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5-Privacy Policy

[Introduction and Tips]​

Dx Studio. (hereinafter referred to as the "Company") is a company incorporated in the Kingdom of Thailand in accordance with the relevant laws of the Kingdom of Thailand. The company operates MINPAY (hereinafter referred to as the "Platform" or "Platform"), which is a platform specifically for users to conduct digital asset transactions and provide related services (hereinafter referred to as the "Service" or "Service"). For the convenience of presentation, the company and the platform are collectively referred to as "we" or other first-person pronouns in this agreement. As long as the natural persons or other entities logging in to the platform are users of the platform, "you" or other second-person pronouns are used below. We and you are collectively referred to as "both parties", and we or you are individually referred to as "a party".

We fully understand and respect the importance of your personal information to you, and we will take appropriate security protection measures in accordance with legal and regulatory requirements to protect the security of your personal information. In view of this, we have formulated this Privacy Policy (hereinafter referred to as "this policy/this privacy policy") and remind you:

This policy applies to all products and services we provide. If the products or services we provide you have a separate privacy policy, the separate privacy policy shall apply to that product or service; if our products or services do not have a separate privacy policy, this policy shall apply.

It should be noted that this policy does not apply to services provided to you by other third parties. The services provided to you by third parties are subject to their privacy policies separately explained to you.

Before using our products or services, please be sure to carefully read and thoroughly understand this policy, especially the terms marked in bold/bold underline. You should read them carefully and confirm that you fully understand and agree before you start using it. If you have any questions, comments or suggestions about the content of this policy, you can contact us through the various contact methods provided by our official website. If you do not agree to any terms in this policy, you should immediately stop accessing this platform.

Part 1 Definition​

Personal information: refers to various information recorded electronically or in other ways that can identify a specific natural person alone or in combination with other information or reflect the activities of a specific natural person.

Personal sensitive information: refers to personal information including ID number, personal biometric information, bank account number, property information, whereabouts, transaction information, information of children under 14 years old (inclusive), etc. (We will prominently identify specific personal sensitive information in bold in this privacy policy).

Personal information deletion: refers to the act of removing personal information from systems involved in realizing daily business functions, so that it remains in a state that cannot be retrieved or accessed.

Children: refers to minors under the age of fourteen.

Part 2 Privacy Policy​
This privacy policy section will help you understand the following:​

1. How we collect and use your information

2. How we use cookies and similar technologies

3. How we share, transfer and publicly disclose your information

4. How we protect your information

5. How do you manage your information

6. How we handle minors’ information

7. How to update this privacy policy

8. How to contact us

1. How we collect and use your information​

When you use our products and/or services, the personal information we need/may need to collect and use includes the following two types:

  1. In order to provide you with the basic functions of our products and/or services, you must authorize us to collect and use the necessary information. If you refuse to provide corresponding information, you will not be able to use our products and/or services normally;

  2. In order to provide you with additional functions of our products and/or services, you may choose to authorize us to collect and use the information. If you refuse to provide it, you will not be able to use the relevant additional functions normally or achieve the functional effects we intend to achieve, but it will not affect your normal use of the basic functions of our products and/or services.

You understand and agree:

  1. We are committed to creating a variety of products and services to meet your needs. Because we provide you with many types of products and services, and the scope of specific products/services that different users choose to use is different, accordingly, the basic/additional functions and the type and scope of personal information collected and used will be different. Please refer to the specific product/service functions;

  2. In order to bring you a better product and service experience, we continue to work hard to improve our technology. As a result, we may launch new or optimized functions from time to time, and may need to collect and use new personal information or change the purpose or method of using personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this policy, pop-up windows, page prompts, etc., and provide you with a way to choose your consent, and collect and use it after obtaining your express consent. During this process, if you have any questions, comments or suggestions, you can contact us through the various contact methods provided on this platform, and we will answer you as soon as possible.

