Privacy Policy
1.Who We Are
This Privacy Policy explains how [ENTITY NAME], a company incorporated in Hong Kong, China, with registered office at [ADDRESS] ("COOTOKENS", "we", "us", "our"), collects, uses and protects personal data. Our contact for privacy matters is privacy@cootokens.com, and our data protection contact is [NAME / TITLE].
2.Scope
This Policy applies to personal data we collect through the Platform, our website, and our business dealings with customers, prospective customers and their personnel.
3.Data We Collect
We collect the following categories of personal data.
- Identity and verification data: name, title, identification or passport details, corporate documents, and information about ownership and control, including your Ultimate Parent Company and beneficial owners.
- Contact data: business email address, telephone number and business address.
- Commercial data: orders, service schedules, billing details and payment records.
- Usage and technical data: IP address, login records, access logs, device and browser information, and capacity usage metrics.
- Communications data: correspondence with us, including support requests and compliance documentation.
4.Sensitive Information
Some data we collect, such as identification documents and ownership and control information, may be sensitive. We collect it only where necessary to meet our legal and regulatory obligations, including export control, sanctions and anti-money-laundering requirements.
5.Why We Process Data and Our Legal Bases
- Providing the Services: identity and contact data, commercial data and usage data; legal basis: performance of a contract.
- Verifying identity, ownership and end use, and complying with export control and sanctions requirements: identity and verification data, communications data; legal basis: legal obligation, and our legitimate interest in lawful operation.
- Billing and payment: commercial data; legal basis: performance of a contract, and legal obligation.
- Security, fraud prevention and network integrity: usage and technical data; legal basis: legitimate interest.
- Establishing and defending legal claims: all categories; legal basis: legitimate interest.
- Marketing communications: contact data; legal basis: consent, where required.
6.Cookies
We use strictly necessary cookies to operate the Platform and, where permitted, analytics cookies to understand usage. You can control cookies through your browser settings. Disabling strictly necessary cookies may prevent the Platform from working.
7.Sharing and Disclosure
We may share personal data with: Upstream Providers and sub-processors that help us deliver the Services; professional advisers, including lawyers and auditors; group companies; and competent authorities, regulators and courts, where required by law or necessary to protect our rights.
8.International Transfers
Your personal data may be transferred to and stored in jurisdictions other than your own, including Hong Kong, China, and the jurisdictions in which our Upstream Providers operate. Where required, we implement appropriate safeguards, such as standard contractual clauses. We do not store your personal data in, or route it through, mainland China, except where a service is provided through official cross-border channels designated by the competent authorities of the People's Republic of China, in which case separate terms and safeguards apply.
9.Retention
We retain personal data for as long as necessary to provide the Services and to meet legal, accounting and reporting requirements. Where we are required by export control, sanctions or accounting law to retain records, we may need to retain them for the applicable statutory period, and we may be unable to delete them in response to a request during that period.
10.Security
We use technical and organisational measures to protect personal data, including access controls, encryption in transit, logging and staff confidentiality obligations. No method of transmission or storage is completely secure.
11.Your Rights
Subject to applicable law, you may have the right to access, correct, delete, restrict or object to the processing of your personal data, to request portability, and to withdraw consent where processing is based on consent. These rights are subject to exceptions, including our legal obligation to retain records under clause 9. To exercise a right, contact privacy@cootokens.com.
12.Children
The Services are intended for business users and are not directed to children. We do not knowingly collect personal data from children.
13.Changes to This Policy
We may update this Policy and will post the revised version with a new effective date.
14.Contact
For questions about this Policy, contact privacy@cootokens.com.