Privacy policy

1、 In the process of fulfilling the terms and conditions, UNITED DIGITAL HOLDING LLC，the foreword attaches importance to the trust of customers and understands the importance of ensuring the confidentiality of customers' personal data and information materials published by customers on the website. The administrator takes effect this policy defines the sequence of operations involving confidential information of both parties when using the website and system services. Before using the system services, each customer should be familiar with the terms of this policy. Latest update of privacy policy: Sep 8, 2022 

2. Definition of terms
Unless otherwise expressly stated or followed in the body of these terms and conditions, the following words shall have the following meanings: 2.1. A cookie is data that does not contain any personal data, created by a website and stored as one or more files on the client's computer. If the customer chooses to block the cookie file, the customer may encounter difficulties or be unable to use the website.
2.2. Information material (data) is any text, graphics, audio, video and mixed type material that has the nature of information.
2.3. Confidential information means any information of non-public data, which is considered confidential in accordance with the agreement of the parties or applicable law.
2.4. Confidentiality means that the information can only be accessed by its owner and any party who can and / or must provide the information to it in accordance with the law and / or the agreement with us.
2.5. Public data means any data (including personal data) to which the owner of such data has unrestricted access (including by publishing data on any website that does not restrict access to such data), or the confidentiality requirements do not apply under this data appendix and / or effective laws.
2.6. Personal data is any information that is directly or indirectly related to a specific or identifiable individual (the subject of personal data).
2.7. The receiving party is the party receiving the confidential information.
2.8. Disclosure of confidential information is one of the actions or omissions of the parties, resulting in the confidential information being known or acquired by a third party without the permission of the owner of the confidential information. The format of information disclosure (oral, written, by any technical means, etc.) is not important.
2.9. For the confidential information disclosed by the administrator, the disclosing party is the member; and the administrator is related to the confidential information disclosed by the member.
2.10. The disclosure of confidential information is transferred to any third party of any confidential information in accordance with the requirements of this appendix, including the disclosure, theft, loss, distortion, destruction, destruction, modification, duplication or prevention of confidential information due to non-compliance. Improper compliance by the receiving party with the terms of this appendix.
2.11. Terms not defined in this section shall be further used in the text within the meaning (in order of priority) specified in the bilateral agreement signed by both parties, and with the competent authority and all its appendices.

3. General provisions
3.1. By using any part of the website and / or services, the customer grants the administrator the right to receive, store, process and use the customer's personal data and other information materials in accordance with the terms of this appendix.
3.2.This appendix does not apply to any method of receiving, storing, processing, using and disclosing customer's personal data and other information materials of external companies and organizations that are not owned and managed by the administrator, and is not the responsibility of the administrator. An individual who is not an administrator employee, even though the customer can access such party's and individual's websites, software and / or GWS through the website.
3.3. The main purpose of receiving, storing, processing and using customers' personal data, public data and other data is to protect customers' interests and improve the quality of personalized and general services provided by administrators to customers.
3.4.This policy is not a separate document and is intended to supplement the terms and conditions; it does not supersede or abrogate any of the provisions contained in the body of the terms and conditions, in particular section 10-14 of the terms and conditions relating to the subject matter of this policy.
3.5.The terms contained in this document and the term "confidential information" do not apply to the following information:
3.5.1. Provided by the receiving party to the receiving party in a non confidential way, and provided or provided to the receiving party, the receiving party shall not be bound by any confidentiality agreement with the other party or any other restrictions related to the disclosure of confidential information, or
3.5.2. Before the other party discloses it as confidential information, the equipment has legally belonged to the receiving party, or
3.5.3. Developed by or for the receiving party;
3.5.4. Not protected by the disclosing party in any form to ensure confidentiality;
3.5.5. According to the requirements of effective laws and regulations;
3.5.6. Publicly available and known to the public due to the actions and decisions of the disclosing party;
3.5.7. Has been provided to the receiving party in a non confidential manner prior to the disclosure of such information by the other party; or
3.5.8. It must be disclosed in accordance with the law in force or in accordance with an order issued by a government agency or any other competent authority.

