Zairo Privacy Policy
Effective
Date: December 31 , 2025
Welcome to Zairo (hereinafter referred to as
"the Software " ) and its digital asset trading and related services
(hereinafter referred to as "the Services"). This Privacy Policy aims
to explain how the Software collects, uses, stores, and protects your personal
information, as well as your rights related to your personal information.
Please carefully read and fully understand all the contents of this Policy
before using the Software Services, especially the clauses marked in bold . If you do not agree to the contents of
this Policy, please do not use the Software Services; once you use the Software
Services, it will be deemed that you have fully understood and agreed to all
the provisions of this Policy.
I. Scope of
Application of the Agreement
This agreement applies to all services provided by
this software , including but not limited to account registration, login,
digital asset top-up, trading, withdrawal, information browsing, and customer
service consultation.
This agreement does not apply to the following
situations:
• For
products or services provided by third parties through this software service,
the privacy policies of such third parties will be separately agreed upon, and
this software shall not be liable for them.
• This
software collects and discloses information in accordance with laws,
regulations, or requirements of competent authorities.
• Public
information posted by users on this software platform, such as transaction
updates and community messages.
II. Information
Collection and Acquisition
2.1 Information you
proactively provide
In order to provide you with services, you need to
proactively provide the following information to this software :
• Account
registration information: including mobile phone number, email address,
password, etc., used for your account registration, login and identity
verification;
• Real-name
authentication information: In accordance with regulatory requirements and
service upgrade needs, you may need to provide your name, ID card number,
photos of the front and back of your ID card, facial recognition information,
etc., to complete real-name authentication in order to enjoy services such as
recharge, withdrawal, and large transactions;
• Transaction-related
information: including your digital asset deposit address, withdrawal address,
transaction authorization records, fund flow records, etc., used to complete
core services such as digital asset deposit, transaction, and withdrawal;
• Customer
service information: When you contact customer service, you may need to provide
account information, a description of the problem, etc., to help you resolve
the issue.
2.2 Information We
Collect Automatically
During your use of this software service, we will
automatically collect the following information through technical means:
• Device
information includes device model, operating system version, unique device
identifier (such as IMEI, MAC address), hardware configuration, network type,
etc., which are used to ensure service compatibility and security and prevent
fraud.
• Usage
behavior information includes your login time, login IP address, browsing
history, transaction operation history, click history, etc., which are used to
optimize service experience, analyze service usage, and ensure transaction
security.
• Information
collected by cookies and similar technologies: We use cookies and other
technologies to store your login status, preferences, and other information so
that you don't have to re-enter some information the next time you use the
service, improving convenience. You can disable cookies in your browser
settings, but this may affect the normal use of some services.
2.3 Information
obtained from third parties
Subject to compliance with laws and regulations, we
may obtain your relevant information from legitimate third-party partners, such
as:
• We
obtain your real-name authentication information from an identity verification
service provider to verify the authenticity of your identity.
• Obtain
your risk assessment information from anti-fraud service providers to ensure
transaction security.
We will verify the legality of information provided
by third parties and use the information only to achieve the purpose of
cooperation.
III. Purpose of
Information Use
We collect your personal information only for the
following lawful purposes. If we use it beyond these purposes, we will obtain
your separate authorization and consent:
1. Provide
and optimize services: to provide you with core services such as account
management, digital asset trading, deposits and withdrawals, and to optimize
service processes and content based on usage;
2. Identity
Verification and Security: Used to verify your identity information, prevent
and identify illegal and irregular activities such as fraud, money laundering,
and account theft, and protect the safety of your account and funds;
3. Service
notifications: These are used to send you notifications about account activity,
transaction alerts, service updates, security tips, etc., to ensure you are
informed of the service status in a timely manner;
4. Customer
service: Responds to your inquiries, complaints, and feedback, and provides
support to help you resolve issues;
5. Compliance
requirements: Used to comply with laws, regulations, regulatory provisions,
judicial documents or industry self-regulatory guidelines, and to fulfill
relevant reporting obligations;
6. Data
analysis and service improvement: After anonymization and de-identification, it
is used to analyze user behavior, study service optimization directions, and
develop new compliant service functions.
IV. Information
Storage and Protection
4.1 Information
storage methods and duration
We will store your personal information on servers
that meet security standards, including our own servers and servers of
third-party cloud service providers. The storage location may be located in the
place where we operate the software or overseas (if cross-border storage is
involved, we will ensure that it complies with the relevant laws and
regulations on cross-border data transmission).
We will store your personal information for the
following periods:
• Information
necessary to provide the service will be stored until your account is closed
and the relevant service is terminated, or until the minimum storage period
required by laws and regulations expires.
• Information
used for compliance purposes will be stored until the legally mandated
compliance storage period expires.
• Anonymized
or de-identified information can be permanently stored and used for purposes
such as data analysis, and this information can no longer identify you.
