1. Policy Statement
Second Dimension Global Platform (hereinafter referred to as "Platform" or "we") allows its users (hereinafter referred to as "Users" or "you") to trade in digital assets (hereinafter referred to as "Digital Assets") and provide other digital asset related services (hereinafter referred to as "Services"). This Privacy Policy (hereinafter referred to as "Policy") explains how we collect, use, process, disclose, share, transfer and protect the personal information of users obtained through accessing and using the Platform (hereinafter referred to as "Personal Information") . For the convenience of expression, we and you are collectively referred to as "Parties" and individually as "Party".
We fully understand and respect the importance of your personal information to you. We will take appropriate security measures to protect your personal information in accordance with the requirements of applicable laws and regulations. In view of this, the purpose of formulating this Policy is to inform you of your rights regarding the processing of your personal information. We will not use your personal information for any purpose not covered by this Policy without prior notice to you and/or without your prior consent.
This Policy applies to all Services on the Platform. Before using the Platform, you should read this Policy carefully and seek independent legal advice if necessary. If you do not agree or understand this Policy, please do not use or access the Services. By using the Services, you shall be deemed to have fully agreed to this Policy and have acknowledged, understood and agreed to be fully bound by this Policy, including any modifications made to this Policy from time to time.
2. Definitions
“Confidential Information” means Identification Information, Third Party Information and Usage Information.
“Enterprise Identification Information” has the meaning given in Section 3.2.
“Digital Assets” has the meaning given in Section 1.
“Identification Information” has the meaning given in Section 3.2.
“Party” has the meaning given in Section 1.
“Personal Identification Information” has the meaning given in Section 3.1.
“Personal Information” has the meaning given in Section 3.1.
“Platform” has the meaning given in Section 1.
“Policy” means the Second Dimension Platform Privacy Policy.
“Service” has the meaning given in Section 1.
“Third Party Information” has the meaning given in Section 3.4.
“Usage Information” has the meaning given in Section 3.3.
“User” has the meaning given in Section 1.
3. How We Collect and Use Your Information
3.1 Personal Identification Information
When you create an account on the Platform, we collect certain personal information from you. If you are an individual user, we will collect the following information from you, including but not limited to your:
(i) full name;
(ii) address (and permanent residence, if different). Your address (or permanent residence) will be verified in the manner specified by us;
(iii) proof of address documents, including bank, brokerage and/or credit card statements, utility bills, mortgage statements and/or property tax statements;
(iv) valid email address;
(v) date of birth;
(vi) nationality;
(vii) identification information, such as your driver's license number, social security or ID number, passport number or other government-issued identification document;
(viii) photos of you and your ID document;
(ix) copies of your official identification documents, including passport, ID card (front and back) and/or other identification documents issued by relevant authorities;
(x) other information we may request or obtain from you from time to time.
If you use Google to authorize login, we will store your Google OpenID and email address, and use this information to create an account, and will not share your Google information with other platforms.
The above is "Personal Identification Information".
3.2 If you are a legal entity rather than an individual, we will collect the following information from you, including but not limited to:
(i) registration and incorporation documents;
(ii) articles of association or memorandum;
(iii) shareholding structure and description thereof;
(iv) board resolution designating the authorized representative in charge of the account;
(v) identification documents of directors, major shareholders and authorized representatives, including the identification information in clauses 3.1(i) to (x) above. Generally, it is required to identify shareholders holding 10% or more of the voting rights of the relevant entity;
(vi) registered office address; and
(vii) other information we may request or obtain from you from time to time.
The above is the "Business Identification Information" and together with the "Personal Identification Information", it is referred to as the "Identification Information". You are obliged to update the Identification Information. We use Identification Information for the following purposes:
(a) to help you register an account on the Platform;
(b) to enable you to access and use the Services;
(c) to facilitate our communication with you;
(d) to ensure the security and safety of the Platform, including protecting the integrity of the Platform;
(e) to assist us in any legal proceedings;
(f) to enable us to comply with the legal and regulatory framework and combat money laundering and/or terrorist financing offences;
(g) to send marketing communications;
(h) for internal business and record keeping purposes; and/or
(i) such other purposes as we may deem necessary from time to time. 3.3 Usage Information
When you access and/or use the Services on the Platform, we may collect certain information related to your use of the Services, including but not limited to your:
(i) transaction information, including account balances, transaction activity, deposits, withdrawals and customer service communications;
(ii) bank account and debit/credit card information;
(iii) browser information, such as your IP address, domain name, login information, browser type and version, time zone setting, browser plug-in type and version, operating system and platform;
(iv) log information, such as your device information, device manufacturer, system version, IMEI serial number, device fingerprint information, location, system activity, number and duration of visits and page interactions;
(v) your communications with us;
(vi) any surveys you complete; and
(vii) other information we may collect from you from time to time.
The above is collectively referred to as "Usage Information". We may use Usage Information for the following purposes:
(a) ensuring the security of your account and its digital assets;
(b) providing you with a more convenient and personalized experience in using the Services;
(c) assisting in any investigation or resolving any potential disputes;
(d) improving the quality of the Services;
(e) managing the operation of the Platform;
(f) for data analysis of Platform usage; and/or
(g) other purposes that we may deem necessary from time to time.
3.4 Third-party information
We may collect information from third parties related to you, which may include, but is not limited to, the following information:
(i) your bank when transferring money to use the Services;
(ii) advertising, search and analysis providers;
(iii) public databases, credit bureaus and identity verification partners;
(iv) institutions that may conduct investigations related to your use of the Services; and
(v) other information that we may collect from you from time to time.