4. Information collection
4.1. The administrator can collect and process the following information about the customer: the customer's full name and last name, occupation, address, email address, telephone number, date of birth, bank or payment card details, as well as documents confirming the customer's identity and residential address that can be provided according to our requirements; information about transactions performed by the customer through the system using the electronic wallet; and Information related to the execution of customer orders;
4.2. In order to meet the mandatory legal obligations related to anti fraud and anti money laundering requirements, the administrator will receive information related to the customer from a third party, including information about the customer's financial history, any decision of the local court, bankruptcy, when the customer opens the wallet or at any other time when the administrator may deem it necessary to prevent fraud and minimize financial risk Information provided by the credit bureau and anti fraud agencies. Further details can be found in Appendix 02 of these terms and conditions.
4.3.The customer must provide their authorization data and other details (mandatory or optional) during the customer's registration in the system and when the customer creates the wallet. After a customer creates and uses their wallet, the administrator can identify the customer every time the customer uses the system and visits the website.
4.4. Administrators can install cookies on the client's computer (unless the client intentionally restricts this option in its browser), as well as receive, store, process, and use information created through cookies.
4.5. When a customer visits the website, the administrator will automatically store, process and use the customer data that is not his personal data, such as the IP address of the customer, the location of the customer that can be identified by his IP address, the technical parameters of the customer's computer, whether there is specific software on the customer's computer, such as the settings of the software, cookies and statistics of the customer's activities.
4.6. In addition to visiting the website, when using the system (if possible), customers also provide information to administrators through mobile device applications, social media applications, payment terminals, etc., and contact and submit requests through phone, email, e-mail or other communication methods through the following methods; administrators will also receive information from other sources when verifying the information previously provided by customers Information about customers.

5. Use of information The administrator shall use the available information related to the customer for the following purposes: providing services related to the customer's wallet and providing services required by the customer; executing customer orders related to remittance and receipt of payment, and using the services to conduct transactions; notifying the customer of changes in services, systems, terms and conditions, software, etc.; meeting the requirements of applicable laws and regulations, especially anti Requirements related to money laundering laws and KYC (know your customer) procedures; verification of customer's financial status, identity and solutions; implementation of verification procedures to prevent fraud and money laundering; provision of services to customers, including answering customer's questions, requests, comments and complaints; enhancement of service security; provision of website content (including Its interactive function); provide customers with the requested products and services, or products and services that the administrator thinks may be of interest to customers; provide help in developing, providing and improving system services, and provide the content of the website and inform customers; implement the internal procedures and processes of the administrator, such as audit, analysis of data processing, quality assessment of the provided services, etc.

6. Information disclosure
6.1. Without the permission of the relevant information client, the administrator shall not provide any personal data to any third party for commercial purposes.
6.2. Personal data may be disclosed to such third parties if they have obtained the permission of the customer in connection with the information; made public the definitive request of the government agency entitled to obtain such information; disclosed to agents and third parties (including but not limited to the acquirer, payment card issuing bank, International) who have reached an agreement with the administrator to perform their obligations to the customer Card systems, telecommunication service providers, billing and delivery companies, administrator's affiliates, etc.), and in the following cases:
1) they know the confidentiality of such information;
2) they take appropriate measures to protect confidential information from unauthorized access and use; and disclose letters to potential creditors, investors, acquirers, partners, shareholders and auditors of the administrator Information; disclose information to companies that may provide products and services to customers; disclose information in the process of information exchange with other companies and organizations to prevent fraud and minimize financial risks; disclose information when the administrator believes that the customer violates the terms of this appendix and / or other agreements and contracts between the administrator and the customer and / or the administrator's internal regulations and rules; Or, when the administrator believes that such information disclosure is necessary to investigate, prevent or take measures to combat illegal activities, suspicious fraud, potential threat to the personal safety of any person, breach of terms and conditions or any bilateral agreement, or if it is necessary to disclose information in other circumstances in accordance with the provisions of this terms and conditions and applicable laws.
6.3. Unless a written agreement is reached with a specific customer, the administrator can publicly disclose the fact that the administrator has a business relationship with the customer.
6.4. Administrators reserve the right to disclose confidential information when required by business practices.
6.5. nothing in this appendix shall limit the right of either party to disclose any Confidential Information pursuant to any order or decision of any court, any other legal obligation or requirement provided by valid laws and regulations (if such information disclosure is mandatory, and to notify the other party of such information disclosure in advance if possible).
6.6. All confidential information shall be the property of the parties to the disclosure of such information; except as expressly provided in this appendix, no rights or licenses will be granted in connection with such confidential information.
6.7. Either party shall return to the other party and / or securely destroy all confidential information (including any confidential information that may be in the process of processing, analysis or translation, including all copies, written instructions, drawings, charts, computer programs, and any format of data requested by the other party in writing, unless such documents must be stored in accordance with effective laws and regulations And shall, if necessary, confirm in writing with the signature of the authorized person that such confidential information has been properly returned or safely destroyed.
6.8. The customer has the right to require the administrator to restrict the third party's access to the customer's personal data for marketing purposes, provided that it does not violate applicable laws and terms and conditions, and may send a written request to the administrator in the following way: the administrator's contact information.

7. Information processing
7.1. By providing its personal data during the registration of the system, the customer agrees to process the data with or without the use of automation technology and / or equipment, in particular the collection, storage, transfer to third parties and the administrator's use for the purpose of providing services to the customer and other purposes specified in the terms and conditions.
7.2. If the customer does not want their personal data to be processed, the customer should contact the administrator using the administrator's contact information or the feedback form on the website. In this case, all information that will be received from the customer will be removed from the administrator's customer database and the customer will not be able to use the service.