4.2 Information
Protection Measures
This software highly values your information
security and has adopted the following technical and management measures to
ensure it:
• Technical
safeguards: We employ encryption technologies (such as SSL encrypted
transmission and AES encrypted storage) to protect your sensitive information
from unauthorized access, tampering, or leakage; we have established a security
monitoring system to monitor potential security risks in real time.
• Management
and safeguards: Establish a strict information security management system,
clearly define information access permissions, provide security training and
background checks for employees who handle personal information; conduct
regular information security audits and risk assessments, and promptly patch
security vulnerabilities;
• Emergency
Response: We have developed an emergency response plan for information security
incidents. In the event of a security incident such as leakage or loss of
personal information, we will immediately activate the emergency response plan,
take remedial measures, and promptly notify you and relevant regulatory
authorities in accordance with the requirements of laws and regulations.
Please note that internet services are inherently
uncertain. Even with the aforementioned protective measures, we cannot
completely eliminate information security risks caused by factors beyond our
control, such as force majeure or third-party attacks. Please safeguard your
account passwords, verification codes, and other sensitive information, and
avoid disclosing them to others.
V. Information
Sharing and Disclosure
We will not share your personal information with
any third party except in the following circumstances:
• With
your explicit authorization and consent: Sharing information with designated
third parties, such as when you authorize a third-party service to access this software
;
• For
partners necessary to provide services: Information will be shared with
partners who provide us with technical support, identity verification, payment
processing, anti-fraud, etc., but such partners may only use the information to
the extent necessary to provide the services and must comply with strict
confidentiality obligations;
• Sharing
between affiliated companies: Subject to compliance with laws and regulations
and for the purpose of providing comprehensive services, we may share your
information with affiliated companies of this software , but affiliated
companies will comply with the privacy protection principles consistent with
this agreement;
• As
required by laws and regulations: In order to comply with laws and regulations,
regulatory provisions, judicial rulings or administrative orders, or to protect
the legitimate rights and interests of this software , you or other third
parties from harm, we may share information with relevant entities.
We will not proactively disclose your personal
information to the public unless the following conditions are met:
• Obtain
your explicit authorization;
• Information
that must be disclosed to the public according to laws, regulations, regulatory
requirements, or mandatory provisions of judicial documents;
• To
protect the interests of this software or the public, and the legitimate rights
and interests of others, this information is disclosed to the extent that it is
reasonable and necessary.
have the following rights related to your personal
information while using this software service:
• Access
and Inquiry Rights: You can log in to your software account and inquire about
your account information, real-name authentication information, transaction
records, and other personal information on the "Personal Center" and
other relevant pages;
• Right
to Correction: If you find any errors or incompleteness in your personal
information, you can apply for correction through the software's customer
service channels. We will process your application promptly after verifying
your identity.
• Right
to deletion: Subject to the provisions of laws and regulations and the terms of
the service agreement, you may apply to delete some of your personal
information. For example, after canceling your account, we will delete or
anonymize your information in accordance with regulations.
• Withdrawal
of consent: You can withdraw your consent to the collection and use of certain
information by turning off device permissions, canceling your account, etc.,
but withdrawing consent may result in some services not working properly.
• Account
cancellation right: You may apply to cancel your account in accordance with the
procedures stipulated in this software . After the account is cancelled, we
will cease to provide you with services and process your information in
accordance with the information storage period agreement.
• Complaints
and suggestions: If you have any questions or objections regarding the
processing of your personal information, you can file a complaint or provide
feedback through the software's customer service channels (such as customer
service hotline or online customer service). We will respond within 15 business
days.
VII. Protection of
Minors' Information
This software does not provide services to minors
(as defined by relevant laws and regulations, natural persons under the age of
18). If you are a minor, please do not register or use this software service;
if we discover that a minor is using the service, we will immediately cease
providing the service and delete their relevant information (unless otherwise
stipulated by laws and regulations). If a guardian discovers that a minor has
mistakenly used this software service, please contact us promptly for handling.
VIII. Amendments and
Notifications to the Agreement
official website, app pop-ups, and in-app messages before
the revised agreement takes effect .
If you disagree with the revised agreement, please
stop using the service immediately; continued use of the service will be
considered as acceptance of the revised agreement. For significant changes, we
will notify you separately (e.g., via email, SMS, etc.).
IX. Applicable Law
and Dispute Resolution
The formation, validity, performance,
interpretation, and dispute resolution of this Agreement shall first be
governed by the applicable laws and regulations (excluding conflict of laws
rules) of the jurisdiction where you use this software service. If the laws and
regulations of the jurisdiction where you use the service do not explicitly
stipulate matters related to this Agreement, or if there are conflicts of
content, the laws and regulations of the place of registration or principal place
of operation of this software company shall apply.
If any provision of this Agreement is held to be
invalid or unenforceable, the validity of the remaining provisions shall remain
unchanged.