Privacy Policy

1. Introduction

UnicornX ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our decentralized trading platform and related services (the "Service"), including our website, mobile application, chat functionality, wallet services, and on/off ramp services.

By using the Service, you consent to the data practices described in this Privacy Policy.

2. Information We Collect

• We collect information about you in various ways when you use our Service:

2.1 Personal Information

• Account Information: When you create an account, we collect information such as your username, email address, and any other information you provide during registration.

• Identity Verification: For compliance purposes, we may collect identity verification documents and information as required by applicable laws and regulations.

• Wallet Information: We collect wallet addresses and transaction data associated with your use of the Service through our wallet service provider, Turnkey Global, Inc., though we do not have access to your private keys.

2.2 Technical Information

• Device Information: We collect information about the device you use to access the Service, including hardware model, operating system, unique device identifiers, and mobile network information.

• Log Information: We automatically collect log information when you use the Service, including your IP address, browser type, referring/exit pages, and timestamps.

• Usage Data: We collect information about your interactions with the Service, including trading activity, features used, and time spent on the platform.

2.3 Chat Communication Data

When you use our chat functionality provided by Easemob Technologies, we may collect:

• Chat Messages: All messages sent and received through our chat system

• Chat Metadata: Information about when messages were sent, participants in conversations, and chat room activities

• User Interactions: Data about your participation in group chats, direct messages, and other communication features

• Moderation Data: Records of any content moderation actions taken on your chat activities

2.4 On/Off Ramp Transaction Data

When you use cryptocurrency deposit and withdrawal services provided by OSL Digital Securities, we may collect:

• Transaction Information: Details of deposits, withdrawals, and other on/off ramp transactions

• Account Data: Information about your accounts and transaction methods, though we do not store sensitive financial credentials

• Compliance Data: Information required for anti-money laundering (AML) and know-your-customer (KYC) compliance

Transaction History: Records of your on/off ramp activities and transaction status

2.5 Communication Data

• We may collect and store communications between you and UnicornX, including customer support inquiries and responses.

3. Purpose of Data Collection and Legal Basis

• We process your personal information for the following purposes and on the following legal bases:

3.1 Contract Performance

• Account Management: To create, maintain, and manage your account, including verifying your identity and providing customer support

• Service Provision: To facilitate and process transactions within the Service, including executing trades, managing wallet addresses, and processing deposits and withdrawals

• Chat Services: To provide and maintain chat functionality, ensure service quality, and enable communication between users

• On/Off Ramp Services: To facilitate cryptocurrency deposits, withdrawals, and related transaction processing

3.2 Legitimate Interests

• Communication: To communicate with you regarding your account, transactions, updates, and promotional materials, where permitted by law

• Improvement of Services: To analyze usage patterns and improve the functionality and user experience of the Service

• Security: To detect, prevent, and address technical issues, fraud, or other illegal activities

• Content Moderation: To monitor and moderate chat communications for safety and compliance purposes

• Compliance Monitoring: To ensure compliance with applicable laws and regulations regarding trading and payment processing

3.3 Legal Obligations

• Regulatory Compliance: To comply with applicable laws, regulations, and legal processes

• AML/KYC Requirements: To meet anti-money laundering and know-your-customer obligations

• Record Keeping: To maintain records as required by applicable financial regulations

3.4 Consent

Where required by law, we will process your personal information based on your explicit consent, which you may withdraw at any time.

4. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The duration of your relationship with UnicornX

• Legal obligations to retain data for certain periods

• Relevant statutes of limitations

• Ongoing or potential disputes or legal claims

• Chat Data: Chat messages and related metadata may be retained for up to [X] years for compliance and safety purposes

• Transaction Data: On/off ramp transaction and related data may be retained as required by applicable financial regulations

5. Data Sharing and Third-Party Services

• We may share your information in the following circumstances:

5.1 Third-Party Service Providers

We engage the following third-party service providers:

• Chat Services Provider:

• Easemob Technologies provides our chat functionality

• Chat data, including messages and metadata, may be processed and stored by Easemob Technologies

• Easemob Technologies has access to chat-related personal information only to perform chat services on our behalf

• Their use of your data is governed by their own privacy policies and our data processing agreements

Wallet Services Provider:

• Turnkey Global, Inc. provides our wallet services

• Wallet-related data, including wallet addresses and transaction metadata, may be processed by Turnkey Global, Inc.