8. Information acquisition
8.1. In order to exercise the rights of the customer and properly fulfill the obligations of the manager under the terms and conditions and the agreements signed by both parties, the manager can review the customer's information materials (timely solve technical problems and prevent illegal activities infringing the rights of any party, other customers, etc.).
8.2. Administrators provide limited access to customer information only to employees who need such information to serve customers or perform their professional duties.
8.3. The customer has the right to request, edit or delete personal data stored on the administrator and / or website. Customers can independently edit, change or delete their personal data using the relevant functions of the website and wallet.
8.4. The applicable personal data protection law gives customers access to any information related to customers. Any request for information may result in a charge for all costs involved in providing administrators with details stored by administrators and / or third parties.

9. Send the message to the publicly accessible page
9.1. The publicly accessible page is any page on the website that any party can access infinitely, and can be indexed by the search engine system.
9.2. Administrators allow customers to send messages and exchange data on publicly accessible pages.
9.3. Customers should exercise caution and common sense when disclosing information that allows them to disclose their identity on publicly accessible pages. It is important to remember that this information may remain on the publicly accessible pages of the site indefinitely. In addition, depending on the specific service, other customers can view this information.
9.4. The customer shall be fully responsible for any information disclosed and distributed by the customer on publicly accessible pages.
9.5. If the customer has any questions about the information of the customer that they are allowed to identify on any publicly accessible page, the customer cannot delete or edit such information; in this case, the customer should contact customer support services.

10. Information protection
10.1. The parties acknowledge and confirm that they will ensure the confidentiality of all information received in the performance of their obligations under these terms and conditions, except as expressly provided in these terms and conditions and in other agreements between the parties.
10.2. In case of any breach of the obligations related to the confidentiality of information by the client, the client shall bear all expenses and losses (including loss of profits) incurred by any third party and / or the manager due to such acts of the client.
10.3. Confidentiality terms are included in these terms and conditions and are accepted by the customer upon confirmation of acceptance by the customer.
10.4. The parties shall not disclose information relating to the operating conditions of the system, and other information received by the parties in the performance of their obligations under the terms and conditions, unless either party is obliged to disclose such information in accordance with applicable law.
10.5. Both parties shall notify each other within one (1) working day in case of occurrence or knowledge, and any third party may disclose or threaten to disclose, illegally acquire or illegally use confidential information.
10.6. The parties shall not unilaterally suspend or terminate measures designed to protect the confidential information set forth in these terms and conditions, including in the event of their reorganization (merger, acquisition, division, separation, conversion or any other type of change in legal status) or liquidation (as required by law).
10.7. The disclosure of confidential information in accordance with the legal and effective requirements of law enforcement agencies or other government authorities and / or officials shall not violate the confidentiality obligations of both parties in accordance with the procedures prescribed by applicable laws.
10.8. If the confidential information is disclosed to the above authorities and / or parties, the party disclosing the confidential information shall notify the owner of the confidential information in writing of the facts of the information disclosure, the content of the information and the name of the institution or institution that disclosed such confidential information to it within one (1) working day after the disclosure of the confidential information.
10.9. It is the responsibility of the customer to ensure the confidentiality of its authentication data in accordance with the other parts of these terms and conditions. Administrators are not responsible for transactions caused by improper storage or loss of information.

11. Miscellaneous Provisions
11.1. The administrator shall have the right to store the customer's personal data and other data for such period as may be necessary to achieve the purposes set forth in this appendix, or as may be required by applicable law, or until the customer elects to delete such data. Data.
11.2. The customer is responsible for providing accurate and true information and for updating the information previously provided in the event of any change to the information.
11.3. The customer allows the administrator to grant permission to other parties who have signed relevant agreements with the administrator to receive, store and process information about the customer (except personal data and information materials of the customer), such as the customer's IP address, cookies and statistics about customer activities, in order to improve the quality of services provided by such parties and provide promotional information.
11.4. The customer agrees not to guarantee the confidentiality of any information transmitted over the Internet; if any third party obtains access to such information outside the technical means of communication area managed by the administrator, the latter shall not be liable for any possible damage caused by such access.
11.5. If in the course of using the website and / or the system, the customer obtains any information about the administrator and / or any third party, according to applicable laws, such information constitutes confidential information and / or trade secret, and the customer shall not store, use or distribute such information.
11.6. When you click the link on our website, you may be redirected to a third-party website. We are not responsible for the content of third-party sites and the information collected from you by third-party sites, including the way these third-party sites process, store and manage such information. Third party service providers may have their own privacy policies. It is highly recommended that you familiarize yourself with these policies to understand how to handle your personal information. Once you leave our website, the terms of this privacy policy will no longer define how to collect and manage your personal information.

12. Applicable law
Any payment service is regulated and protected by Massachusetts law.