Metalpha is a platform operated by Metalpha Technologies Limited and its affiliates (“Metalpha”, "we" or "us") providing services for registered users ("you") to invest in digital assets (the "Service"). By continuing to access or use the Service provided by us, you confirm that you have carefully read and fully understood and consent to the policies and practices of our privacy policy (the “Privacy Policy”). This Privacy Policy explains our policies and practices regarding the collection, use, and disclosure of data when you accessing and/or using our Service, the choices you have associated with that data, and how you can contact us about our privacy practices. We may update this Privacy Policy at any time by posting the amended version (including the effective date of the amended version) on our website and associated application program interface or mobile.
Special Notice
This Privacy Policy applies to all products and services we provide. However, depending on what products and services you use, we may provide you with an additional privacy notice detailing the collection, use, and disclosure and share of your data for that product or service (each “Privacy Notice”). In the event of any conflict between this Privacy Policy and any Privacy Notice, the Privacy Notice shall prevail.
In particular, this Privacy Policy does not apply to third-party websites, products, or services, even if we provide links to them or they link to us, which shall be subject to the Privacy policy otherwise explained to you by such third-party providers.
If you have any question, comment or suggestion to this Policy, you may contact us through the various contact forms provided by us officially. If you do not agree to any of the terms of this Privacy Policy, you should immediately stop accessing the platform.
This Privacy Policy section will help you understand the following:
- What Personal Information we collect
- How we use your information
- How we share your information
- Cookies
- Marketing and promotional information
- How we protect your information
- How you may manage your information
- How we handle information about minors
- Updates to this Privacy Policy
- How to contact us
- WHAT PERSONAL INFORMATION WE COLLECT
- We collect, process and store certain information that identifies or is reasonably capable of identifying you, directly or indirectly, and information that relates to, describes, is reasonably capable of being associated with or could reasonably be linked to you (“Personal Information”). For the purposes of this Privacy Policy, only the definition of personal information from the applicable law of your legal residence will apply to you and be deemed your “Personal Information”.
- Personal Information we may collect during your use of our products and/or services include but without limitation:
- Name
- Gender
- Date and place of birth
- Nationality and government ID type and number
- Identification document type (e.g. Passport)
- Identification document number (e.g. Passport No.)
- Residential and correspondence address
- Transaction and order activities
- Financial and bank account information
- Employment information;
- Contact phone number and email address
- IP address and blockchain address
- Device information such as type, model and version which you used to login
- Network environment, device biometric information
- Brower and software information
- Location information
- You understand that we will only be able to provide you with the basic function of our products and/or services if we are authorized by you to collect and use the necessary Personal Information. If you refuse to provide such necessary Personal Information, we will not be able to provide any product and/or service to you.
- In order to provide you with additional functions of our products and/or services, you may opt-in authorizing us to collect and use the additional Personal Information. If you refuse to provide such additional Personal Information, we will not be able to provide the relevant additional functions to you, but this will not affect your access to the basic functions of our products and/or services.
- You understand and agree that you shall only provide us with your own Personal Information, and that if the information you provide contains any Personal Information of other users, you have obtained legal authorization before providing such personal information to the platform.
- HOW WE USE YOUR INFORMATION
- You understand and agree that we may use your Personal Information for the following purposes:
- to enable you to use our products and/or services and to optimize and improve our products and/or services to bring you better experiences.
- to ensure security and safety of the services we provide.
- to keep transaction record on the platform.
- to provide customer services and handling complaint or disputes. Please note that, to facilitate the contact and help you solve problems or record solution plans or result related to related problems promptly, we may save the communication records and other relevant content between you and us (including account information, order information, other information which you provide in order to prove the facts, or the contact information you left). We will use your account information and order information if you consult, complain, or provide suggestions for any specific order.
- to discharge our legal and/or regulatory obligations.
- to market or promote our products and/or services to you.
- other necessary uses that would be reasonably expected for the operation of our business to the extent permitted by applicable laws and regulations.
- other additional uses with your prior consent.
- Please be informed that, according to the applicable laws, if we take technical measures or other necessary measures for processing personal information, that could make the information receiver unable to identify any specific person and cannot retrieve it again, or we may conduct research, statistical analysis or to the collected information in a de-identified manner, to improve the content and layout of this platform, to provide product or service support to business decisions, and to improve our products and services (including the using anonymous information for machine learning or algorithm model training), such processed information can be used without prior notice to you or obtaining your consent.
- If we stop operating products or services of the platform, we will stop the activity to collect your Personal Information in time, inform you with the notification of cessation of operations with individual delivery or by public notice and remove or anonymize personal information related to ceased business held by us.
- HOW WE SHARE YOUR PERSONAL INFORMATION
We will not share with any third-party companies, organizations, or individuals your Personal Information, except in the following circumstances:
- share in accordance with laws: we may share your Personal Information in accordance with the laws and regulations, to protect or defect us during litigation and dispute resolution, or, according to the requirement of the administrative and judicial institutions.
- share when obtaining explicit permission: we may share your Personal Information with others after attaining your explicit consent.
- share in case you choose to share in your own discretion: we will, at your discretion, share the necessary information in your order relating to the digital asset transaction to the counterparty to enable your trading and after-sales service needs.
- share with our affiliates and professional advisors: we may share your Personal Information with our affiliates and professional advisors to the extent necessary for the operation of our business.