• They have access to wallet-related information only to perform wallet services on our behalf

• Your private keys remain under your control and are not accessible to us or our service providers

• Their use of your data is governed by their privacy policies and our data processing agreements

On/Off Ramp Services Provider:

• OSL Digital Securities provides cryptocurrency deposit and withdrawal services

• Transaction data, compliance information, and related personal data may be processed by OSL Digital Securities

• They have access to transaction-related personal information only to perform on/off ramp services

• Their use of your data is governed by their privacy policies and applicable financial services regulations

Other Service Providers:

• We may engage other third-party service providers for hosting services, analytics, and customer support

• These providers have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose

5.2 Legal Requirements

• We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5.3 Business Transfers

In the event of a merger, acquisition, or asset sale, your personal information may be transferred as a business asset. We will notify you before your personal information is transferred and becomes subject to a different Privacy Policy.

5.4 Compliance and Safety

• We may share information when we believe it is necessary to:

• Comply with applicable laws and regulations

• Protect the safety and security of our users and the public

• Prevent fraud, money laundering, or other illegal activities

• Enforce our Terms of Service

6. Security of Your Information

We are committed to ensuring the security of your personal information. We implement industry-standard administrative, technical, and physical safeguards to protect your information from unauthorized access, use, or disclosure.

6.1 Wallet Security

It is important to note that UnicornX does not have access to your private keys through our wallet service provider, Turnkey Global, Inc. Your wallet address and private keys are securely managed through advanced cryptographic protocols, and we encourage you to take appropriate measures to protect your account credentials.

6.2 Chat Security

Chat communications are protected using encryption and other security measures. However, you should be aware that no method of electronic communication is completely secure.

6.3 Transaction Security

On/off ramp transactions are secured through industry-standard encryption and security protocols implemented by our service provider, OSL Digital Securities. We do not store sensitive financial credentials.

6.4 General Security

While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

7. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information:

7.1 Access and Portability

You may have the right to access your personal information and, in certain circumstances, receive a copy of your personal information in a structured, commonly used format.

7.2 Correction and Deletion

You may have the right to correct inaccurate personal information and, in certain circumstances, request deletion of your personal information.

7.3 Restriction and Objection

You may have the right to restrict or object to certain processing of your personal information.

7.4 Withdrawal of Consent

Where processing is based on consent, you may withdraw your consent at any time.

7.5 Chat-Specific Rights

You may request deletion of specific chat messages or chat history, subject to our retention requirements and technical limitations.

To exercise these rights, please contact us using the information provided at the end of this Policy.

8. Referral System and Social Features

UnicornX incorporates a referral system that allows users to earn rebates. Users may share their referral links, and when others register and engage in trading activities through those links, both the referrer and the referred user may receive rebates.

Additionally, users are permitted to publish broadcasts in the marketplace following the execution of trades. Other users may click on the trading card to follow the trade, thereby earning a commission on the transaction fees associated with those trades.

When you participate in these social features, information about your activities may be visible to other users as part of the platform's functionality.

9. Application Downloads and Third-Party Risks

Users who choose to download the UnicornX application from sources outside of the official iOS App Store or Google Play Store do so at their own risk. We expressly disclaim any responsibility for the security, functionality, or legality of applications downloaded from unauthorized sources. It is the user's responsibility to ensure that they are downloading the application from a legitimate source.

10. International Data Transfers

Your information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

This includes transfers to:

• Easemob Technologies for chat functionality

• Turnkey Global, Inc. for wallet services

• OSL Digital Securities for on/off ramp services

• Other service providers located in various jurisdictions

If you are located outside of the country where our servers are located and choose to provide information to us, please note that we transfer the information, including personal information, to that country and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We implement appropriate safeguards to ensure your personal information receives adequate protection during international transfers.

11. Children's Privacy

Our Service is not directed to individuals under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you are aware that your Child has provided us with personal information, please contact us. If we become aware that we have collected personal information from Children without verification of parental consent, we take steps to remove that information from our servers.

12. Changes to This Privacy Policy

We reserve the right to amend this Privacy Policy at any time. Any changes will be effective immediately upon posting the revised Policy on this page. We will notify you of any material changes to this Policy by:

• Posting a notice on our Service

• Sending you an email notification

• Other means as required by law

We encourage you to review this Policy periodically to remain informed about our practices.

The date the Privacy Policy was last revised is identified at the top of the page.

13. Additional Information for Specific Jurisdictions

13.1 European Union

If you are located in the European Union, you have additional rights under the General Data Protection Regulation (GDPR), including the right to lodge a complaint with a supervisory authority.

13.2 California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and other applicable privacy laws.

13.3 Other Jurisdictions

We comply with applicable privacy laws in jurisdictions where we operate. If you have specific questions about your rights under local privacy laws, please contact us.

14. Data Protection Officer

If you have questions about how we handle your personal information or wish to exercise your rights, you may contact our Data Protection Officer at:

Email: [e-mail]

15. Contact Information

For any inquiries, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: [e-mail]

Data Protection Officer: [e-mail]

By using the UnicornX Service, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.