imKey 服务条款

IMKEY User Agreement

Last Updated:January 1, 2019

Dear User,

Thank you for using our Website, Products and Services. This IMKEY User Agreement (“Agreement”) is made between you (“User”) and IMKEY PTE. LTD. (Company Registration Number: 201803699C), a company incorporated in Singapore and having its registered address at 83 CLEMENCEAU AVENUE #10-02, SINGAPORE 239920 (“Company”) and is legally binding between you and Company. In this Agreement (a) “we” and “us” refer to the Company and “our” shall be construed accordingly; and (b) “you” refers to User and “your” shall be construed accordingly. Each of you and the Company shall hereinafter be referred to as a “Party”, and collectively, you and the Company shall hereinafter be referred to as the “Parties”.

Company hereby reminds you that you must carefully read the full content of this Agreement and other documents mentioned in this Agreement before using our Website (“IMKEY Website”), Products and Services. In particular, you must carefully read the section of “Disclaimer and Limitation of Liability” and other sections which are displayed in bold in this Agreement. You must make sure that you fully understand the whole Agreement and evaluate the risks of using IMKEY Website, Products and Services on your own.

1. Confirmation and Acceptance of this Agreement

  • 1.1 You understand that this Agreement and other relevant documents apply to your use of IMKEY Website (imkey.im), including but not limited to your using, browsing our Website, purchasing and using Products or Services on IMKEY Website and participating in activities etc.

  • 1.2 Your usage of IMKEY Website is deemed as having read and accepted this Agreement, which shall cause this Agreement to become effective and legally binding on both you and Company immediately. IF YOU DO NOT AGREE TO THE TERMS IN THIS AGREEMENT, YOU SHALL CEASE USAGE OF IMKEY WEBSITE IMMEDIATELY.

  • 1.3 In using IMKEY Website, you agree:

    • 1.3.1 to be bound by the latest version of this Agreement without variation or modification;

    • 1.3.2 that in the jurisdiction to which you are subject, you are of legal age to use IMKEY Website and to create binding legal and financial obligations for any liability you may incur as a result of the use of IMKEY Website;

    • 1.3.3 to accept the Company’s rights to unilaterally decide to refuse Services and cancel the order in a specific jurisdiction according to applicable laws;

    • 1.3.4 to prepare your own Internet access device and bear the cost for surfing the Internet; and

    • 1.3.5 that you are not an Excluded Person (as defined herein).

  • 1.4 Company 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 IMKEY Website and you will not be notified separately. If you do not agree with the modifications, you shall cease to use IMKEY Website immediately. Use of IMKEY Website by you after any modification to this Agreement constitutes your acceptance of this Agreement as modified.

2. Definition

  • 2.1 Excluded Person:

    • 2.1.1 a person other than a natural person who possesses legal and mental capacity to enter into this Agreement; or

    • 2.1.2 a User who is prohibited, restricted, unauthorized or ineligible in any form or manner whether in full or in part under this Agreement, laws, regulatory requirements, or rules in the jurisdiction applicable to such User, to use IMKEY Website.

  • 2.2 Alert: means the messages displayed on IMKEY Website which provides suggestions for Users on subsequent operations.

  • 2.3 Specific Users: means Users who shall cooperate with Company and disclose Personal Information in order to comply with the laws, regulations and policies of Singapore and other countries.

  • 2.4 Personal Information: means information recorded in electronic or any other form which may identify a natural person when used alone or in combination with other information, including but not limited to name, date of birth, identification card number, personal biological identification information, address, telephone number, bank card number, e-mail address, wallet address, mobile device information, operation record, transaction record, but excluding PIN code, Private Key and Mnemonic Words.

  • 2.5 Third Party:means third-party payment platforms, third-party crypto currency wallets, third-party DApps, third-party smart contracts etc.

3. Your Rights and Obligations

  • 3.1 You shall comply with all applicable laws and regulations of the country or region you reside in. You shall not use IMKEY Website for any unlawful purposes or by any unlawful means.

