeheron's servers, and once lost, you need to reset the new password with recovery phrase.
c) Message Notification: The notifications/prompts in the Safeheron software operation interface suggest users follow the steps to operate.
d) Specific Users: Users who should cooperate with Safeheron and disclose Personal Information in order to comply with the laws, regulations, and policies of Singapore and other countries.
e) Private Key Shard: Consists of 256 random bits, the core for the User to hold and use the Tokens.
f) Public Key: Public key is derived from the Private Key based on cryptography and is used to generate blockchain wallet addresses. A wallet address is a public address for the reception of Tokens.
g) Recovery Phrase: Consists of 24 in-order words that are randomly generated, and it is based on BIP39, the industry standard of blockchain. It is a human-readable format of words to back up your Private Key for recovery. It is an easy-to-record form of private key shards, which is convenient for users to back up and keep.
h) Keystore: A file that is encrypted by Private Key Shard or Recovery Phrase and protected by the User’s Wallet Password. Keystore is stored only on Users’ devices and will not be synchronized to Safeheron servers.
i) Cryptocurrency: The cryptocurrencies which are supported by Safeheron currently, including but not limited to ETH, BTC, and so on.
j) Materials: Contents in the columns of “Safeheron Academy”, etc. on Safeheron. The Materials are Safeheron’s proprietary properties. User shall not reproduce or distribute the materials without Safeheron’s permission and authorization.
k) Personal Information: Various information recorded electronically or in other ways that can identify the user's personal identity alone or in combination with other information, including but not limited to the name, date of birth, ID number, personal biometric information, address, mobile number, bank card number of a natural person, email address, wallet address, mobile device information, operation records, transaction records, etc., but does not include the user's wallet password, private key, recovery phrase, and Keystore.

III. Services

1. Create or import team. You may use Safeheron to create a new team or join a team in accordance with this Agreement.
2. Transfer and Receive Cryptocurrencies. You may use Safeheron wallet to manage your digital tokens by transfer and receive, i.e., you may revise the blockchain ledger by signing with your Private Key Shard. Transfer/Send means the payer transfer the cryptocurrencies to the blockchain address of the payee. The actual transfer and receive happen on the blockchain system (instead of on Safeheron).
3. Observe the market. You may use Safeheron to observe the quotation of the cryptocurrency supported by Safeheron. The quotation of each token is captured by Safeheron from the corresponding party and is displayed in the “Wallet” column on Safeheron.
4. Manage Assets. You may use Safeheron to add and manage cryptocurrencies supported by Safeheron.
5. Browse the DApp. Users may connect to DApps and authorize DApp operations through browser plug-ins, Wallet Connect, etc. provided by Safeheron.
6. Transaction History. We will copy all or part of your transaction records from the blockchain system. However, Users shall refer to the blockchain system for the latest transaction history.
7. Suspension of Service. You understand that we are not able to reverse or cancel the transaction because transactions based on blockchain technologies are irrevocable. However, under certain circumstances, we may suspend or limit the function of Safeheron used by a particular User.
8. Other services that Safeheron would like to provide.

IV. Users who use Safeheron must understand that

1. In order to guarantee the security of users’ cryptocurrencies, Safeheron offers decentralized service which is largely different from the banking and financial institutions. Users shall understand that Safeheron DOES NOT provide the following services:
a) Store users’ Wallet Password (the password users set in Security), local Private Key Shard, Recovery Phrase or Keystore;
b) Recover users’ Wallet Password, local Private Key Shard, Recovery Phrase or Keystore;
c) Freeze the wallet;
d) Report the loss of wallet;
e) Recover the wallet;
f) Rollback transactions.
2. Users shall take care of their devices, back up the Safeheron App, and back up the Wallet Password, Recovery Phrase, local Private Key Shard, and Keystore by themselves as Safeheron doesn’t provide the above services. Safeheron is not able to recover the wallet or wallet password, private key shard, recovery phrase, or Keystore for the cases: a) user’s device is lost; b) user deletes Safeheron App and doesn’t back up Safeheron; c) user deletes and doesn’t back up wallet; d) wallets get stolen or forget wallet password, local private key shard, recovery phrase or Keystore. Nor can Safeheron cancel transactions for the mishandling of Users (such as typing in wrong addresses for transactions).
3. Safeheron does not support all existing cryptocurrencies. Do not use Safeheron to handle any non-supported cryptocurrencies.
4. Safeheron is only a tool for Users to manage their cryptocurrencies and is not an exchange or a trading platform. For the purpose of this Agreement, the word “transactions” only means transferring and receiving cryptocurrencies, which is substantially different from transactions on the exchanges and trading platforms.
5. Safeheron support integrating DApps. Users shall, at their sole discretion, decide whether there would be any risks to accept the services or transactions provided by or to conduct transactions on the third-party-developed DApps and operate as per the third-party DApps’ policies.