We will collect and use your personal information to implement the functions described below in this policy:

(1) Help you register and provide you with the services provided by this platform;

  1. Registration service

We provide you with basic membership services through this platform account. In order to register as a member and use our membership services, you need to fill in and provide the following information when applying for registration:

(1) Identity information. This information can help us verify whether you are eligible to register as a member of this platform, including but not limited to your name, your residential address, other different certificates issued by your country or government that prove your identity information, as well as the involved numbers and all other information that can help us verify your identity (hereinafter collectively referred to as "identity information"). This identity information varies depending on whether you are an individual user or an institutional user. According to the laws and regulations of different jurisdictions, the information we collect for users from different countries or regions may be different. The following information and data serve as an indicative example:

Individual users: nationality, full legal name (including previous names and names in local languages), identification number, email address, phone number, social security number ("SSN"), passport number or any government-issued identification number, date of birth, proof of identity (such as a passport, driver's license, or government-issued identification).

Institutional users: company legal name (including legal name in local language), registration information, business phone number, authorized representative and authorized user personal information, principal place of business, personal information of all beneficial owners), identification documents of shareholders/beneficial owners (passport or government-issued ID card), company structure, company establishment-related documents, board of directors resolutions, declaration of funding sources, risk and compliance control statements and other information or documents required by the platform.

(2) Service information. This information helps us contact you and smoothly provide you with different modes of digital asset trading services, including but not limited to your personal identity information, contact information, transaction information, and your debit card information and/or other account information (hereinafter collectively referred to as "service information"). At the same time, please understand that the services we provide you are constantly updated and developed. If you choose to use other services not covered by the above description, and we need to collect additional information about you based on this service, we will explain the scope and purpose of information collection to you through page prompts, interaction processes, agreement stipulations, pop-up prompts, etc., and obtain your consent.

If you only want to use the browsing service, you do not need to register as our member and provide the above information.

  1. Other registration services

Real-name authentication: After you register and log in, you need to enter the "Personal Center" to complete the real-name authentication in the identity authentication process. You need to provide your real name, ID number or passport number to the platform during the process of using real-name authentication.

Advanced authentication: When your transaction volume on this platform exceeds a certain limit, the platform will require you to undergo advanced authentication in order to maintain the security of your assets. In addition to the real-name authentication information during the authentication process, you agree that the platform will conduct advanced authentication of "face recognition" on you. Face recognition will involve the platform's collection of your relevant video streams or face images.

Account information display: If you already have an account on this platform, we may display your above personal information in the service (real-name authentication only displays the results of whether the authentication is passed), as well as the operations you perform in the products and services associated with the platform account, including centralized display of your personal information and transaction orders through this platform account. We will respect the choices you make regarding platform account settings.

(2) Security management services and service information push services

When you use the services provided by this platform or visit this platform, in order to ensure the security of your transaction and the safe and stable operation of the service, this platform needs to automatically receive and record your web browser information, the device type, model version and other device identification symbols used to log in to your account, the IP address and record on the web page you requested to access, the region, network environment, device fingerprint information, service log information, software information, location information, etc.

Please note that device information alone is information that does not identify a specific natural person. If we combine this type of non-personal information with other information to identify a specific natural person, or use it in combination with personal information, then during the combined use period, this type of non-personal information will be treated as personal information. Unless we obtain your authorization or otherwise require laws and regulations, we will anonymize and de-identify this type of information.

In order to provide you with information display and push services that are more convenient and more in line with your personalized needs, in the future we may extract your preference characteristics based on your device information and your browsing usage information on this platform or client, and generate indirect crowd portraits based on feature tags for display, push information and possible commercial advertisements. If you do not agree to receive such push information or withdraw your consent to the collection of personal information, you can contact us according to the contact information provided in this policy.

We work hard to ensure your browsing experience. If you do not want to accept the commercial advertisements we send you, you can unsubscribe or close by replying to the text message prompt or other methods we provide.

In addition, we will also use your above information in order to continuously improve and optimize the above functions.

(3) Transaction record storage and inquiry services

The relevant data we collect regarding your transactions on this platform, including but not limited to transaction records. If you need to check your order transaction records, you can check your personal transaction details in the "Order Management" of the platform, including: counterparty nickname, order time, order number, transaction information, digital asset type and quantity, etc.

(4) Customer service and dispute resolution

When you contact us or submit an application for sale or dispute resolution, in order to protect the security of your account and system, we need you to provide necessary personal information to verify your membership status.

In order to facilitate contact with you, help you solve the problem as soon as possible, or record the solutions and results of related problems, we may save the communication records and related content between you and us (including account information, order information, other information you provide to prove relevant facts, or the contact information you left). If you make inquiries, complaints or provide suggestions for a specific order, we will use your account information and order information.

