ViaWallet Service Agreement

Last update : May 10, 2019

Dear User :

Thank you for choosing the ViaWallet service. The ViaWallet Service Agreement (hereinafter “Agreement”) is a legally binding agreement between Viabtc Technology LTD (hereinafter “Company”), a company registered in [ Hong Kong ] under registration number [ 68073584-000-08-18-0 ] whose registered address is [ Room 1907 ,19/F, LEE GARDEN ONE, 33 HYSAN AVENUE, CAUSEWAY BAY ,Hong Kong ] and you (hereinafter “User”). As used in this Agreement, (1) “we” or “our” refers to the Company and (2) “you” or “yours(your?)” refer to the User. You and the Company may individually be referred to as a “party” and together as “parties”.

The Company specifically reminds you that before using our ViaWallet (hereinafter “ViaWallet”) mobile application, which may be downloaded on mobile application platforms, including but not limited to Google Play and Apple App Store, please carefully review the terms of this Agreement, particularly, provisions whose headings are in bold lettering such as “Disclaimer and Limitation of Liability”, to ensure that you have read, understood, agreed with and fully accepted all of the terms and conditions contained in the Agreement and the risks associated with transacting in digital assets. By downloading the ViaWallet and setting up or importing a wallet (as defined below), you are deemed to have fully read and accepted all the terms of this Agreement, and this Agreement is effective immediately and is binding on both parties. If you do not agree to the terms of this Agreement, you should stop using ViaWallet immediately. If you have already downloaded ViaWallet, please delete it now.

This Agreement may be updated by the Company at any time. Once the updated Agreement or terms is published on the ViaWallet platform, it will automatically take effect immediately without further notice. After the Company announces the terms of the revised Agreement, if you do not accept the revised terms, please stop using ViaWallet immediately; your continued use of ViaWallet will be deemed as acceptance of the Agreement as revised.

1. Definitions

In this Agreement, the following terms and expressions shall have the meanings ascribed to them below, unless the context of use of any term requires otherwise:

  • 1. “China” refers to the People’s Republic of China, including the Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan.
  • 2. “ViaWallet” refers to the digital wallet developed on its blockchain by the Company, including other auxiliary tools developed to facilitate your use of the blockchain system.
  • 3. “Excluded Person”, other than a natural person, does not have the legal capacity to enter into this Agreement.
  • 4. “Create or Import Wallet” refers to the process of setting up or importing a wallet using ViaWallet after acceptance of this Agreement.
  • 5. “Wallet Password” refers to the password you decide to use for your account during the setting up of your ViaWallet wallet, which is encrypted with your Private Key for your protection. ViaWallet is a decentralized application. The Wallet Password is not stored on your mobile device or our server. If you lose or forget your Wallet Password, you will need to reset your password with your Private Key or Mnemonic Phrase.
  • 6. “Information Guide” is ViaWallet’s software interface that provides information to assist you in navigation and it is recommended that you follow the guide when using the system.
  • 7. “Specified Users” refer to users who must comply with the laws, regulations and policies of xxx or other countries and cooperate with our Company’s obligations relating to their personal information disclosure.
  • 8. “Private Key” composed of a 256-bit random character key controlled by a User for use with digital tokens.
  • 9. “Public Key” is generated by the Private Key using cryptographic principles to generate the blockchain digital wallet address. The digital wallet address is a public address for receiving digital payments.
  • 10. “Mnemonic Phrase” consists of 12 (or 15/18/21/24) ordered words generated by a random algorithm which complies with blockchain BIP39 industry standard. It is an easy-to-record expression of the Private Key, convenient for Users to backup and keep.
  • 11. “Keystore” is an encrypted formatted file of your Private Key or Mnemonic Phrase saved by your password. It is only stored on your mobile device and will not be synchronized to the Company’s servers.
  • 12. “Digital Tokens” refer to different digital tokens currently supported by ViaWallet, including but not limited to, BTC, BCH, etc.
  • 13. “Message Center” refers to the inbox where you can receive information or notifications from the Company.
  • 14. “Personal Information” refers to information that is electronically or otherwise recorded that can lead to a User’s personal identity, either alone or in combination with other information, including but not limited to, the name of a natural person, date of birth, identification number, personal biometric information, address, telephone number, bank card number, mailing address, wallet address, mobile device information, operation history, transaction history, etc., but does not include a User's Wallet PIN, Private Key, Mnemonic Phrase, or Keystore.