V. Your Rights and Obligations

1. Create or Join Team
A. Create or join team: You are entitled to use Safeheron on your device to create and/or join team in accordance of this Agreement. You set Wallet Password and other information and use your wallet on Safeheron to transfer and receive cryptocurrencies on blockchain.
B. Identification verification: Specific Users will be asked to complete identification verification before using Safeheron to comply with related laws and regulations, according to the notification of Safeheron. Specific Users may be asked to provide Personal Information including but not limited to name, ID card number, mobile number, bank card information, etc., without which the Specific Users will not be able to use certain services and the Specific Users alone shall be responsible for the loss caused by their delay in completing the verification.
C. Safeheron may develop different versions of Safeheron software for different terminal devices. You shall download and install the applicable version. If you download and install Safeheron or other applications with the same name as “Safeheron” from any unauthorized third party. Safeheron cannot guarantee the normal operation or security of such applications. Any loss caused by using such applications shall be borne by you.
D. A previous version of Safeheron may stop operating after a new version is released. Safeheron cannot guarantee the security, continuous operation, or customer service of the previous version. Users shall download and use the latest version.
2. Use of Safeheron
A. Users shall take care of their devices, Wallet Password, local Private Key Shard, Recovery Phrase and Keystore by themselves. Safeheron does not store or hold the above information for Users. You shall be responsible for any risks, liabilities, losses and expenses which result from frauds, you losing your device, disclosing (whether actively or passively) or forgetting Wallet Password, local Private Key Shard, Recovery Phrase or Keystore, or your wallet being attacked.
B. Follow the Alert. You understand and agree to follow the Alert pushed by Safeheron. You shall be responsible for any risks, liabilities, losses and expenses which result from your failure to comply with the Alert.
C. You understand that Safeheron undertakes no responsibility to conduct due diligence on the services or transactions provided by third-party-developed DApps. You shall make investment decisions rationally and assume the risks by yourself.
D. Complete the identification verification. If Safeheron reasonably deems your operation or transactions to be abnormal, or considers your identification to be doubtful, or Safeheron considers it necessary to verify your identification documents or other necessary documents, you shall cooperate with Safeheron and provide your valid identification documents or other necessary documents and complete the identification verification in time.
3. Transfer of Cryptocurrencies
A. You understand that you may be subject to daily limits on the amount and times of transfers according to your location, regulatory requirements, transferring purposes, risk control by Safeheron, or identification verification.
B. You understand that blockchain operations are “irrevocable”. When you use Safeheron to transfer cryptocurrencies, you shall be responsible for the consequences of your mishandling of the transfer (including but not limited to wrong addresses).
C. You understand that the following reasons may result in “transfer failed” or “mining overtime”:
a) Insufficient balance in wallet;
b) Insufficient gas for transaction;
c) Blockchain’s failure to execute the code of smart contracts;
d) The transfer amount exceeds the transfer limits imposed by authorities, Safeheron or laws or regulations;
e) Technical failure of the network or equipment;
f) Abandoned transactions result from blockchain network congestion or failure;
g) The wallet address of yours or your counterparty’s is identified as special addresses, such as high-risk address, exchange address, ICO address, Token address, etc.
h) Safeheron has been taken by competent authorities to suspend payment, freeze or otherwise restriction to use.
D. You understand that Safeheron is only a tool for transfer of cryptocurrencies. Safeheron shall be deemed to have fulfilled its obligations once you have finished the transfer and shall not be held liable for any other disputes.
F. Notifications. Safeheron may send notifications to you by web announcements, e-mails, Notification Centre information, popup tips or client-end notices (e.g., information about your transfer or suggestions on certain operations) which you shall be aware of timely.
4. Service Fees And Taxes
A. Safeheron Basic Plan is free but will be charged according to your usage. When you need to pay, you will be prompted and confirmed by you;
B. You need to pay gas when you transfer cryptocurrencies, the amount of which would be on your sole discretion and would be collected by certain blockchain system;
C. You understand that under some specific circumstances, your transfer of cryptocurrencies may fail due to unstable network, but you may still be charged gas by certain blockchain system;
D. You shall bear all the applicable taxes and other expenses that occurred due to your transactions on Safeheron.