  • 3.2 When you purchase and use Products or Services, participate in activities via IMKEY Website, you shall provide IMKEY Website with detailed, true and accurate Personal Information and update such information from time to time. Otherwise, the corresponding consequences shall be borne by yourself.

  • 3.3 You shall pay Company the price and fees of purchased goods and service (if any). When you use third-party products or services, they may charge handling fees and/or services fees from you, which shall be subject to the fees collected by them and not covered in the price and fees of products or service (if any) displayed on IMKEY Website.

  • 3.4 You shall not use IMKEY Website to commit any illegal or unlawful activities, including but not limited to:

    • 3.4.1 activities endangering national security of the country or area you reside in, disclosing state secrets, overturning the government or undermining national unity;

    • 3.4.2 any illegal conducts, such as money laundering, illegal fund raising etc;

    • 3.4.3 accessing Company system, collecting or processing the content provided by Company, intervening or attempting to intervene any Users, by the employment of any automated programs, software, network engines, web crawlers, web analytics tools, data mining tools or similar tools etc;

    • 3.4.4 providing gambling information or inducing others to engage in gambling;

    • 3.4.5 use IMKEY Website to conduct profit-making activities;

    • 3.4.6 committing any activities which harms or attempts to harm IMKEY Website system and data;

    • 3.4.7 other activities which Company has reason to believe are inappropriate.

  • 3.5 You understand and agree to comply with the Alert(s) published by Company on IMKEY Website. You shall be responsible for any risks, liabilities, losses and expenses which result from your failure to comply with any Alert(s).

  • 3.6 In accordance with relevant laws and regulations or when Company deems it necessary (including but not limited to abnormal transaction behaviors or transactions, suspicious identity), Specific Users will be asked to complete identification verification before using IMKEY Website, according to the Alert of IMKEY Website. Specific Users may be asked to provide Personal Information including but not limited to name, identification card number, cell phone number, bank card information, etc., without which Specific Users will not be able to use certain functions of IMKEY Website and Specific Users alone shall be responsible for the loss caused by their delay in completing the verification.

  • 3.7 You shall purchase and use our Products and Services from our official channel (imkey.im). If you obtain our Products or Services from an unauthorized channel, Company will not be able to guarantee the normal use or effective provision of Products or Services, nor will guarantee security of them. Users alone shall be responsible for the loss caused thereby.

  • 3.8 You shall not import, export, sell or transfer our Products or Services in violation of laws and regulations. You undertake that our delivery of Products or Services via official channel to you will not violate any applicable laws and regulations.

  • 3.9 You understand and agree that, if your violation of relevant laws (including but not limited to regulatory rules concerning Customs and/or tax) or provisions of this Agreement makes Company suffer any loss, subject to any others’ claims or bear any administrative department’s penalties, you shall compensate Company (including reasonable attorney fees).

4. IMKEY Website’s Rights and Obligations

  • 4.1 Provide User with online shopping platform and pre-sales and after-sales service.

  • 4.2 We will do our best to ensure that the prices of the items you purchased are consistent with their prices displayed on IMKEY Website, but the price list or statement does not constitute an offer, which is merely an invitation to offer, while your order placed will be an offer. IMKEY Website reserves the right to unilaterally withdraw any our acceptance in the event of any obvious errors or shortages of products and orders displayed on the Website. At the same time, IMKEY Website reserves the right to limit the number of product orders.

  • 4.3 You acknowledge and agree that Company will push events and other important information to you by means of e-mail and telephone number you provided to us or announcements on the IMKEY Website. Please kindly pay attention to it.

  • 4.4 You acknowledge and agree that Company reserves the right to change the price, quantity and other information of Products and Services on IMKEY Website without any notice to you.

5. Change, Suspension, Termination of IMKEY Website Services

  • 5.1 You acknowledge and accept that Company may, at its sole discretion, provide only a part of Services of IMKEY Website for the time being, suspend certain Services or provide new Services in the future. When we change our Services, your continuous use of IMKEY Website is deemed as your acceptance of this Agreement and revisions of this Agreement.