- share with a cooperative partner: we may share your Personal Information with our trusted service providers that help us operate our platform, conduct business, or provide you with services, as long as (i) the parties agreed to keep such information confidential; (ii) we believe that the information disclosed is appropriate, is necessary for compliance with laws, regulations, rules or orders from courts or other competent authorities, to implement our platform strategy, to properly operate the platform, to provide services to affiliates, or to protect the rights, property or safety or the rights of others or us.
- under the circumstance where any merger, acquisition, or bankruptcy liquidation happens to the platform or other situations involving merger, acquisition, or bankruptcy liquidation that involves personal information transfer: we will request the new company, organization or individual which holds your Personal Information continue to be bound by this Policy, otherwise we will ask the company, organization or individual to ask for a new authorization from you.
- in the event of any reasonable suspicion of a criminal conduct, violation of laws and regulations, or a severe breach of the agreements and rules of this platform.
Please note that we may take technical measures or other necessary measures that could make the Personal Information receiver unable to identify a specific person and cannot retrieve it again, in which case the sharing of your Personal Information after such procession does not require prior notice to or consent from you.
- COOKIES
When you access our platform, we may place certain data saved on your devices accessing our products and/or services (i.e. Cookies) in accordance with the market practice, which will be used to recognize you as a customer, collect usage information to optimize our customized services and improve your user experience. Such information may also be used to ensure compliance and account security as well as evaluation and improvement of our services and marketing activities.
You may reject the use of cookies but this will affect your use of certain or all of the functions on our platform.
- MARKETING AND PROMOTIONAL INFORMATION
We may send you marketing and promotional information relating to our products and/or services. You may choose not to receive such marketing and promotional information by giving us explicit instruction via our official channel. Please note that you will continue to receive important notices and updates in connection with our products and/or services after you cease to receive our marketing and promotional information.
- HOW WE PROTECT YOUR INFORMATION
- We take reasonable measures to protect and ensure the security of your Personal Information from unauthorized access, alteration, disclosure and destruction. Our security measures include, but are not limited to, physical, electronic, administrative, technical measures, such as encrypted transmission and storage using Secure Socket Layer Encryption (SSL), restricted access on a need-to-know basis and de-identification of sensitive information, and regular review of our information collection, storage and processing procedures, etc.
- Despite of the security measures we have implemented and our commitment to safeguard your Personal Information in line with the market standard, we cannot guarantee the absolute security of the transmission of information via the Internet or the electronic storage of information. We will update and publicize security risk, personal information security impact assessment reports and other relevant contents from time to time, which can be obtained through posts on this platform.
- If you are aware of any security vulnerabilities on our platform, we welcome any suggestion or report on any security vulnerability that you become aware of or would like to recommend to us.
- HOW YOU MAY MANAGE YOUR INFORMATION
In the applicable circumstances, you may be entitled to one or more of the following rights to request for access or manage your Personal Information that we have by contacting us through the method set out in this Privacy Policy:
- To access, correct and/or delete your Personal Information
You may request for a copy of your Personal Information we have. You may request to update your Personal Information if any of such Personal Information is inaccurate or not up-to-date. You may also request to delete your Personal Information, provided that we may retain certain Personal Information to the extent permitted by the applicable laws and regulations to discharge our legal or regulatory obligations.
- To change the scope of authorization
You may contact us to grant or withdraw your authorization as to certain Personal Information. Please note that any change of the scope of authorization may affect your future access to our products and/or services. However, any change of the scope of authorization does not affect the historical processing of Personal Information that have been previously carried out based on your previous authorization.
- To close your account
You may apply for the cancellation of your account. After the effective cancellation of your account, we will delete or anonymize your Personal Information in accordance with applicable law, provided that we may retain certain Personal Information to the extent permitted by the applicable laws and regulations to discharge our legal or regulatory obligations. Upon cancellation of your account, you will no longer be able to use any of our products and/or services.
- Our response to your requests
We are committed to responding to your requests within 15 days. For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. Please note that your requests might be rejected on the grounds permitted by applicable laws and regulations.
- HOW WE HANDLE INFORMATION ABOUT MINORS
The platform is not open to minors under the age of 18. If we become aware of or have a reasonable belief that any user is under the age of 18, we will not suspend the user’s account and discontinue his/her use of the products or services of the platform, and will delete such user’s Personal Information as soon as possible.
- UPDATES TO THIS PRIVACY POLICY
We may update our Privacy Policy from time to time, which will be posted by us from time to time on this platform and/or through our official channels. If you do not agree to the revised content, you shall stop accessing the platform immediately. When an updated version of this Privacy Policy is published, your continued access to the platform shall be deemed as an explicit indication that you agree to the updated content and you agree to abide by the updated Privacy Policy.
- HOW TO CONTACT US
- If you have any questions or concern regarding this Privacy Policy or our processing of your Personal Information, please email us at: support@metalpha.finance. This is our only valid and official channel to receive your feedback., Any communication made other than through this email might not be received by us timely or at all, and you shall be responsible for any loss, omission or delay caused thereby.
- We will only communicate or announce notices to you through the official channel of the platform or by posting notice on this platform. We will not be responsible for your loss in relation to your reliance on or trust in any information received other than through the official channels as set out above.