VI. Risks

1. You understand and acknowledge that the blockchain technology is a field of innovation where the laws and regulations are not fully established. You may be faced with material risks including instability of technology or failure of Tokens redemption. You also understand that cryptocurrencies have much higher volatility compared to other financial assets. You shall make investment decisions and hold or dispose of the cryptocurrencies in a reasonable way and corresponding to your financial status and risk preferences. You also acknowledge that the market information is captured from exchanges by Safeheron and may not represent the latest or the best quotation of each cryptocurrency.
2. If you or your counterparty fails to comply with this Agreement or fails to follow the instructions, tips, or rules on the website or on the page of the transaction or payment, Safeheron does not guarantee the successful transfer of the cryptocurrencies and Safeheron shall not be held liable for any of the consequences of such failure. If you or your counterparty has already received the payment in Safeheron wallet or third-party wallet, you understand that transactions on blockchain are irreversible and irrevocable. You and your counterparty shall assume the liabilities and consequences of your transactions.
3. When you use third-party-developed DApps integrated into Safeheron, Safeheron strongly suggests you read this Agreement and Safeheron’s Alert carefully, get familiar with the counterparty and the product information and evaluate the risks before you make transactions on such DApps. You understand that such transactions and corresponding contractual relationships are between you and your counterparty. Safeheron shall not be held liable for any risks, responsibilities, losses or expenses that occurred due to such transactions.
4. It is your sole responsibility to make sure that your counterparty is a person with full capacity for civil acts and decide whether you shall transact with him/her.
5. You shall check the official blockchain system or other blockchain tools when you receive Alert such as “transaction failed” or “mining overtime” in order to avoid a repetitive transfer. If you fail to follow this instruction, you shall bear the losses and expenses that occurred due to such a repetitive transfer.
6. You understand that after you create or join a team on Safeheron, your Keystore, local Private Key Shard, and Recovery Phrase are only stored on your mobile device and will not be stored in Safeheron or on the servers of Safeheron. You may change another mobile device to use Safeheron after you follow the instructions to backup your wallet. If you lose your mobile device before you could write down or backup your Wallet Password, local Private Key Shard, Recovery Phrase, or Keystore, you may lose your cryptocurrencies and Safeheron is unable to restore them. If your Wallet Password, local Private Key Shard, Recovery Phrase, or Keystore is disclosed or the device which stores or holds your Wallet Password, local Private Key Shard, Recovery Phrase, or Keystore is hacked or attacked, you may lose your cryptocurrencies and Safeheron is unable to recover them. You shall bear the foregoing losses on your own.
7. We suggest you backup your Wallet Password, local Private Key Shard, Recovery Phrase, and other information when you create a team. Please do not use electronic methods such as screenshots, e-mails, or note-taking apps on mobiles, text messages, WeChat, or QQ to back up any of the above information.
8. In order to avoid potential security risks, we suggest you use Safeheron in a secured network environment. Please do not use a jailbreak or Rooted mobile device. Safeheron shall have no responsibilities for the losses due to the security problems of your own network environment.
9. Be alert to frauds when you use Safeheron. If you find any suspicious conduct, we encourage you to inform us immediately.

VII. Change, Suspension, Termination of Safeheron Service

1. You acknowledge and accept that Safeheron may, at its sole discretion, provide only a part of services for the time being, suspend certain services or provide new services in the future. When we change our services, your continued use of Safeheron is deemed as your acceptance of this Agreement and revisions of this Agreement.
2. You understand that Safeheron may suspend services under the following circumstances:
A. due to the maintenance, upgrading, failure of equipment and blockchain system and the interruption of communications, etc., which lead to the suspension of the operation of Safeheron;
B. due to force majeure events including but not limited to typhoons, earthquakes, tsunamis, floods, power outages, war, terrorist attacks, or computer viruses, Trojan Horse, hacker attacks, system instability or government behaviors, and other reasons, Safeheron is unable to provide services or in Safeheron’s reasonable opinion, continuous provision of services would result in significant risks;
C. due to other events which Safeheron cannot control or reasonably predicate.
3. Safeheron reserves the right to unilaterally suspend or terminate all or part of the function of Safeheron under the following circumstances:
A. Death of Users;
B. If you steal others’ wallets information or devices;
C. If you provide false Personal Information on Safeheron or cheat on the Questionnaire;
D. If you refuse to allow mandatory updates of Safeheron;
E. If you use Safeheron to commit illegal or criminal activities;
F. If you hinder the normal use of Safeheron by other Users;
G. If you pretend to be staff or management personnel of Safeheron;
H. If you threaten the normal operation of the Safeheron computer system by the attack, invasion, alternation, or any other means;
I. If you use Safeheron to send spam;
J. If you spread rumors which endanger the goodwill of Safeheron;
K. If there are illegal acts, other acts in violation of this agreement, and circumstances where the company reasonably believes that the functions shall be suspended.
4. You are entitled to export your wallets and other information within a reasonable amount of time if Safeheron changes, suspends, or terminates its services.

VIIl. Your Representations and Warranties

1. You shall comply with all applicable laws and regulations of the country or area you reside in. You shall not use Safeheron for any unlawful purposes or by any unlawful means.
2. You shall not use Safeheron to commit any illegal or unlawful activities, including but not limited to:
A. Activities opposing the basic principles set forth in the constitution, endangering national security, disclosing state secrets, overturning the government, or undermining national unity;
B. Any illegal conduct, such as money laundering, illegal fundraising, etc.;
C. Accessing Safeheron services, collecting or processing the content provided by Safeheron, intervening or attempting to intervene with any Users, by the employment of any automated programs, software, network engines, web crawlers, web analytics tools, data mining tools, or similar tools, etc.;
D. Providing gambling information or inducing others to engage in gambling;
E. Invading into others’ Safeheron wallets to steal cryptocurrencies;
F. Engaging in any inaccurate or false transactions with the counterparty;
G. Committing any activities which harm or attempt to harm Safeheron service system and data;
H. Other violations and acts that Safeheron reasonably deems to be inappropriate.
3. You understand and accept that you shall be responsible for any violation of law (including but not limited to the regulations of the Customs and Tax) or for breach of this Agreement by you and shall indemnify Safeheron against the losses, the third-party claims, or administrative penalties against Safeheron incurred by such violation or breach, including reasonable attorney’s fees.
4. You confirm that you will pay the service fees charged by Safeheron in time (if applicable). Safeheron reserves the right to suspend the services when the User fails to pay service fees.

IX. Privacy Policy

Your privacy is of utmost importance for Safeheron. Please refer to Safeheron Privacy Policy as updated by us from time to time for relevant privacy protection policies.