  • 5.2 You understand that Company may suspend Services of IMKEY Website under following circumstances (or may completely terminate Services in connection with any of the following circumstances):

  • 5.2.1 maintenance, upgrading, failure of equipment and blockchain system and the interruption of communications etc., which lead to the suspension of the operation of IMKEY Website;

  • 5.2.2 force majeure events including but not limited to typhoon, earthquake, tsunami, flood, power outage, war, or terrorist attacks, or computer viruses, trojan horse, hacker attacks, system instability or government behaviors and other reasons, which result in the Company’s inability to provide Services or if in Company’s reasonable opinion, continuous provision of Services would result in significant risks;

  • 5.2.3 material adverse change of applicable laws or policies; or

  • 5.2.4 any other event(s) which Company cannot control or reasonably predict.

  • 5.3 Company reserves the right to unilaterally suspend or terminate all or part of Services of IMKEY Website under the following circumstances:

  • 5.3.1 if you provide false Personal Information to Company;

  • 5.3.2 if you use IMKEY Website to commit illegal or criminal activities;

  • 5.3.3 if you hinder the normal use of IMKEY Website by other Users;

  • 5.3.4 if you pretend to be staff or management personnel of Company;

  • 5.3.5 if you threaten the normal operation of Company computer system by attack, invasion, alternation or any other means;

  • 5.3.6 if you use IMKEY Website to send spam;

  • 5.3.7 if you spread rumours which endanger the goodwill of Company and IMKEY Website; or

  • 5.3.8 if you conduct any illegal activities, breach this Agreement etc or other circumstances under which Company reasonably considers necessary to suspend Services.

  • 5.4 You acknowledge and agree that, under circumstances provided in above Article 5.3, apart from suspension or termination of Services, Company is entitled to choose one or more following penalties on a case to case basis:

  • 5.4.1 warning;

  • 5.4.2 correction within a time limit;

  • 5.4.3 canceling the order;

  • 5.4.4 prohibition of transactions;

  • 5.4.5 forbidding User to use IMKEY Website, purchase Products or Services of Company permanently;

  • 5.4.6 claiming against User by litigation or non-litigation means; and/or

  • 5.4.7 notifying and assisting government departments in enforcement of law.

6. Privacy Policy

  • 6.1 Any personal data or information which you provide to us is also subject to our privacy policy (“IMKEY Privacy Policy”), which is incorporated by reference into this Agreement.

7. Disclaimer and Limitation of Liability

  • 7.1 Company only undertakes obligations expressly set forth in this Agreement。

  • 7.2 YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE WEBSITE, PRODUCTS AND SERVICES ARE PROVIDED ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS. Company shall not be held liable for Users’ failure to use IMKEY Website, Products or Services resulted from any of the following reasons:

  • 7.2.1 your own reasons (including but not limited to your failure to check delivery statements displayed on IMKEY Website or provide correct delivery information or receive the delivered goods, which cause delivery delay of ordered goods or unsuccessful delivery);

  • 7.2.2 maintenance or upgrading of IMKEY Website system;

  • 7.2.3 force majeure, such as typhoon, earthquake, flood, lightning or terrorist attack etc;

  • 7.2.4 malfunction of your mobile device hardware and software, and failure of telecommunication lines and power supply lines;

  • 7.2.5 malfunction of Third Parties linked on IMKEY Website;

  • 7.2.6 your improper, unauthorized or unrecognized use of IMKEY Website;

  • 7.2.7 computer viruses, trojan horse, malicious program attacks, network congestion, system instability, system or equipment failure, telecommunication failure, power failure, banking issues, government acts etc;

  • 7.2.8 Company being unable to copy accurate transaction records due to system delay or blockchain instability etc;

  • 7.2.9 any other reasons not imputed to Company.

  • 7.3 Company does not make any express or implied representations or warranties in following forms that:

    • 7.3.1 IMKEY Website, Products or Services provided by Company would satisfy all your needs;

    • 7.3.2 information of IMKEY Website, Products or Services provided by Company is real time, accurate and remains unchanged;

    • 7.3.3 your operation of IMKEY Website would meet all your expectations; or

    • 7.3.4 all the data and information you obtained from the Third Party during your usage of IMKEY Website are prompt, accurate, complete, and reliable.