In order to reasonably need to provide services and improve service quality, we may also use other information about you, including the relevant information you provide when you contact customer service, and the questionnaire response information you send to us when you participate in the questionnaire.

(5) Others

  1. If the information you provide contains the personal information of other users, you must ensure that you have obtained legal authorization before providing such personal information to this platform. If it involves children's personal information, you need to obtain the consent of the corresponding child's guardian before publishing. In the above circumstances, the guardian has the right to contact us through Article 9 of this policy to request correction or deletion of the content involving children's personal information.

  2. If we use information for other purposes not specified in this policy, or if we use information collected for specific purposes for other purposes, or if we proactively obtain your personal information from a third party, we will obtain your consent in advance.

If we obtain your information indirectly from a third party, we will clearly request in writing before collection that the third party collect personal information after obtaining your consent in accordance with the law and inform you of the content of the shared information, and any sensitive information will require your explicit confirmation before it is provided to us for use. The third party promises the legality and compliance of the source of personal information. If the third party commits any violation, we will clearly require the other party to bear corresponding legal responsibilities; at the same time, we will strengthen the security of personal information (including sensitive information reporting, encrypted storage of sensitive information, access control, etc.). We will use no less protective means and measures than we use for our own users' personal information to protect indirectly obtained personal information.

  1. Exceptions with authorization and consent

You fully understand and agree that our collection and use of your personal information does not require your authorization and consent under the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, withdrawal of consent, or request for information:

(1) Related to national security and national defense security;

(2) Relevant to public security, public health, and major public interests;

(3) Relevant to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and judgment execution;

(4) To protect your or other individuals’ life, property and other major legitimate rights and interests but it is difficult to obtain your consent;

(5) Personal information that you disclose to the public on your own;

(6) Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

(7) Necessary to sign and perform relevant agreements or other written documents with you;

(8) Necessary to maintain the safe and stable operation of the products and/or services provided, such as discovering and handling product and/or service failures;

(9) Necessary for legitimate news reporting;

(10) When it is necessary for an academic research institution to conduct statistical or academic research based on public interests, and when providing the results of academic research or description to the outside world, the personal information contained in the results will be de-identified;

(11) Other situations stipulated by laws and regulations.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot recover, or we may conduct de-identified research, statistical analysis and prediction on the collected information to improve the content and layout of this platform, provide product or service support for business decisions, and improve our products and services (including using anonymous data for machine learning or model algorithm training), then the use of such processed data does not require separate notification to you and your consent.

  1. If we stop operating the products or services of this platform, we will promptly stop collecting your personal information, notify you of the cessation of operations in the form of one-by-one delivery or announcements, and delete or anonymize the personal information we hold related to the closed business.
2. How we use Cookies​

If your browser or browser add-ons allow it, you can modify your acceptance of cookies or reject our cookies. See AboutCookies.org for details. However, if you do so, in some cases it may affect your safe access to our platform and may require you to change user settings each time you visit our platform. You understand and agree:

  1. When you visit our platform, we use Google Stats through cookies to record our performance and check the effectiveness of online advertising. A cookie is a small amount of data that is sent to your browser and stored on your computer's hard drive. Cookies can only be sent to your computer's hard drive when you use your computer to enter our platform.

  2. Cookies are often used to record the habits and preferences of visitors when browsing various items on our platform. The information collected by cookies is anonymous collective statistical data and does not contain personal information.

  3. Cookies cannot be used to obtain data on your hard drive, your email address, and your private data. They can enable this platform or the service provider system to recognize your browser and capture and remember information. Most browsers are preset to accept cookies. You can choose to set your browser not to accept cookies, or to notify you if cookies are placed. However, if you set it to disable cookies, you may not be able to activate or use certain features of our platform.

3. How we share, transfer and publicly disclose your information​

(1) Sharing

We will not share your personal information with companies, organizations and individuals other than the service providers of this platform, except in the following circumstances:

  1. Sharing under legal circumstances: We may share your personal information externally in accordance with laws and regulations, litigation, dispute resolution needs, or as required by administrative and judicial authorities in accordance with the law.