X. Disclaimer and Limitation of Liability

1. Safeheron only undertakes obligations expressly set forth in this Agreement.
2. YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, Safeheron IS PROVIDED ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS. Safeheron shall not be held liable for the malfunction of Safeheron which results from the following reasons:
A. System maintenance or upgrading of Safeheron;
B. Force majeure, such as typhoon, earthquake, flood, lightning or terrorist attack, etc.;
C. Malfunction of your device hardware and software and failure of telecommunication lines and power supply lines;
D. Your improper, unauthorized, or unrecognized use of Safeheron services;
E. Computer viruses, Trojan Horse, malicious program attacks, network congestion, system instability, system or equipment failure, telecommunication failure, power failure, banking issues, government acts, etc.;
F. any other reasons not imputed to Safeheron.
3. Safeheron shall not be held liable under the following circumstances:
A. Users lose their devices, delete Safeheron App or wallets without back-up, forget Wallet Passwords, local Private Key Shards, Recovery Phrases, Keystores without back-up, which results in the loss of their cryptocurrencies;
B. Users disclose their Wallet Passwords, local Private Key Shards, Recovery Phrases, Keystores, or lend or transfer their Safeheron wallets to others, or authorize others to use their devices or Safeheron wallets, or download Safeheron applications through unofficial channels, or use Safeheron applications by other insecure means, which result in the loss of their cryptocurrencies;
C. Users mishandle Safeheron (including but not limited to the wrong address, failure of the node servers selected by you), which results in the loss of cryptocurrencies;
D. Users are unfamiliar with the knowledge of blockchain and their mishandling of Safeheron results in the loss of their cryptocurrencies;
E. Safeheron is unable to copy accurate transaction records due to system delay or blockchain instability etc.;
F. The risks and consequences of users’ transactions on the third-party-developed DApps.
4. You understand that Safeheron is only a management tool for cryptocurrencies which is incapable to control the quality, security, and legitimacy of products and services provided by the third-party-developed DApps, or the authenticity and accuracy of their information and their capabilities to fulfill the obligations under the agreements with you. You, at your sole discretion, decide whether to transact on the third-party-developed DApps. It is the third-party-developed DApps, instead of Safeheron, that transact with you. We kindly remind you to carefully review the authenticity, legitimacy, and effectiveness of related information provided by the third-party-developed DApps before you decide to use the DApps. In addition, you shall also assume all the risks arising from the transactions between you and any third-party exchanges.
5. You acknowledge that Safeheron may provide services to you and your counterparties simultaneously and you agree to waive any actual or potential conflicts of interests and will not claim against Safeheron on such base or burden Safeheron with more responsibilities or duty of care.
6. Safeheron does not warrant that:
A. Services provided by Safeheron would satisfy all your needs;
B. All techniques, products, services, information or other materials from Safeheron would meet your expectations;
C. All the transaction information in digital tokens markets captured from the third party exchanges are prompt, accurate, complete, and reliable;
D. Your counterparties on Safeheron will perform their obligations in the transaction agreements with you timely.
7. You are aware that Safeheron is only a tool for Users to manage their cryptocurrencies and to display transaction information. Safeheron does not provide legal, tax or investment advice. You shall seek advice from professional legal, tax, and investment advisors. In addition, Safeheron shall not be liable for any investment loss, data loss, etc. during your use of our service.
8. You understand that we may change our entry standards, limit the range and ways to provide services for specific Users, etc. at any time in accordance with relevant laws and regulations.

XI. Breach of Contract

1. If Safeheron discovers or receives a report or complains from another person that the user has violated the terms of this Agreement, Safeheron reserves the right to delete and block the related content and depending on the circumstances of the act issues the punishment, including but not limited to warnings, restrictions or prohibitions on the use of some or all of the features, account bans until cancellations, and announcing the disposal results.
2. You understand and agree that you shall be solely liable for any claims, or losses claimed by third parties as a result of your breach of this Agreement or the relevant terms of service, and you shall be liable for any loss Safeheron suffered.

XII. Entire Agreement

1. This Agreement incorporates Safeheron User Agreement, Safeheron Privacy Policy, and other rules posted by Safeheron from time to time.
2. If any provision of this Agreement is found by a court with competent jurisdiction to be invalid, the other provisions of this Agreement remain in full force and effect.
3. This English version and other translated versions of this Agreement (if any) are provided for the convenience of Users, and are not intended to revise the Chinese version of this Agreement. If there is any discrepancy between the Chinese version and non-Chinese version of this Agreement, the Chinese version shall prevail.

XIll. Intellectual Property Rights Protection

Safeheron is an application developed and owned by Safeheron. The intellectual property rights of any contents displayed in Safeheron (including this Agreement, announcements, articles, videos, audios, images, archives, information, materials, trademarks or logos) are owned by Safeheron or the third-party licensors. Users can only use the Safeheron applications and its contents for the purpose of holding and managing their cryptocurrencies. In particular, without prior written consent from Safeheron or the third-party licensors, no one shall use, modify, decompile, reproduce, publicly disseminate, alter, distribute, issue, or publicly publish the abovementioned applications and contents.