2.ViaWallet Service (hereinafter “Service”)

  • 1. Create or import a wallet. For Digital Tokens supported by ViaWallet, you can use ViaWallet to generate a new wallet or import a compatible wallet generated by other wallet tools from similar blockchain systems.
  • 2. Transfer or receive payments. You can use ViaWallet’s transfer and collection functions to manage Digital Tokens; the Private Key may also be used for electronic signatures and to modify the ledger of the blockchain to reflect transfers. Transfer refers to a payer using a payee’s blockchain address for transferring Digital Tokens, which produces a valid record of the transaction in the distributed ledger of the blockchain system itself (rather than actually delivering or transferring Digital Tokens to the ViaWallet). Based on the “non-cancelable” attribute of the blockchain system transaction, when you use the transfer function, we cannot withdraw or cancel the transaction for you.
  • 3. Transaction record. We copy all or part of your transaction history from the blockchain system. However, you should rely on the latest transaction record of the blockchain system itself as the official record instead of our transaction record.
  • 4. Limitation to Services of the Company
  • When the above-mentioned services are provided by the Company, you should also understand that:
  • 1. because a blockchain is decentralized, the Company’s Services in protecting of the security of your Digital Tokens are also decentralized, which is greatly different from services of banking or financial institutions. You understand and accept that the Company does not assume the following responsibilities:
  • (1) storing Wallet PIN (that is, the password set when you setup(create?)/import the wallet), Private Key, Mnemonic Phrase or Keystore;
  • (2) retrieving your Wallet PIN, Private Key, Mnemonic Phrase, or Keystore;
  • (3) blocking wallet account;
  • (4) losing wallet;
  • (5) restoring the wallet;
  • (6) cancelling transactions.
  • 2. You are solely responsible for your mobile device which contains your ViaWallet and for backing up of your ViaWallet, Wallet Password, Mnemonic Phrase, Private Key, and Keystore. If you lose your mobile device, delete or failed to back up ViaWallet or your wallet, if your wallet is stolen, or you forget your Wallet PIN, Private Key, Mnemonic Phrase or Keystore, the Company cannot restore them; if you make a mistake in effecting a transaction (such as sending to a wrong transfer address or wrong exchange amount), the Company cannot cancel the transaction and the Company shall not bear any responsibility whatsoever.

    3. The Services that the Company and ViaWallet can provide do not cover all existing digital tokens. Please do not use ViaWallet to handle any digital tokens that are not supported by ViaWallet.

3.Your Rights and Obligations

  • 1.Setting up or importing a wallet

    1. Setup or import a wallet. You have the right to setup(create?) and/or import a wallet via ViaWallet on your mobile device; set the Wallet PIN and similar data, and use your own wallet via the ViaWallet app to conduct transactions such as making transfers or receiving payments on the blockchain.

    2. Authentication. In accordance with the requirements of relevant laws and regulations, Specified Users must complete relevant authentication procedure as prompted by ViaWallet when using Services provided by ViaWallet. Personal Information required includes, but is not limited to, providing name, identification number, Personal Information, such as mobile phone number and bank card number information. Otherwise, a Specified User will not be able to use the Services, and any loss caused by the delay to the Specified User shall be at his own risk.

    3. The Company may develop different versions of ViaWallet for different terminal devices. You should choose to download the appropriate version for installation suitable for your device. If you obtain the software or installation program from a third party which is not authorized by us, the Company will not be able to ensure normal functions of the software or its security. Therefore, any resulting loss will be at your own risk.

    4. After a new version of ViaWallet is released, the old version may no longer be fully functional. The Company will not warrant security, full functionality or the ability to provide corresponding customer service for the old software after a new version is released. Please check for and download the latest version of ViaWallet, which may be released at any time.