  • 7.4 Payment method:

    • 7.4.1 you acknowledge and agree that for the payment method, payment limit and number of transactions you can use on IMKEY Website may be different or restricted depending on country or region where you are using the payment method, regulatory requirements, payment purpose, risk control of IMKEY Website and identity verification etc;

    • 7.4.2 you acknowledge and agree that based on the irrevocable attribute of blockchain operation, when you use the third-party payment method on IMKEY Website, you shall bear the consequences of your operation errors (including but not limited to problems that you input wrong payment address, select the transfer node server by yourself, press the confirm option by mistake);

    • 7.4.3 you acknowledge and agree that transaction operations such as payment are completed on the Third Party, IMKEY Website is solely a platform providing you with options. Whether or not to use the third-party products or services is at your choice, Company does not make any guarantee to the quality of products or services provided by the Third Party. Company does not undertake any responsibility related to disputes arising from payment operation.

  • 7.5 In any case, the total liability for Company under this Agreement shall not exceed the greater of: a) total amount of orders paid to Company by the User involved in the most recent fiscal year; or b) 100 Singapore Dollars.

  • 7.6 Company does not provide legal, tax or investment advice. You shall seek advice from professional legal, tax and investment advisors. In addition, Company shall not be liable for any investment loss, data loss etc. during your use of IMKEY Website.

  • 7.7 You understand that we may change our entry standards, limit the range and ways to use IMKEY Website for specific Users from time to time in accordance with applicable laws and regulations.

8. Miscellaneous

  • 8.1 The intellectual property rights of any contents displayed on IMKEY Website (including materials, trademarks or logos) are owned by Company, Company’s affiliates or third-party licensors. Users can only use IMKEY Website and its contents for the purposes hereunder. In particular, without prior written consent from Company, Company’s affiliates or third-party licensors (or the permission of relevant open source agreement), no one shall use, modify, decompile, reproduce, publicly disseminate, alter, distribute, issue or publicly publish the abovementioned intellectual property rights, or copy the trademark, logo, user interface or design of IMKEY Website. This Agreement shall not entitle you to any intellectual property rights, including the rights in relation to the use, for any purpose, of any information, image, user interface, logos, trademarks, trade names, internet domain names or copyright in connection with us or IMKEY Website.

  • 8.2 Any failure by us to enforce this Agreement or to assert any right(s), claim(s) or causes of action against you under this Agreement shall not be construed as a waiver of our right to assert any right(s), claim(s) or causes of action against you.

  • 8.3 Subject to this Agreement, only you and no other person shall have the right to any claim against us in connection with use of IMKEY Website. You shall not assign, trade or transfer, or attempt to assign, trade or transfer, your right to any such claim. Any such assignment or transfer shall be void and shall not impose any obligation or liability on or against us to the assignee or transferee.

  • 8.4 Entire Agreement:

    • 8.4.1 This Agreement includes this IMKEY User Agreement, IMKEY Privacy Policy, imKey Terms of Use and other documents, posted by Company from time to time.

    • 8.4.2 Save for the IMKEY User Agreement, IMKEY Privacy Policy, and imKey Terms of Use which are incorporated in this Agreement, this Agreement contains the entire agreement and the understanding between us and supersedes all prior agreements, understandings or arrangements (both oral and written) in relation to the use of IMKEY Website in connection thereto.

  • 8.5 The tax and delivery service policies for Products and Services on IMKEY Website are subject to announcements and notices posted on IMKEY Website.

  • 8.6 Governing Law and Dispute Resolution:

    • 8.6.1 This Agreement shall be governed by and construed in accordance with the laws of the Republic of Singapore.

    • 8.6.2 In the event of any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity or termination, the Parties shall first seek settlement of that dispute. In the event that such dispute is not resolved within a period of 30 days from the commencement of such settlement process, such dispute shall be referred to and finally be resolved by arbitration in Singapore in accordance with the rules of the Singapore International Arbitration Centre (“SIAC”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The tribunal shall consist of a sole arbitrator to be appointed by the Chairman of the SIAC. The language of the arbitration shall be English. Each of the Parties irrevocably submits to the non-exclusive jurisdiction of the courts of Singapore to support and assist the arbitration process pursuant to the foregoing of this paragraph, including if necessary the grant of interlocutory relief pending the outcome of that process.