XIV. Governing Law and Dispute Resolution

1. The validity, interpretation, alternation, enforcement, and dispute resolution of this Agreement and its revised versions shall be governed and construed in accordance with the Safeheron's national laws. Where there is no applicable law, this Agreement shall be interpreted by applicable commercial and/or industrial practices.
2. In case of any dispute arising from the interpretation and performance of this agreement, both parties shall negotiate in good faith to resolve the dispute. If the parties fail to reach an agreement on the settlement within thirty (30) days, either party may submit the dispute to the competent court where Safeheron is located for arbitration in accordance with its arbitration rules. The arbitration shall be conducted in [Singapore] and the language of the arbitration shall be Chinese. The arbitration award shall be final and binding on both parties.

XV. Your Personal Information Protection

“Your Personal Information” refers to the raw data generated when you or members authorized by you provide and use the service. When using Safeheron's services, you may choose to provide, upload, import, transmit, publish or agree to Safehreon's access to certain data managed by you.
You authorize Safeheron to use, process, display, duplicate and store the data to:
1.1. Provide you with services.
1.2. Manage and improve services.
1.3. Collect and analyze anonymous information.
​​You are entitled to back up your data, including key shards, extended public keys, transaction information, audit logs, and all other data that belongs to you, and you can implement backup plans and security strategies for your needs.
You are entitled to the ownership of your data and its rights and interests and other rights. You represent and warrant that you’ve owned or obtained all rights of your data and authorize Safeheron to access your data in accordance with the services of this Agreement. You represent and warrant that you have provided the necessary consents and licenses in the case of any personally identifiable information and personal data contained, and complied with applicable privacy laws and regulations (including but not limited to the EU General Data Protection Regulation "GDPR"), agreed Safeheron to receive, transmit and use your data only to perform the services of this Agreement. You are solely responsible for the reliability, integrity, accuracy and quality of your data. If you require a Data Processing Agreement ("DPA"), Safeheron will securely deliver the data to you.
This Agreement takes your access credentials (such as email address, password, 2-factor verification, API key), key shards, and this Agreement as confidential information, and Safeheron will protect the confidential information collected as required by industry standards. You agree and have the sole right to protect the confidential information and not to disclose it to any third party. You shall take the sole responsibility for the activities and risks arising from the confidential information under your control. Safeheron cannot and will not be liable for loss or damage arising from your failure to properly safeguard your confidential information.

XVI. Miscellaneous

1. If you live outside of Singapore, you shall fully understand and conform to the laws, regulations, and rules in your jurisdictions that are relevant to the use of Safeheron services.
2. During your use of Safeheron services, if you come across any problems, you can contact us through the submission of your feedback on Safeheron.
3. This Agreement is accessible to all Users on Safeheron. We encourage you to read this Agreement each time you log onto Safeheron.
4. This Agreement shall become effective on May 16, 2022. As for any issues not covered in this Agreement, you shall comply with the announcements and relevant rules as updated by Safeheron from time to time.
Safeheron PTE. LTD.
© 2022 Safeheron PTE. LTD. All rights reserved.

Safeheron Privacy Policy

LAST UPDATED: Nov 16, 2022
Changelog
Version
Updated Terms
Update Date
Effective Date
V1.0.0
Published Safeheron Privacy Policy
2022-05-16
2022-05-16
V1.0.1
Terms Updated:
II. Use of Personal Information Collected
  1. 1.
    Information retention added
  2. 2.
    Details of information collected updated
VII. How We Use Cookies
  1. 1.
    Cookie categories and periods added
Term Added:
IX. Cross-Border Data Transmission
2022-11-16
2022-11-16

Introduction

Thank you for using our application and/or visiting our website. We take our data protection responsibilities very seriously and have designed our website in a way that users can browse without having to provide any personal data.
The Privacy Policy (this "Privacy Policy") describes how SAFEHERON PTE.LTD. and how our affiliates ("Safeheron" or “We”) will collect, use, maintain, share and store information collected in connection with the use of our website https://www.safeheron.com/, any other related domain or subdomain thereof ("Site"), the use of our platform's mobile wallet application and any other software applications we license ("Platform"). This is in connection with our role as controller of your personal information (In applicable of data protection laws), and in instances where data is collected and processed. Additional details are provided in this Privacy Policy.
For the purposes of this Privacy Policy, "personal information" refers to information relating to an identified or identifiable individual. For the purposes of this Privacy Policy, personal information does not include de-identified or aggregated information and, to the extent permitted by law, does not include information that is lawfully available to the public or lawfully available in government records.
Our services are not available to users in mainland China.