  • 2.Usage

    1.You are responsible for the safekeeping of your mobile device, Wallet PIN, Private Key, Mnemonic Phrase and Keystore. The Company is not responsible for the safekeeping the above data for you. You are solely responsible for any risks, liabilities, losses, and expenses incurred as a result of the loss of your mobile device or hardware wallet, active or passive disclosure of data, forgotten Wallet PIN, Private Keys, Mnemonics Phrase, Keystore or loss from attacks, fraud, etc.

    2. ViaWallet Information Guide. You understand and agree to abide by the Information Guide issued by the Company on ViaWallet and to comply with the instructions of the Information Guide; otherwise, you shall bear all risks and resulting liabilities, losses, expenses, etc.

    3. Third party services. You understand and acknowledge that ViaWallet is not obligated to perform due diligence review of third party services and you have carefully evaluated and assumed all risks associated with the use of ViaWallet.

    4. Provide information and documentation. If the Company believes that it is necessary to obtain relevant information to comply with any applicable laws or regulations related to the use or operation of ViaWallet, you must provide such information to the Company in a timely manner in accordance with the requirements of the Company, and you understand and acknowledge that the Company may limit, suspend or terminate your use of ViaWallet until you provide information that meets the Company’s requirements. You undertake to notify the Company promptly of any change in the documents and information you provide to the Company pursuant to this Agreement, and in the absence of any written notice of the change, the Company has the right to consider the documents you have already provided and the content of such information as true, correct, and not misleading and unchanged.

    5. Completion of authentication. When the Company reasonably believes that your trading behavior or trading situation is abnormal, or that veracity of your Personal Information as provided is suspect, or if the Company requires that you confirm submitted identity documents or other necessary documents, you must affirmatively cooperate with the Company to confirm validity of identity card or other necessary documents to complete the authentication process in a timely manner.

    6. Transfers.

    (1) You are aware that the daily transfer limit and number of transactions you can use in the ViaWallet service may vary depending on the country in which you use the transfer service, regulatory requirements, transfer purposes, ViaWallet risk control requirements, authentication, and for other reasons.

    (2) You understand the “irrevocable” attribute of blockchain operations. When you use the ViaWallet transfer function, you are responsible for the consequences of any mistakes (including but not limited to, inputting the wrong transfer address, issues with the transfer node server you select).

    (3) You understand that when using the ViaWallet service, the following conditions may result in the transfer function not being available, the transfer "transaction failed" or "package timeout":

    a) insufficient wallet balance;

    b) insufficient transaction mining fees;

    c) blockchain smart contract execution code failure;

    d) limitation of amount of payment required by regulatory authorities, ViaWallet or laws and regulations;

    e) technical failures, such as networks and equipment malfunction;

    f) blockchain network congestion, malfunction, etc., which caused the transaction to be abandoned;

    g) your address or counterparty address identified as a special address, such as a high-risk address;

    h) other unexpected reasons.

  • (4) You understand that ViaWallet is only a transfer tool. After a transfer is completed, the Company has fulfilled all its obligations for the current transfer. The Company does not assume any other responsibility for such transfer.

    7.Legal compliance. You understand that you must comply with the requirements of relevant laws and regulations and national policies when using ViaWallet.

    8.Notice and announcements. ViaWallet will send you notifications by means of website announcements, emails, text messages, phone calls, Message Center messages, pop-up reminders or client notifications, such as messages to inform you of the progress of a transaction or to guide you to carry out a needed action, so please pay timely attention to such messages.

    9.Service fees and taxation.

    • (1) The Company will not charge you any service or handling fees for the time being, and the Company will separately notify you or publish an announcement when it decides to charge for certain services in the future.
    • (2) You will pay “miner fee” or network fee when you use ViaWallet for transfers. The amount is at your discretion and is collected by the blockchain network.
    • (3) You acknowledge that your transfer may fail under certain circumstances (including but not limited to, insufficient “mining fee” or network fee paid for the transfer, or instability of the relevant blockchain network); in such cases, even if your transfer is not completed, you will be charged a miner fee by the blockchain network.
    • (4) You are responsible for all tax and other expenses incurred as a result of trading on ViaWallet.