  • 8.7 The Contracts (Rights of Third Parties) Act (Chapter 53B) of Republic of Singapore, as may be modified, amended or supplemented from time to time, shall apply to this. A person who is not a Party shall not have any rights whatsoever under this Agreement or to enforce this Agreement.

  • 8.8 Severance and Partial Invalidity:

    • 8.8.1 If any of part of this Agreement is rendered void, illegal or unenforceable by any legislation to which it is subject, it shall be rendered void, illegal or unenforceable to that extent and no further and, for the avoidance of doubt, the rest of this Agreement shall continue to be valid and in full force and effect.

    • 8.8.2 The illegality, invalidity or unenforceability of any provision of this Agreement under the law of any jurisdiction shall not affect its legality, validity or enforceability under the law of any other jurisdiction nor the legality, validity or enforceability of any other provision.

  • 8.9 Translated versions of this Agreement (if any) are provided for the convenience of Users and are not intended to revise the English version of this Agreement. If there is any discrepancy between the English version and non-English version of this Agreement, the English version shall prevail.

  • 8.10 You shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of IMKEY Website.

  • 8.11 During your use of IMKEY Website, if you come across any problems, you can contact us through contact information published on our Website.

  • 8.12 This Agreement is accessible for all Users on IMKEY Website. We encourage you to read this Agreement each time you access IMKEY Website.

  • 8.13 This Agreement shall become effective on 1 January 2019.

As for any issues not covered in this Agreement, you shall comply with the announcements and relevant rules as updated by Company from time to time.

IMKEY PTE. LTD.

(Company Registration Number: 201803699C)

IMKEY Privacy Policy

Last Updated: January 1, 2019

Dear Users,

IMKEY PTE. LTD. (“Company”, “we”, “us”, or “our”) respects and protects the privacy of Users (“you”, “your” or “Users”). The Company will collect, use, disclose and process your Personal Information, in accordance with this Privacy Policy (“Policy”) when you:

  • (a) use our Website, Products or Services; and/or

  • (b) provide us with your Personal Information, regardless of the medium through which such Personal Information is provided.

The Company recommends that you shall carefully read and understand the whole contents of this Policy before your use of our Website, Products or Services. Additionally, significant information including the Disclaimer is in bold form in this Policy. Definitions of key words in this Policy are consistent with those in the IMKEY User Agreement of the Company. If there is any discrepancy between the definitions of any defined term used in this Policy and the IMKEY User Agreement, the definition of any defined term used in this Policy shall prevail.

By providing us with your Personal Information, you consent to our collection, use, disclosure (including transferring) and processing of your Personal Information in accordance with this Policy. Please DO NOT provide any Personal Information to us if you do not accept this Policy.

The Company reserves the right to update this Policy online from time to time, without notice to you, and the revised Policy will come into effect and supersede the older versions once posted on our official website. The revised Policy will apply to Personal Information you provided to us previously. In particular, if you do not accept the revised Policy, please immediately stop your use of our Website, Products or Services. Your continuous use of our Website, Products or Services will be regarded as your acceptance of the revised Policy.

1. Information We Collect

  • 1.1 When you use our Website or purchase our Products or Services through links of our associatesaffiliates’ DApp, we will collect your personally identifiable information, including but not limited to your name, delivery address, telephone number, e-mail address, location information etc.

  • 1.2 When you choose to pay by the payment method we provide, we may obtain your WeChat account, Alipay account, digital crypto currency wallet address and other information from a Tthird Pparty.

  • 1.3 When you use our customer service, we may request for you to provide us with your name, telephone number, order number, waybill number, addressee, delivery address, payment method, query problem and other information.

  • 1.4 In order to satisfy requirements of laws and regulations and satisfy your needs or requests for specific services, we may also request for you to provide us with additional Personal Information in order for us to enable your use of any specific functions of our Website, Products or Services. Your refusal to provide us with the requested Personal Information will be considered as your choice to not use a particular specific function.