  2. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

  3. Sharing when you actively choose: We will share the necessary transaction-related information in your order information with the counterparty of digital assets based on your choice to meet your transaction and after-sales service needs.

  4. Sharing with authorized partners: our affiliates, trusted third parties who help us operate our platform, conduct business, or provide services to you, as long as these parties agree to keep this information confidential; when we believe that the information disclosed is appropriate, is in compliance with laws, regulations, rules and regulations, or orders from courts or other competent authorities, implements our platform strategies, is needed for the normal operation of the platform, is required by affiliates to provide services or protect our or others' rights, property or safety.

(2) Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

  1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

  2. When a merger, acquisition, or bankruptcy liquidation occurs on this platform, or other situations involving mergers, acquisitions, or bankruptcy liquidation, if personal information is transferred, we will require the new company or organization that holds your personal information to continue to be bound by this policy, otherwise we will require the company, organization, or individual to re-solicit your authorization and consent.

(3) Public disclosure

We will only publicly disclose your personal information under the following circumstances:

  1. We may publicly disclose your personal information with your explicit consent or based on your active choice;

  2. If we determine that you have violated laws and regulations or seriously violated the relevant agreements and rules of this platform, or to protect the personal and property safety of users of this platform or the public from infringement, we may disclose your personal information in accordance with laws and regulations or with your consent, including relevant violations and the measures that this platform has taken against you.

(4) Exceptions to obtaining prior authorization and consent when sharing, transferring, or publicly disclosing personal information

In the following circumstances, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent:

  1. Relevant to national security and national defense security;

  2. Relevant to public safety, public health, and major public interests;

  3. Relevant to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and judgment execution;

  4. To protect your or other individuals’ life, property and other major legitimate rights and interests but it is difficult to obtain your consent;

  5. Personal information that you disclose to the public on your own;

  6. Collect personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot recover it, the sharing, transfer, and public disclosure of such processed data do not require separate notification to you and your consent.

4. How we protect your information​
  1. We implement appropriate physical, electronic, managerial and technical measures to protect and ensure the security of your personal information. We strive to ensure that any personal information collected through our platform is free from interference by any third parties not related to us. The security measures we take include but are not limited to:

(1) Physical measures: Records containing your personal information will be stored in a locked place.

(2) Electronic measures: Computer data containing your personal information will be stored on computer systems and storage media subject to strict login restrictions.

(3) Management measures: We have established internal departments to protect the security of user information, and have established relevant internal control systems. We adopt strict authorization principles for staff who may have access to your information. Only staff authorized by us can access your personal information. These staff need to abide by our internal rules for keeping personal information confidential. In addition, we continue to train our staff on relevant laws and regulations, privacy and security guidelines, and strengthen security awareness, and regularly organize emergency response training and emergency drills for relevant internal personnel to master their job responsibilities and emergency response strategies and procedures.

(4) Technical measures: Encryption technology such as Secure Socket Layer Encryption may be used to transmit your personal data.

(5) Security measures: To ensure the security of your information, we are committed to using a variety of current and common security technologies and supporting management systems to minimize the risk of your information being leaked, damaged, misused, unauthorized accessed, disclosed and altered. For example: encrypted transmission through network security layer software (SSL), encrypted information storage, and strictly restricted access to the data center. When transmitting and storing sensitive personal information (including personal biometric information), we will adopt security measures such as encryption, permission control, de-identification, and desensitization.

(6) Other measures: Regularly review our personal data collection, storage and processing procedures; and limit our employees and suppliers' access to your data based on necessary principles, and our employees and suppliers are required to abide by strict contractual confidentiality obligations. .

  1. If you know of any security vulnerabilities on our platform, please contact us immediately so that we can take appropriate action as soon as possible.

  2. Despite the implementation of the above technical and security measures, we cannot guarantee the absolute security of data transmission on the Internet, so we cannot absolutely guarantee that the personal data you provide to us through our platform will be safe at all times. We will update and disclose security risks, personal information security impact assessment reports and other relevant content from time to time, which you can obtain through announcements on this platform.

5. How do you manage your information?​

You can access and manage your information in the following ways:

(1) Query, correct and delete your information

You have the right to obtain a copy of your personal data upon request and to ensure that the information we hold about you is accurate and up to date. If any of your personal data is inaccurate, you can request that your information be updated. You can also request that your personal data be deleted, but we may deny your deletion request in certain circumstances, such as due to legal requirements or other legal purposes. For data access, correction or deletion requests, you may contact us via the contact details in Article 8.