4.Notice of Risk

  • 1. You understand and acknowledge that because laws, regulations and policies in the field of digital tokens have not yet settled, significant risks exist, such as inability to realize cash and technical instability. You also understand that price volatility of digital tokens is much higher than other financial assets. We caution you to hold or dispose of digital tokens in a reasonable manner based on your financial situation and risk tolerance. You also understand that the price quote function provided by ViaWallet is only a search result of digital token exchange rate information from some exchanges, and does not indicate the latest market or best offer price.

    2. When using the Service, if you or your counter party fails to comply with instructions or rules stated in this Agreement or related website page descriptions regarding transaction or payment, the Company cannot guarantee completion of transactions and the Company shall not be responsibility for any resulting damages. In the event that the foregoing occurs but funds have been credited to your or your counterparty’s ViaWallet wallet or third-party wallet, due to the “irreversible” nature of blockchain operation and the “non-cancellable” characteristics of transactions, you and your counterparty shall bear any corresponding consequences.

    3. When you use third-party services through ViaWallet, we strongly recommend that you carefully read their user agreements, privacy policies and other related documents and information of such third-party service providers, to understand the transaction mechanics and product information, and carefully assess risks before you trade on such third party platform. You understand that in a transaction, binding contractual relationship established is between you and your counterpart and not with the Company. The Company does not assume any responsibility for any risks, liabilities, losses and expenses caused by trading activities.

    4. When you transfer digital tokens to another wallet addresses, you should judge whether the other party has full legal capacity and decide whether to trade with or transfer money to such other party.

    5. During the transfer process, if you receive notice such as “transaction failure”, “package timeout”, or other similar notice, you should reconfirm your transaction status with the official channel of the relevant blockchain system or through other blockchain query tools, to avoid double transfers; all resulting losses and expenses shall be borne by you.

    6. You understand that when you create or import a wallet on ViaWallet, your Keystore, Private Key, Mnemonic Phrase, etc. are only stored on the current mobile device and are not stored on ViaWallet or our servers. You can change your mobile device by syncing your wallet according to the instructions provided by ViaWallet. However, if you do not save or back up your Wallet PIN, Private Key, Mnemonic Phrase, Keystore, etc. and your mobile device becomes lost, your Digital Tokens will be lost and we will not be able to retrieve them for you. If you are exporting, saving or backing up your Wallet PIN, Private Key, Mnemonic Phrase, Keystore, etc., or if the device or server that saved or backed up the above information is hacked or controlled by a hacker, and your Digital Tokens are lost as a result, the Company cannot help you recover them. Any and all losses arising from the foregoing shall be borne by you.

    7. We recommend that you make a secure backup of your Wallet PIN, Private Key, Mnemonic Phrase, and Keystore when creating or importing your wallet. We suggest that you do not use the following electronic backup methods: screenshots, emails, notepad applications in mobile phones, SMS, WeChat, QQ and other electronic backup methods. We recommend that you copy information such as Mnemonics Phrase and Keystore in a paper notebook and you can also keep your electronic data in the password manager.

    8. We recommend that you use ViaWallet in a secure network environment to ensure that your mobile device is not jailbroken or rooted to minimize potential security risks.

    9. When you use ViaWallet, please be aware of fraudulent activities. Upon encountering any suspicious behavior, we encourage you to notify us as soon as possible.

5.Disclaimer and Limitation of Liability

  • 1. You understand and agree that the Company may, at its sole discretion, temporarily stop provision of some Services, suspend or terminate Services or open new service functions in the future. When we change our Services, as long as you still use ViaWallet, you are agreeing to the terms of this Agreement or the Agreement as revised.

    2. To avoid or minimize security failure or misuse of ViaWallet or Digital Tokens, you should not use ViaWallet without having basic knowledge of how blockchains work. For users who do not have such basic knowledge of blockchain, the Company reserves the right to refuse provision of some or all of its Services.