  • 1.5 To the extent permitted by applicable laws and regulations, the Company may collect and use the Personal Information in the following circumstances without your prior consent or authorization:

    • 1.5.1 information related to national security and national defense;

    • 1.5.2 information related to public security, public health, significant public interests;

    • 1.5.3 information related to criminal investigation, prosecution, trial and enforcement;

    • 1.5.4 Personal Information in the public domain;

    • 1.5.5 Personal Information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

    • 1.5.6 Personal Information necessary to maintain the security and compliance of Services, such as to detect or to solve the malfunction of Products and Services; and/or

    • 1.5.7 other circumstances permitted by laws and regulations.

  • 1.6 We collect information in the following ways:

  • 1.6.1 when you provide us with your Personal Information for whatever reasons;

  • 1.6.2 when you authorize us to obtain your Personal Information from a Tthird Pparty;

  • 1.6.3 when you use our Products and Services;

  • 1.6.4 when you contact us or interact with our employees through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, e-mails, fax and letters;

  • 1.6.5 when you transact with us, contact us or request that we contact you;

  • 1.6.6 when you request to be included in an e-mail or our mailing list; and/or

  • 1.6.7 when we copy all or part of your transaction records on the blockchain. However, you shall refer to the blockchain system for your latest transaction records.

  • 1.7 Our website may contain certain technologies that collect Personal Information in the manner described in this Policy (see Article 5 below) or the applicable terms and conditions.

  • 1.8 Your provision of Personal Information to us is voluntary and you may withdraw your consent for us to use your Personal Information at any time. However, if you choose not to provide us with the Personal Information we require, it may not be possible for you to use certain functions of our Website, Products or Services or for us to contact you, or provide Products or Services which you need from us.

  • 1.9 In certain circumstances, you may also provide us with the Personal Information of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her Personal Information and that he/she has consented to your disclosure of his/her Personal Information to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such Personal Information in accordance with the terms of this Policy.

  • 1.10 You are responsible for ensuring that all Personal Information that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your Personal Information.

2. How We Use Your Information

  • 2.1 We collect, use or disclose your Personal Information for one or more of the following purposes:

    • 2.1.1 to provide you with Products and/or Services that you request for;

    • 2.1.2 to manage your relationship with us;

    • 2.1.3 to facilitate your use of our Website, Products and Services;

    • 2.1.4 to push important notifications to you, such as update of User Agreement and this Policy;

    • 2.1.5 to assist with your enquiries, feedback, complaints and requests by using the wallet address and the mobile device information provided by you;

    • 2.1.6 to notify you of our Products, Services, programmes and activities;

    • 2.1.7 to resolve any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct;

    • 2.1.8 to conduct our internal audit, data analysis and research;

    • 2.1.9 to conduct user behavior analysis by tracking the Users’ use of website;

    • 2.1.10 to comply with our obligations in accordance with laws, regulations and to cooperate with regulatory authorities;

    • 2.1.11 to comply with international sanctions and applicable regulations for securityies, andanti to counter- money-laundering or financing of terrorism;

    • 2.1.12 to enforce obligations owed to usperform our legal obligations, and contractual terms and conditions; and/or

    • 2.1.13 any other reasonable purposes related to the aforesaid.

  • 2.2 If you have consented, we may use your Personal Information, from time to time, for additional purposes such as to inform you of the latest activities, special offers and promotions offered by our strategic business partners, associates and affiliates.

3. How You Control Your Own Information

You are entitled to control your Personal Information provided when using our Website, Products and Services.

  • 3.1 You may access purchase webpage of IMKEY Website via our official Website or links of our affiliates’ DApp and update, revise and delete your name, delivery address, telephone number, e-mail address and other information thereof. We may require you to verify your identity in order to protect your information security.

  • 3.2 You acknowledge that since blockchain is an open source system, your transaction records are automatically public and transparent in the whole blockchain.