I. Information Collected

In the course of using Safeheron services, we may collect information that is voluntarily provided while using our services or as a result of using our services in the following manner:
1.1. Institutional Data: Employer identification number (or other similar government-issued number) and/or personal identification information for all significant beneficial owners and/or a list of current directors of the institution, size of the institution's personnel, and type of business conducted.
1.2. Contact Information: Telephone number and/or e-mail.
1.3. Geographic Location Data: IP address, country code, postal code, working address of the institutional customer.
1.4. Account Information: Account name, customer ID, password and/or user name.
1.5. Transaction Data: Information about transactions made on our Platform, such as details of trade orders, amounts and/or timestamps of virtual assets held in your account.
1.6. Usage Data: Authentication data, clickstream data, cookies, pixel tags and other similar tools that uniquely identify your browser, as well as your consent to collect any of the data mentioned thereof.
1.7. Technical Information: Device type, classification and model number, unique device identification number (e.g. OAID, AndroidID, IDFV, IDFA, GAID, IMEI), source of submission (Web or App), telecommunication carrier information, browser type and version, browser plug-in type and version, application version and SDK version, operating system and platform, language settings, privacy preferences, time zone settings, diagnostic data, such as crash logs and any other data we collect to obtain your consent when required and other information stored or available to measure technical diagnostics on the devices that allow us access when you visit the Site or use service/application, the full URL clickstream to, through and from the service, cookie identifiers and your activity.
1.8. Marketing and Communications Data: Marketing communications preferences, survey responses, information provided to our support, business, sales team and/or user research team.
1.9. Risk Management Data: Personal credit information, including payment history, credit information and debt information, etc. legal data, litigation-related, case-involved information, compliance assessment, risk assessment, risk level, KYC certification results and reasons for KYC failure.
1.10. Financial Data: Bank account information (e.g. account number, sort code), remittance account, bank account type (SWIFT/ABA), SWIFT code, ABA number, legal tender deposit certificate information, currency, deposit amount, withdrawal amount, payment card master account number (PAN), cryptocurrency deposit address.

II. Use of Personal Information Collected

Information collected may be used for the following purposes:
Purpose of Collection
Categories of Personal Information
Information Retention
Registering a new client
  • Account Information
  • Contact Information
  • Financial Data
Duration of relationship + 5 years after cancellation
Implementation and compliance with anti-money laundering requirements
  • Account Information
  • Contact Information
  • Financial Data
  • Institutional Data
Duration of relationship + 5 years after cancellation
Processing and providing our services and any application functionality to you, including the execution, management and processing of any instructions or orders placed by you
  • Contact Information
  • Financial Data
  • Transaction Data
  • Marketing and Communication Data
10 years
Ensuring proper management of our payments, fees and charges, as well as the recovery and collection of monies due to us
  • Account Information
  • Contact Information
  • Financial Data
10 years
Managing risk and preventing crime, including conducting anti-money laundering, counter-terrorism, sanctions screening, fraud and other background checks, detecting, investigating, reporting and preventing financial crimes broadly defined, complying with laws and regulations that apply to us and responding to and resolving complaints
  • Contact Information
  • Account Information
  • Financial Data
  • Technical Information
  • Transaction Data
  • Data that may be disclosed through KYC or other background checks (Ex: Reported in media or available publicly)
Duration of relationship + 6 years after cancellation
To enable users to properly engage and use our services, and in the event of unusual usage scenarios, use this data to locate and resolve any issues. We can also recommend more suitable products/services based on the needs of your organization
  • Contact Information
  • Account Information
  • Technical Information
  • Usage Data
  • Marketing and Communication Data
Duration of relationship + 6 years after cancellation
Collecting marketing data to study customer behavior, including their preferences, interests and how they use our products/services to determine our marketing campaigns and grow our clientbase
  • Account Information
  • Contact information
  • Technical Information
  • Usage data
  • Marketing and Communication Data
Duration of relationship + 5 years after cancellation
Managing and protecting our services and social media channels, including bans, troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting
We collect your personal information to improve security, monitor and verify identity/service access, combat spam/ malware/security risks, and to comply with applicable security laws and regulations. The threat landscape online is constantly evolving, making it essential that we have accurate and updated information regarding your use of our services. Without processing your personal information, we may not be able to ensure the security of our services
  • Account Information
  • Contact Information
  • Financial Data
  • Technical Information
  • Usage Data
  • Transaction Data
Duration of relationship + 5 years after cancellation
To provide you with relevant services and advertisements and to measure or understand the effectiveness of the advertisements provided to you
  • Account Information
  • Contact information
  • Technical Information
  • Marketing and Communication Data
Duration of relationship + 5 years after cancellation
Using data analytics to improve our services, marketing, customer relationships and experience
  • Technical Information
  • Usage Data
Duration of relationship + 5 years after cancellation
Use of services on social media platforms or advertising platforms, some of which may involve using the data received for their own purposes, including marketing
  • Technical Information
  • Usage Data
Duration of relationship + 5 years after cancellation
Use of services on financial institutions, crime and fraud prevention companies, and risk measurement companies to proactively prevent crime and fraud
  • Account Information
  • Contact information
  • Risk Management Data
  • Financial Data
  • Transaction Data
  • Technical Information
  • Usage Data
Duration of relationship + 5 years after cancellation
Recording voice calls and communications for compliance, customer relationship maintenance, quality assurance and training purposes
  • Account Information
  • Contact information
  • Financial Data
  • Transaction Data
Duration of relationship + 5 years after cancellation
Diagnosing and resolving faults as soon as possible in the event of any malfunction affecting your use of the service (e.g. program crashes, functional abnormalities, display abnormalities) in order to enhance your user experience
  • Technical data (including diagnostic data)
Duration of relationship + more than 5 years after cancellation

III. Sharing and Transfer of Personal Data

3.1. Sharing

We will not share your user information with other organizations and individuals, except for the following:
3.1.1. Sharing with explicit consent: We may share your information with other parties after your explicit consent.
3.1.2. Sharing under legal circumstances: We may share your information with the public in accordance with the provisions of laws and regulations, the need for litigation or arbitration settlement, or as requested by administrative or judicial authorities in accordance with the law.