    3. You acknowledge that the Company will suspend Services (or terminate Services completely) due to:

    • (1) technical reasons such as equipment malfunctions; blockchain system maintenance, upgrades, or failures; or communication interruptions;
    • (2) force majeure events such as typhoon, earthquake, tsunami, flood, power outage, war or terrorist attack, computer viruses, Trojans, hackers, system instability or government actions, etc., so that the Company cannot reasonably provide Services or continuing to provide Services if such would present greater risk to the Company;
    • (3) material adverse change in the applicable law or policy;
    • (4) maintenance or upgrade of the ViaWallet system or when the system is down;
    • (5) malfunctioning of hardware and software of your mobile device and the communication line and power supply line;
    • (6) use of the Company’s Services improperly or without the authorization or approval of the Company;
    • (7) computer viruses, Trojans, malicious program attacks, network congestion, system instability, system or equipment failure, communication failures, power failures, banking or government actions, etc.;
    • (8) system lag, unstable blockchain system, etc., causing the Company’s transaction records on the blockchain to be distorted;
    • (9) any other reason not caused by the Company;
    • (10) other circumstances beyond the Company’s control or are reasonably unforeseeable.

    4.The Company may unilaterally suspend or terminate some or all of the Services to ViaWallet when a User:

    • (1) dies;
    • (2) steal other people’s wallet information or mobile devices;
    • (3) provide false Personal Information in ViaWallet;
    • (4) reject required ViaWallet updates;
    • (5) use ViaWallet for illegal or criminal activities;
    • (6) deny access to other Users from using ViaWallet;
    • (7) make false claims against the staff or management of the Company;
    • (8) attack, invade, alter, or otherwise threaten the proper functioning of the Company’s computer systems;
    • (9) promote spam ads using ViaWallet;
    • (10) spread rumors that damage the goodwill of the Company and ViaWallet;
    • (11) engage in illegal activities, breaches of this Agreement, and in situations where the Company reasonably believes that Services should be suspended;
    • (12) lose Digital Tokens due to insufficient knowledge of blockchain technology. 。

    5.If the Company changes, discontinues or terminates the Services, you have the right to export information such as your wallet within a reasonable time.

6.Your Representations and Warranties

1. You agree to abide by the laws and regulations of the country or jurisdiction in which you live, and you must not use ViaWallet for any illegal purpose or in any illegal way.

2. You are not an Excluded Person who is not eligible to use the ViaWallet Services.

3. You may not use ViaWallet to engage in any illegal or criminal conduct, including but not limited to:

  • (1) endangering national security in the country or jurisdiction where you live, leaking state secrets, subverting state power, and undermining national unity;
  • (2) engage in any criminal activity, including but not limited to, money laundering, illegal fund raising, or similar financial misfeasance;
  • (3) interfere or attempt to interfere by using an automated program, software, engine, web crawler, web analytics tool, data mining tool, or similar tool to access the Company's Services, collect or process content provided by the Company or other Users;
  • (4) provide gambling information or inducing others to participate in gambling in any way;
  • (5) use ViaWallet to invade other people’s wallet to steal digital tokens;
  • (6) conduct transaction that is inconsistent with the transaction content claimed by the counterparty, or engage in fake transactions;
  • (7) engage in any infringement or possible violation of the ViaWallet service system and data;
  • (8) other acts that the Company may reasonably consider inappropriate.

4. You understand and agree that if you breach relevant laws (including but not limited to, customs and / or tax regulations) or the provisions of this Agreement resulting in the Company suffering loss, claims by any third party or any administrative department penalties, you shall compensate the Company for such loss and expenses, including reasonable legal advisors fees.

5. You promise to pay the Company’s service fees (if any) on time, otherwise the Company has the right to suspend Services provided to you.

7.Privacy Policy

Any data or information you provide to us is also subject to our ViaWallet Privacy Policy (“Privacy Policy”), which is also part of this Agreement.

8.Other terms

1. No assignment. Subject to the terms of this Agreement, only you personally (and no others) have the right to make claims against us for use of the Services. There is no third party beneficiary to this Agreement. You may not assign, transfer, or attempt to assign or transfer your rights to make claims. Any such transfer is void and we do not assume any obligation or liability to the transferee.