  • 3.3 Our Website may contain links to other websites, products, services or smart contracts that are not owned, operated, developed or maintained by us. These links are provided only for your convenience. This Policy only applies to our Website, Products and Services. When visiting these third-party websites, or using these third-party products, services or smart contracts, you understand that the IMKEY User Agreement and IMKEY Privacy Policy and imKey Terms of Use will no longer apply. You are encouraged to carefully review their privacy policies and related terms of service.

  • 3.4 You are entitled to ask us to update, revise, and delete your Personal Information and/or withdraw any consent provided to us. If you wish to withdraw any consent you have given us at any time, or if you wish to update, revise, delete or have access to your Personal Information held by us, or if you do not accept any amendment to this Policy, please contact us at: Customer Service E-mail: support@IMKEY.im

  • 3.5 We may charge you a fee for responding to your request for access to your Personal Information held by us, or for information about the ways in which we have (or may have) used your Personal Information in the one-year period preceding your request. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received. We will endeavour to respond to your request within thirty (30) days, and if that is not possible, we will inform you of the time by which we will respond to you.

  • 3.6 In many circumstances, we need to use your Personal Information in order for us to provide you with Products or Services that you require. If you do not provide us with the required Personal Information, or if you withdraw your consent to our use and/or disclosure of your Personal Information for these purposes, it may not be possible for us to continue to serve you or provide you with the Products and Services that you require.

  • 4 Information We may Share or Transfer

    • 4.1 We will keep your Personal Information for so long as we need the Personal Information for our business and legal purposes.

    • 4.2 We do not sell, trade or otherwise transfer your Personal Information to Tthird Pparties without your consent.

    • 4.3 If you have consented to our disclosure of your Personal Information to our strategic business partners and associatesaffiliates, we may disclose your Personal Information to them. They will use your Personal Information only for the purposes you have consented to.

    • 4.4 You agree that we may disclose or share your Personal Information with Tthird Pparties such as:

      • 4.4.1 Tthird Pparties that have signed cooperation agreements with us to provide services to you, for example, we may disclose your purchase information and recipient information to authorized distributors or logistics enterprises that have signed cooperation agreements with us after your ordering Products on our Website;

      • 4.4.2 service providers and data processors working on our behalf and providing services to us such as conducting know-your-clients checks, accounting, data processing or management services, website hosting, maintenance and operation services, e-mail message services, analysis services, handling of payment transactions, marketing etc; and

      • 4.4.3 our consultants and professional advisors (such as accountants, lawyers, auditors).

  • 4.5 If we need to transfer your Personal Information to any country for the purposes set out above, we shall obtain your prior consent and ensure that the recipient of the Personal Information protects your Personal Information to the same level as we have committed to protecting your Personal Information. Where these countries or territories do not have personal data protection laws that are comparable to the laws applicable to our relationship with you, we will enter into legally enforceable agreements with the recipients.

  • 4.6 The Company will not share with or transfer your Personal Information to any Tthird Pparty without your prior consent, except for the following circumstances:

    • 4.6.1 the collected Personal Information is publicized by yourself;

    • 4.6.2 the Personal Information is collected from public information which was legally disclosed, such as news (lawfully reported), government information disclosure and other channels;

    • **4.6.3 in order to abide by applicable laws, regulations, legal procedures, and administrative or judiciary authorities or to enforce our Policy or protect our or others’ rights, property or safety;

    • **4.6.4 in the case of mergers and acquisitions, if transfer of Personal Information is involved, the Company may require the receivers of Personal Information to be continuously bound by this Policy.

5. Automatic Data Collection Technologies

  • 5.1 We use Automatic Data Collection Technologies on our Website, Products or Services. Examples of such technologies include:

    • 5.1.1 Cookies (or browser cookies). Cookies are small text files which are set by a website or application operator so that your browser or device may be recognized. We may make use of cookies on our Website, Products or Services to store and track information such as the number of users and their frequency of use, profiles of users and their online preferences. Cookies do not capture information which would personally identify you, but the information collected may be used to assist us in analyzing the usage of our Website, Products or Services and to improve your online experience with us. You can disable the Cookies by changing the setting on your browser. However, this may affect the functionality of the Website, Products or Services.