The above are collectively referred to as "Third-party Information". Before obtaining third-party information, we will require the third party to obtain your consent before collecting such third-party information. We may use third-party information for the following purposes:
(a) to assist with internal and/or external investigations;
(b) to comply with our legal or regulatory obligations;
(c) personal data processing activities such as identity verification, payment processing, compliance with court orders, other reporting obligations and anti-money laundering or counter-terrorism financing policies; and
(d) other purposes we may deem necessary from time to time.
Before obtaining third-party information, we require third parties to obtain your prior consent in accordance with any applicable laws, rules and regulations before collecting third-party information. We will protect third-party information with the same level of protection as personal information.
4. How We Use Cookies
When you use the Services, we may use data files called cookies (hereinafter referred to as "Cookies") stored on your device. We use Cookies to identify you as a platform user, collect information about your use of the Services to provide you with customized services, and collect information about your device.
5. How we share, transfer or disclose your information
We shall not disclose any Confidential Information to any third party except:
(i) to the extent required by applicable laws, rules and regulations;
(ii) to comply with requests from relevant authorities;
(ii) where there is a legal obligation to disclose such information;
(iii) where disclosure of such information is in our legitimate business interests;
(iv) where disclosure of such information is in accordance with the Second Dimension Global Platform User Agreement and/or this Policy;
(v) where the Confidential Information has become public;
(vi) where disclosure of such information is necessary for the operation of the Platform;
(vii) where disclosure is necessary to protect the interests of the Platform and/or other users; and/or
(viii) at your request or with your consent.
We will endeavor to make such disclosures on a “need to know” basis and may disclose Confidential Information to the following parties (hereinafter referred to as “Recipients”):
(a) any affiliates and subsidiaries;
(b) our service providers and business partners; and/or
(c) relevant authorities to assist them in their investigations.
If Confidential Information is disclosed pursuant to Section 5, the Receiving Party may store the Confidential Information on its own systems to comply with its legal or other obligations.
6. How We Protect Your Information
We will take various measures to protect Confidential Information (hereinafter referred to as "Protection Measures"). These measures include:
(i) physical measures, such as ensuring that Confidential Information is stored in secure facilities;
(ii) electronic measures, such as strict access requirements for accessing Confidential Information;
(iii) management measures, such as establishing an internal department to protect confidentiality systems, implementing internal controls to ensure that only relevant employees are allowed to access Confidential Information, and conducting training to ensure that relevant employees know how to handle Confidential Information;
(iv) security measures, such as using security technologies and management systems to minimize the risk of disclosure, damage, misuse and/or access to Confidential Information without proper authorization. When storing and transmitting personal information, we should take measures such as encryption to protect personal information; and
(v) other measures, such as regularly reviewing the procedures and technologies used to protect confidential information.
6.1 If you discover any potential security breaches, please contact us so that we can take appropriate measures as soon as possible. Despite the protection measures taken, we cannot guarantee the absolute security of Confidential Information. When you sign up for our services, please choose a complex password and turn on advanced security features such as two-factor authentication. Never share your account authentication information with third parties. We will anonymize and remove identifiers from confidential information when necessary.
6.2 Subject to any applicable laws, rules and regulations, we will store such confidential information for as long as reasonably necessary for the purposes described in this Policy or to enable us to comply with regulatory requirements regarding the retention of such personal information, and may retain it until the expiration of any legal challenge period.
7. How You Manage Your Information
Subject to applicable laws, rules and regulations, you may perform the following actions with respect to your personal information (“Management Request”):
(i) obtain a copy of your personal information upon request;
(ii) determine whether your personal information is current and accurate;
(iii) delete your personal information with our consent;
(iv) authorize us to process your personal information, or revoke that authorization;
(v) object to the processing of your personal information;
(vi) restrict the processing of your personal information; and/or
(vii) withdraw your consent to any processing of your personal data, if such processing is subject to your consent.
If you contact us regarding any management request, we reserve the right to:
(a) require you to provide appropriate identification information to verify your identity before processing your management request;
(b) charge you a fee to process your management request if we believe your management request is unreasonable;
(c) reject your management request if we believe it is not possible to meet your management request due to platform limitations;
(d) reject your management request if your management request is subject to applicable laws, regulations or rules;
(e) reject your management request if we have a legal or other obligation not to fulfill your management request;
(f) restrict your use of the service if the management request prevents us from continuing to provide the service to you; and/or
(g) reject your management request if your management request would adversely affect us, other users or the platform.
8. Anonymization and Aggregate Data
8.1 Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. Except for this section, the rest of this Policy does not apply to anonymous or aggregated personal data (i.e., we combine users' information so that it cannot identify or reference individual users).
8.2 We may use anonymous or aggregated customer data for any business purpose, including to better understand user needs and behavior, improve our products and services, implement business intelligence and marketing, and detect security threats. We may analyze anonymous data ourselves or enable analysis provided by third parties.
9. Transfer of Confidential Information Outside Your Country
By using such services, you consent to the transfer of your confidential information to other countries, including countries with different levels of privacy and data protection laws than your country. In all such transfers, we will protect your confidential information as set out in this Policy.
10. External Links
Although the Platform strives to include only safe and relevant external links, you should exercise caution before clicking on any external link. We cannot control, guarantee or verify their content. They have their own policies and practices in terms of privacy and personal data, and you should familiarize yourself with these policies and practices before continuing to access these external websites and applications.
11. How This Policy Is Updated
This Policy is reviewed regularly to ensure that any new obligations are taken into account, as well as any changes in the regulatory environment. If there are any changes to this Policy, we will post the updated Policy on the Platform and change the last updated time. If you continue to use the Service after this Policy is updated, you will be deemed to have agreed to the updated Policy. If you do not agree to any terms in the updated Policy, you should immediately stop accessing and/or using the Service.
12. How to Contact Us
If you have any questions about this Policy, you can contact us by sending an email to: seconddimension001@gmail.com.