2. Intellectual Property Rights. ViaWallet is an application developed and owned by the Company. The intellectual property rights to any content displayed in ViaWallet, including this Agreement, announcements, articles, videos, audio, images, archives, information, materials, trademarks or logos, are owned by the Company or third party rights holders. Users may only use the ViaWallet application and its contents for the purpose of holding and managing Digital Tokens. You may not use, modify, reverse compile, reproduce, publicly transmit, alter, distribute, issue or publicly publish such applications without the prior written consent of the Company or the consent of third party rights holders (or as permitted by the relevant open source agreement) and content providers (including ViaWallet open source code). This Agreement shall not be deemed to grant you any intellectual property rights, including any right to use any information, images, user interface, logo, trademark, trade name, network domain name or copyright in connection with us or the Services for any purpose.

3. Non-waiver. Any failure by us to enforce this Agreement or to present a claim against you, shall in no way affect our rights, claims or cause of action under this Agreement which shall not be deemed a waiver of our right to make any right, claim or cause of action against you.

4. Entire Agreement.

(1) This Agreement consists of this Agreement, the ViaWallet Privacy Policy and the rules published by the Company from time to time (including the contents of the Message Center).

(2) In addition to the ViaWallet Service Agreement and the ViaWallet Privacy Policy, this Agreement contains the entire agreement and understanding between us regarding the use of ViaWallet and related services and supersedes all previous (verbal and written) agreements, understandings or arrangements.


(1) Use of the Services under this Agreement does not cover any taxes or related charges that may apply or is generated in any jurisdiction where you use the Service (“Tax Payable”).

(2) You are responsible for determining any Tax Payable and reporting, withholding, collecting, reporting and paying the correct amount of Tax Payable to the appropriate tax authorities. You are solely responsible for all penalties, claims, fines, charges and other liabilities arising from your failure to complete or fulfill any of your taxable obligations.

(3) We are not responsible for determining any Tax Payable or reporting, withholding, collecting, reporting and paying the correct Tax Payable to the appropriate tax authorities.

6. This Agreement is governed and construed by the laws of [Hong Kong].

7. Severability

(1) When any part of this Agreement is deemed to be invalid, illegal or unenforceable by any legislation or law that binds this Agreement, it shall be deemed invalid, illegal or unenforceable only within that scope (and shall not be further extended). For the avoidance of doubt, the remainder of this Agreement will remain in force and remain in full force and effect.

(2) Under the laws of any relevant jurisdiction, any provision of this Agreement that is deemed to be illegal, invalid or unenforceable shall not affect the fact that the provision is deemed to be lawful, valid or enforceable under the laws of other jurisdictions, and shall not affect the legality, validity or enforceability of other provisions of this Agreement.

8. Translation of this Agreement. Any translation of this Agreement, if any, is provided for convenience only and is not intended to modify the English language version of this Agreement. In the event of a conflict between the English and non-English versions of this Agreement, the English version shall prevail.


1. You should fully understand and comply with all relevant laws, rules and regulations in your jurisdiction and use of Services.

2. If you encounter any problems while using the Service, you can contact us by submitting feedback in ViaWallet.

3. All Users can view this Agreement in ViaWallet. The Company encourages you to review this Agreement each time you visit ViaWallet.

4. This Agreement is effective as of May 10, 2019.

Matters not covered in this Agreement, are subjected to the announcements and related rules that the Company updates from time to time.

ViaBTC Technology LTD.

(Company registration number:68073584-000-08-18-0)

ViaWallet Privacy Policy

Last update : May 10, 2019

Dear User :

ViaBTC Technology LTD. (hereinafter referred to as the “Company” or “we”) respects and protects the privacy of our users (hereinafter referred to as “you” or “User”). The Company collects, discloses and processes your personal information in accordance with this Privacy Policy (hereinafter referred to as this “Policy”) when you:

(a) enter or use our website or mobile app (“Apps”) and use our services;

(b) provide us with your personal information, regardless of the medium used.

We recommend that you carefully read and understand the entire content of this Policy before using the Apps. Important information such as disclaimers and other terms will be reflected in bold format. The definition of keywords in this Policy is consistent with the Company’s “ViaWallet Service Agreement”. In the event of any inconsistency between the definitions or terms used in this Policy and ViaWallet Service Agreement, this Policy shall prevail.

By providing us with your personal information, you consent to the collection, use, disclosure (including transmission) and processing of your personal information in accordance with the provisions of this Policy. If you do not accept this Policy, please do not provide us with any personal information.