3.2. Transfer

We will not transfer your information to any company, organization or individual, except for the following:
3.2.1. Transferring with express consent: We may transfer your information to other parties after obtaining your express consent.
3.2.2. In the event of a merger, acquisition or liquidation of Safeheron with another legal entity, or other merger, acquisition or liquidation involving the transfer of user information, we will require the new company or organization holding your data to continue to be bound by this Policy, or we will require that company, organization or individual to seek your authorized consent again.
Your prior authorized consent is not required to share or transfer your user information in the following cases:
3.3.1. Related to national security and national defense security.
3.3.2. Related to public safety, public health, and significant public interest.
3.4.3. Related to crime investigation, prosecution, trial and sentence enforcement, etc.
3.4.4. For the purpose of safeguarding yours or another individual's significant legal rights and interests, such as life or property, including circumstances where it is difficult to obtain your consent.
3.4.5. Personal information that you disclose to the public on your own.

IV. Protecting Your Personal Information

We strive to safeguard the security of our users' information against loss, misuse, alteration, and unauthorized access or disclosure.
4.1. We will use a variety of security protections to safeguard information within a reasonable level of security. For example, we will use encryption technology (e.g., SSL), MPC, de-identification, anonymization processing, etc. to protect your personal information.
4.2. We’ve established special management systems, operating procedures and organizations to safeguard information. For example, we strictly limit the scope of people who can access your information, as we require them to comply with confidentiality obligations and conduct routine audits.
4.3. In the unlikely event of a personal information leak, we will promptly notify you by email, push notification, and other forms of communication in a timely manner, and we will bear the corresponding legal responsibility. At the same time, we will also take the initiative to report the disposition of the incident in accordance with the requirements of the regulatory authorities.
4.4. We have met the requirements of ISO27001 certification standard in terms of information security and have obtained the corresponding certification.
4.5. We will take all reasonable steps to ensure that no unrelated personal information is collected. We will only retain your personal information for as long as is necessary to achieve the purposes described in this policy, unless an extended retention period is required or permitted by law.

V. Your Rights

You are entitled to certain rights in relation to your personal information.
5.1. You’re allowed two requests per calendar year for the following:
a) Specific personal information we collect about you
b) Categories of personal information we collect about you
c) Categories of sources from which we collect your personal information
d) Business purposes for which we collect your personal information
5.2. If you believe that the personal information we have collected is inaccurate, you can request a correction on the personal information collected.
5.3. To receive the personal information you provide to us in a structured, common and machine-readable format and transfer it to other data controllers (data migration).
5.4. To restrict or object to the processing of your personal information for compelling and legitimate reasons related to your particular situation, unless such processing is expressly provided for by law.
5.5. To file a complaint with the regulatory authority where you live or where the issue of the subject of the complaint arose. We will not discriminate against you for exercising any of these rights. If you wish to make a request for additional information, please contact us using the information provided in the "Contact Us" section below.
5.6. You may make a request to us to delete personal information in the following cases:
1) If our handling of personal information violates laws and regulations.
2) If we collect and use your personal information without your consent.
3) If our processing of personal information is in breach of our agreement with you.
4) If you no longer use our products or services, or if you wish to terminate your account.
5) If we no longer provide products or services to you.
5.7. For security purposes, you may need to provide a written request or otherwise to prove your identity. We may ask you to verify your identity before we process your request. We will respond within thirty days, and if you are not satisfied, you may also reach out by submitting an email to [email protected] to make a complaint. In principle, we do not charge a fee for reasonable requests, but we may charge a fee for repeated requests that exceed reasonable limits, as we deem appropriate. We may deny requests that are unwarrantedly repetitive, require excessive technical configuration (Ex: Requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (Ex: Involving the backup of information to be stored on tapes).
5.8. We will not be able to respond to your request in the following cases:
1) Obligations of a controller of personal information under laws and regulations.
2) Directly related to national security and/or national defense security.
3) Directly related to public safety, public health, and significant public interest.
4) Directly related to criminal investigation, prosecution, trial and enforcement of sentences.
5) Where the controller of personal information has sufficient evidence of subjective malice or abuse of rights by the subject of personal information.
6) For the purpose of safeguarding the life, property, and other significant legitimate rights and interests of the subject of personal information or other individuals, but where it is difficult to obtain the consent of the individual.
7) When responding to the request of the subject’s personal information will result in serious damage to the legitimate rights and interests of the subject’s personal information or other individuals or organizations; involving commercial interest.

VI. Collection of Information on Minors

6.1. Our products, websites, and services are primarily intended for adults. Minors should not create their own personal information accounts without the consent of their parents or legal guardians.
6.2. In the case of personal information collected from minors with parental consent, we will only use or publicly disclose this information as permitted by law, with the express consent of the parent or legal guardian, or as necessary to protect the minor.
6.3. Although local laws and customs define minors differently, we consider any person under the age of 14 to be a minor.
6.4. If we find that we have collected personal information from a minor without prior verifiable parental consent, we will seek to delete the relevant data as soon as possible.

