隱私權政策

1. Personal Data We Collect

1. At sign-up (required): email, password (stored using one-way encryption that cannot be decrypted), nickname 2. At sign-up (optional): phone number, Telegram username 3. While using the Service: registered exchange UIDs, support ticket content, community posts and attachments, activity point records 4. Generated or collected automatically: IP address, access times, sign-up consent records (items, version, time), security records (failed logins, blocks, etc.) 5. When using the auto-trading program: program login records, access period and redeemed access codes, a PC identifier (converted so the original value cannot be recovered), and the Toobit UID linked to your exchange API key (to confirm a referral account) 6. If you consent in the auto-trading program: anonymous operating statistics (program version, operating system, uptime, error types, order execution quality, returns, drawdown and exposure, and the range of assets traded). We do not collect API keys or secrets, exact balances, Telegram details or files on your PC.

2. Purposes of Use

1. Identifying members, confirming sign-up intent and managing accounts 2. Verifying UIDs and providing rebate information 3. Answering inquiries and sending notices 4. Operating the community and managing posts 5. Preventing fraudulent sign-ups and use, maintaining security and handling disputes 6. Statistical analysis to improve the Service (in a form that cannot identify individuals) 7. Checking eligibility for the auto-trading program (referral account and access period), fixing errors, improving trading performance and publishing aggregate statistics such as average user performance

3. Retention

1. As a rule, data is deleted without delay when a member closes their account. 2. To prevent abuse, the email, UIDs and IP addresses of members subject to restrictions are kept for 1 year from the date of the restriction. 3. Sign-up consent records are kept for 3 years after account closure to handle disputes. 4. Security records are deleted automatically 30 days after creation. 5. Anonymous operating statistics from the auto-trading program are deleted automatically 400 days after collection, and you can turn sending off at any time in the program settings. 6. Data that applicable law requires us to keep is retained for the period set by that law.

4. Disclosure to Third Parties

1. The Company does not sell or provide users' personal data to third parties. 2. Exceptions are where the user consents, where investigative or other authorities request it through legal procedures, or where it is urgently needed to protect the life, body or property of the user or others. 3. UID verification is done by the Company looking up the UID directly in the third-party exchange's partner dashboard, and no other personal data such as email or phone number is provided to the exchange for this purpose.

5. Processors and Storage Abroad

The Company entrusts the following processing to operate the Service, and personal data may therefore be stored on servers abroad.

- Processor: Railway Corporation (United States) - Task: operating the website and database servers (cloud hosting) - Data transferred: all personal data listed in Section 1 - Method: transmission over the network when the Service is used - Retention: until account closure or the end of the processing agreement

6. Cookies and Browser Storage

1. The Company uses essential cookies to keep you signed in. 2. Browser storage (localStorage) is used for convenience features such as the display theme and whether you have seen a notice, and this information stays on your device. 3. The Company does not use advertising cookies or third-party analytics tools. 4. You can delete cookies and storage in your browser settings, but some features such as staying signed in may stop working.

7. Your Rights

1. You may view and correct your personal data at any time, directly on My Page or by request through customer support. 2. You may request deletion, suspension of processing or withdrawal of consent (account closure), and the Company will act without delay except where the law requires retention. 3. You may be asked to send your request from your registered email to verify your identity.

8. Security Measures

1. Passwords are stored using one-way encryption that cannot be decrypted. 2. All communication uses encrypted connections (HTTPS). 3. Administrative access is kept to a minimum, and abnormal access is detected and blocked automatically. 4. However, complete security cannot be guaranteed on the internet, and the Company is not liable for data leaks caused by a member's own negligence.

9. Minors

The Company does not accept sign-ups from persons who are not of legal age in their country of residence. If we learn that a minor's data has been collected, we delete it without delay.

10. Contact and Changes

1. Privacy inquiries can be made through the customer support page. 2. This Policy may change with the law or the Service, and changes will be announced on the Service. 3. Effective date: November 4, 2026