This Policy may be updated by the Company online at any time without notice. The updated Policy is effective as soon as it is published on our platform and replaces the original Policy. The updated Policy will immediately apply to personal information you provide to us. If you do not accept the revised terms, please stop using the Apps immediately and your continued use of the Apps will be considered acceptance of the revised Policy.

1.What information do we collect from you?

1. We will collect information such as your mobile device information, operation history, transaction history, wallet address, etc.

2. To meet your specific service needs, we will collect your personal information, including but not limited to your name, bank card number, mobile number, email address and other information.

3. You know that your wallet password, private key, mnemonic phrase, and Keystore are not stored or synced to our server. The Company cannot retrieve your wallet password, private key, mnemonic phrase, and Keystore (an encrypted formatted file of your private key or mnemonic phrase saved by your password). Keystore is only stored on your mobile device and is not be synchronized to the Company’s servers.

4. We may ask you to provide more personal information so that you can use certain features on our App. If you do not agree to provide such personal information, you are deemed to have waived the specific features of the App.

5. To the extent required by law and regulation, the Company may collect and use your personal information in the following circumstances without your consent or authorization:

  • (1) national security and national defense security;
  • (2) public safety, public health, and major public interests;
  • (3) criminal investigation, prosecution, trial and execution of judgments;
  • (4) personal information collected in the public domain;
  • (5) personal information collected from legally publicly disclosed information medium, such as legitimate news reports, government information disclosure, etc.;
  • (6) maintenance of security and compliance of the service, such as the discovery and handling of faults in products and services;
  • (7) other circumstances permitted by laws and regulations.

6. We collect information when you:

  • (1) take the initiative to provide us with information for whatever reason;
  • (2) authorize us to obtain your information from a third party;
  • (3) use our applications and services;
  • (4) contact or interact with our employees through various communication channels, such as through social platforms, communication platforms, face-to-face meetings, telephone calls, emails, faxes, and letters;
  • (5) enter into a transaction through us, contact us or ask us to contact you;
  • (6) request to subscribe to our mail;
  • (7) engage in a transaction through the blockchain system, we will copy your transaction history; however, we only copy the transaction history as available in the blockchain system.

7. Our Apps may contain some techniques for collecting personal information, and the specific collection methods is described in this Policy (see Article 5 below) or our applicable terms and conditions.

8. Providing personal information is your choice and you can withdraw your consent at any time. However, if you decide not to provide us with the personal information we request, you may not be able to use the App and we may not be able to contact you or provide you with the products or services you need.

9. In some cases, you may provide us with personal information that is not your own. If you provide information about others, you should ensure that you have obtained the consent of the person whose information is provided to allow us to collect personal information about that person, and the person agrees to disclose personal information to us. You agree that if such person files a claim against us for the collection, use and disclosure of their personal information you provide, you will indemnify and defend us for all expenses and damages we may incur.

10. You should ensure that the personal information you provide to us is true, accurate and complete. You should notify us when your personal information changes.

2. How we use your information

We will collect, use or disclose your personal information for one or more of the following purposes:

(1) provide you with the products and / or services you request;

(2) handle your relationship with us;

(3) improve your user experience;

(4) through the unique serial number of your mobile device, confirm your exchange with your wallet;

(5) send you important notices, such as software updates, service agreements, and changes to the terms of this Policy;

(6) through your mobile device and wallet address, assist you with your questions, feedback, complaints and requests;

(7) inform you about our products, services, projects and activities;

(8) resolve disputes, if reasonable, investigate complaints, claims or disputes, or actual or possible illegal conduct;

(9) conduct internal audit, data analysis and research;

(10) perform user behavior analysis by tracking your usage of the application;

(11) comply with legal and regulatory requirements and with regulatory agencies;

(12) comply with international laws and regulations regarding safety and anti-money laundering or counter-terrorism requirements;

(13) fulfill our obligations and the terms of the ViaWallet Service Agreement;

(14) any reasonable purpose related to the foregoing purposes.

3. How do you control your information

You have the following rights to control your personal information in the App:

1. You can import other wallets into the App by syncing your wallet or import your App’s wallet into another digital token management wallet. The App will show you the information needed for importing the wallet.