VII. How We Use Cookies

We collect certain information through tracking technologies used on the Site, such as cookies (data files placed on devices used to access the Site), mobile analytics software, and pixel tags (transparent graphic images, sometimes called web beacons or tracking beacons, placed on web pages or emails that indicate that a page or email has been viewed and may tell your browser to fetch content). We do this to analyze trends, track users' movement around the Site, gather demographic information, and generally collect information that we believe to be insightful or useful. For security purposes, we or our third-party service providers may place cookies or similar files on your device to facilitate site navigation. We may use social media platform cookies to improve our user experience.
Most browsers allow you to control cookies, including whether to accept them and how to delete them. You can set most browsers to notify you when you receive a cookie, or you can choose to block cookies using your browser; however, please note that some features of the Site may not function properly or may be slowed down if you reject cookies. If you block or delete a cookie, not all of the tracking we described in this Privacy Policy will stop.
We use cookies provided by Google Analytics to collect statistical information about the use of the Site. We use Google Analytics to learn more about the types of users who visit the Site, their activities on the Site, and to help improve the Site. In order to provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to: information about your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you access the Site, and other information about you. You can visit www.google.com/policies/privacy/partners/ to learn more about Google Analytics and how it collects and processes data, including how it controls the information sent to Google. You can opt out of Google Analytics here tools.google.com/dlpage/gaoptout (this requires you to install a browser plug-in).
Some web browsers may provide an option whereby you can request that your browser notify the website you are visiting that you do not want your activity to be tracked by a cookie or other persistent identifier (often referred to as a ‘do not track’). The Site does not currently respond to ‘Do Not Track’ signals.
Different types of cookies can be used for specific purposes, e.g.
Cookie Category
Period
Absolutely Necessary Cookies
These cookies are necessary for the service to function and cannot be turned off on our system. They are typically set only for actions you take deemed as service requests, such as setting your privacy preferences, logging in, or filling out a form. You can set your browser to block or alert you to these cookies, but some parts of the Site will not work properly. These cookies do not store any personally identifiable information.
Up to 365 days
Performance Cookies
These cookies allow us to calculate the number of visits and sources of traffic so that we can measure and improve the performance of our Site. They help us to understand which pages are most and least popular and to see how visitors move around the Site. All information collected by these cookies are aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Site and will not be able to monitor its performance.
Up to 2 years
Functional Cookies
These cookies enable our services to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function properly.
Up to 365 days
Location Cookies
These cookies may be set by our advertising partners through our website. These companies may use them to build a profile of your interests and to show you relevant advertisements on other websites. They do not store personal information directly, but are based on uniquely identifying your browser and Internet device. If you do not allow these cookies, you will experience less targeted advertising.
Up to 365 days
Social Media Cookies
These cookies are set up by a series of social media services that we add to our website to enable you to share our content with your friends and network. They enable them to track your browser on other sites and build a profile of your interests. This may affect the content and messages you see on the other sites you visit. If you do not allow these cookies, you may not be able to use or view these sharing tools.
Up to 365 days

VIII. How Long We Retain Your Personal Data

We will retain your personal information for as long as required or permitted by law or in accordance with the retention policies that we may establish from time to time. We consider the following factors for determining the duration of such retention; the time required to retain personal information for business purposes; the maintenance of corresponding business records; improving the performance and quality of the Site and Platform; the processing of your inquiries; whether we reasonably believe that the data is needed to process any litigation; and whether legal and contractual obligations impose any requirements for data retention.
Please refer to the ‘Use of Personal Information Collected’ section above for the relevant retention periods for each Purpose of Collection.

IX. Cross-Border Data Transmission

Given that we are an international company, our use of your personal information necessarily involves cross-border data transfers. Safeheron processes and stores data on servers in Hong Kong, China. When we transfer data across borders, we do so in accordance with applicable data protection laws. For example, we may use standard contractual clauses when we transfer data from the European Economic Area to jurisdictions that are not considered to have an adequate level of data protection. In the absence of an adequate decision or standard contractual terms or any other right to transfer your data, we may rely on your consent as the basis for such transfers.

X. Cancellation of E-mail Services

You can unsubscribe from receiving marketing and promotional messages from us at any time by:
10.1. Selecting the unsubscribe link in the message we send you, or
10.2. Using the information provided in the ‘Contact Us’ section below to contact us. Please note that even if you choose not to receive the above emails, we will still send you a reply when you contact us for other reasons related to your use of our Site or Platform.

XI. Update of Privacy Policy

Rights will not be reduced under the personal information protection policy without your express consent. We will post any changes made to this policy on our website or app. When changes are made to the Privacy Policy, we will promptly notify you of the changes to the Privacy Policy by email, push notification, and change the ‘last updated’ date on our blog. If you do not agree with the revised policy, we advise you to stop using our Platform and services. We will also keep an older version of this policy on file for you to review.

XII. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at [email protected]. Generally, we will respond within thirty days. If you are not satisfied with our response, especially if you believe our personal information processing practices have infringed on your legal rights, you may also seek a resolution through government, courts, or other relevant agencies.