    • 5.1.2 Web analytics. Web analytics is the term given to a method for collecting and assessing the behavior of visitors to websites and mobile applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or mobile application, or to find out what information and services our visitors are most interested in. The web analytics services on our Website, Products or Services are provided by third-party service providers.

6. How We Protect Your Information

  • 6.1 If the Company ceases operation, the Company will stop the collection of your Personal Information and take steps to delete or anonymize your Personal Information held by us within a reasonable period.

  • 6.2 To protect your Personal Information, the Company may adopt data security techniques, improve internal compliance levels, provide security training for our staff, and set security authority for access to relevant data to protect your Personal Information.

  • 6.3 We will send you messages about information security and update articles concerning the use of Products and Services and information protection on our Website for your reference.

7. Protection for the Minors

The following special provisions apply to minors who are under the age of 18 years old:

  • 7.1 The minors shall not use our Services without the guidance from their parents or guardians.

  • 7.2 The parents and guardians of the minors shall provide guidance to the minors on using our Website, Products or Services after they read this Policy, IMKEY User Agreement, imKey Terms of Use and other relevant rules.

  • 7.3 Our Website, Products or Services will ensure the confidentiality and security of the minors’ Personal Information in accordance with the applicable laws and regulations.

8. Disclaimer

  • 8.1 After you access the websites, products, services or smart contracts operated by Tthird Pparties, you acknowledge and agree that this Policy no longer applies to the collection, use, disclosure and transfer of your Personal Information by these Tthird Pparties. The Company is unable to guarantee that these third-party websites, products, services and/or smart contracts will implement reasonable security measures to protect your Personal Information.

  • 8.2 You acknowledge and agree that different countries and regions have different definitions of Personal Information and we will protect your Personal Information in accordance with the applicable laws set forth in Article 9.2. In order to protect Users’ Personal Information to the maximum extent as permitted by laws, we may process some non-Personal Information in accordance with protection standards of Personal Information; if non-Personal Information is mixed with Personal Information, we will regard non-Personal Information as Personal Information.

  • 8.3 You are solely responsible for your use of these third-party websites, products, services and/or smart contracts and agree that you will not hold the Company liable for any damages incurred or injuries inflicted as a result of the collection, use, disclosure and transfer of your Personal Information by these third-party websites, products, services and/or smart contracts .

  • 8.4 YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY WILL ADOPT MEASURES AS REASONABLE AS POSSIBLE TO PROTECT YOUR PERSONAL INFORMATION UNDER CURRENT TECHNIQUES ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS, TO AVOID THE DISCLOSURE, TAMPERING OR DAMAGE OF INFORMATION. SINCE THE COMPANY TRANSFERS DATA WIRELESSLY, THE COMPANY MAKES NO GUARANTEE ON THE PRIVACY AND SECURITY OF WIRELESS INTERNET DATA TRANSFERRING.

9. Miscellaneous

  • 9.1 You shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of the Websites, Products and Services provided by the Company.

  • 9.2 The validity, interpretation, alternation, enforcement, dispute resolution of this Policy and its revised versions shall be governed and construed in accordance with the laws of Singapore. Where there is no applicable law, this Policy shall be interpreted by applicable commercial and/or industrial practices. If any dispute or claim in connection with this Policy arises between you and the Company, the parties shall first attempt to resolve the dispute or claim through amicable negotiations in good faith. If the parties cannot reach an agreement, either party may sue the other party at the competent court in Singapore.

  • 9.3 You may access this Policy and other terms (e.g. IMKEY User Agreement, imKey Terms of Use) through our Website. We encourage you to check the IMKEY User Agreement and the Policy of the Company each time you access our Website.

  • 9.4 Any translated versions of this Policy are provided for the convenience of Users and are not intended to amend the original English version of this Policy. If there is any discrepancy between the English version and non-English version of this Policy, the English version shall prevail.

  • 9.5 This Policy shall become effective on January 1, 2019.

As for any issues not covered in this Policy, you shall comply with the announcements and relevant rules as updated by the Company from time to time.

IMKEY PTE. LTD.

(Company Registration Number: 201803699C)