In order to respond to a data access, correction or deletion request, we will verify the identity of the requesting party to ensure that he/she is legally entitled to make such request. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee if your request is repetitive or burdensome.

(2) Change the scope of your authorization and consent

Each business function requires some basic personal information to complete (see "Part 1" of this Privacy Policy). In addition, you can contact us through the contact information in Article 8 to give or withdraw your authorization and consent.

When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.

(3) Cancel your account

You can contact us through the contact information in Article 8 to apply for cancellation of your account; after you voluntarily cancel your account, we will stop providing products or services to you, delete or anonymize your personal information in accordance with the requirements of applicable laws.

(4) Respond to your above request

For security reasons, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We will respond within 15 days. If you are not satisfied, you can also initiate a complaint through the contact information we provide.

In principle, we do not charge fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain fee at our discretion. We may reject requests that are not directly related to your identity, duplicate information without reason, or require too many technical means (for example, requiring the development of a new system or fundamentally changing existing practices), posing risks to the legitimate rights and interests of others, or that are impractical.

In the following circumstances, we will not be able to respond to your request in accordance with legal and regulatory requirements:

  1. Relevant to national security and national defense security;

  2. Relevant to public safety, public health, and major public interests;

  3. Relevant to criminal investigation, prosecution, trial and execution of judgments;

  4. There is sufficient evidence that the personal information subject has subjective malice or abused his rights;

  5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

  6. Involving business secrets.

6. How we handle minors’ information​

This platform is open to children. If we discover or suspect that a user is under 14 years old, we will ask the user to close his or her account and will not allow the user to continue to use platform products or services. We will delete the relevant information as soon as possible. If you know of anyone under the age of 14 using our Services, please notify us so we can take action to prevent them from accessing our products or services.

For minors who are over 14 but not yet 18, we expect parents or guardians to direct the minor’s use of our Services. We will protect the confidentiality and security of minors' information in accordance with relevant laws and regulations.

If you are a minor, it is recommended that your parents or guardians read this policy and use our services or provide us with your information with the consent of your parents or guardians. For situations where we collect your information with the consent of your parents or guardians, we will only use or publicly disclose this information as permitted by law, with the express consent of your parents or guardians, or as necessary to protect your rights and interests. If your guardian does not agree with you using our services or providing information to us in accordance with this policy, please terminate your use of our services immediately and notify us in time so that we can take appropriate measures.

If you are the parent or guardian of a minor and you have questions about the processing of the information of the minor under your custody, please contact us through the contact information published in this policy.

7. How to update this privacy policy​

Our privacy policy may change.

We will not limit your rights under this Privacy Policy without your explicit consent. We will post any changes to the Privacy Policy on our official channels. If you do not agree with the revised content, you should stop accessing this platform immediately. When an updated version of the Privacy Policy is released, your continued access to this platform will display and indicate that you agree to the updated content and agree to abide by the updated Privacy Policy.

For major changes, we will also provide more prominent notifications (including notifications through public announcements on this platform or even providing you with pop-up reminders).

Major changes referred to in this policy include but are not limited to:

  1. Our service model has undergone major changes. Such as the purpose of processing personal information, the type of personal information processed, the use of personal information, etc.;

  2. We have major changes in control and other aspects. Such as changes in information controllers caused by mergers, acquisitions, reorganizations, etc.;

  3. The main objects to whom personal information is shared, transferred or publicly disclosed change;

  4. Significant changes in your rights to participate in the processing of personal information and how you exercise them;

  5. Our responsible departments, contact information and complaint channels for handling personal information security have changed;

  6. The personal information security impact assessment report indicates that there is a high risk.

8. How to contact us​

  1. If you have any requirements and comments, you can email s0932s520@hotmail.com. This is the only valid and official email we use to communicate with you, so we are not responsible for your failure to use valid contact information or any actions or inactions.

  2. We only publish announcements and information through valid contact information on this platform or post announcements on this platform, so we are not responsible for any losses caused by your trust in information not obtained through the above methods.

  3. If you have any questions about our privacy policy, please feel free to contact us.