2. You can modify your digital token type, transfer and collection activities through the “assets” section.

3. Please note that neither you nor we have control over disclosure of your transaction history due to the public nature of the blockchain trading system so such record is publicly available through the blockchain system.

4. Our App will contain links to other websites, apps or smart contracts that are not owned, operated, developed or maintained by us. These links are provided for your convenience. This Policy applies only to our applications. When you use third party services, please note that the ViaWallet Service Agreement and ViaWallet Privacy Policy will no longer apply. We recommend that before using them, you read and understand the privacy rules and related user service agreements of such third party service providers.

4. We may share or transfer your information

1. We will store your personal information for business and legal purposes.

2. We will not sell, assign, or transfer your personal information to third parties without your consent.

3. If you consent to the disclosure of your personal information to a strategic partner or related party, we may disclose your personal information to such entities. These entities will use your personal information only for the purposes for which you have agreed.

4. You agree that we may disclose or share your personal information with the following third parties:

(1) service providers and data processors who represent us and provide services to us for such services as “know your customer” reviews, accounting, data processing or management services, web hosting, maintenance and operations services, mail information services, analytical services, payment transaction processing, marketing, etc.;

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

5. For the purposes described above, we may need to transfer your personal information to another country, but we will obtain your consent and ensure that the recipient of the personal information has the same level of personal information protection as ours. If there is no personal information protection law applicable in these countries or jurisdictions with legal protection standards similar to those in our relationship with you, we will enter into a legally enforceable agreement with the recipient of the personal information to provide such level of protection.

6. We will not share or transfer your personal information to any third party without your prior consent, except in the following cases:

(1) personal information collected is disclosed to the public by yourself;

(2) personal information collected is collected from legally publicly disclosed information media, such as legitimate news reports, government information disclosure, etc.;

(3) providing or enforcing this Policy to protect our rights, property or safety or those of other parties in accordance with applicable laws and regulations, legal procedures, administrative or judicial requirements;

(4) in the case of merger and acquisition of our Company, if the transfer of personal information is involved, the Company will require the recipient of the personal information to continue to be bound by this policy

5.How we protect your information

1. If the Company ceases to operate, the Company will stop collecting your personal information and activities and within a reasonable period of time will take measures to delete or anonymize your personal information held.

2. In order to protect your personal information, the Company will adopt data security technical measures to improve internal compliance, increase internal employee information security training, and secure access to relevant data to protect your private information.

3. We will use our ViaWallet Message Center to send you messages about safe communications and from time to time, provide wallet usage updates and security measure information through our ViaWallet Help Center for your reference.

6. Disclaimer

1. You acknowledge that upon your using third party services, this Policy will not apply to the collection, use, disclosure and transmission of your personal information by such third parties. The Company cannot assure you that such third parties will take appropriate security measures.

2. You are solely responsible for the use of third party services and you agree that if the third party collects, uses, discloses and transmits your personal information, resulting in loss or damage to you, the Company will not be liable to you for any resulting loss, damages, or expenses.

3. You acknowledge and accept that, to the full extent permitted by applicable law, the Company does not guarantee security for your personal information. As far as is practicable, the Company will endeavor to use state of the art security measures on an “as is”, “as available” and “no guarantee” basis to protect your personal information from disclosure, tampering or damage. However, the Company uses wireless transmission of data and cannot assure privacy and security of data transfer over a wireless network.

7.Other terms

1. You need to fully understand and comply with all relevant laws, rules and regulations in your jurisdiction as well as those laws, rules and regulations governing our Company.

2. This policy applies to Hong Kong law and should be interpreted accordingly.

3. You can view this Policy and our other service rules in our App. We encourage you to review our service agreements and privacy policy each time you access the App.

4. Any translation of this Policy is provided for convenience only and is not intended modify the terms of this Policy. In the event of a conflict between the English and non-English versions of this Policy, the English version shall prevail.

5. This Policy shall become effective on May 10, 2019.

This Policy is developing and you are subject to the announcements and related updated rules that the Company issues from time to time.

ViaBTC Technology LTD.

(Company registration number:68073584-000-08-18-0)