Terms of service

[Notice] Main Contents of the Terms of Use

※ The main content of these basic terms and conditions is that the company separately notifies the members for the rights and interests of the company and members, in order to fulfill the legal obligations under the Act on the regulation of the terms and conditions. Therefore, members must check the main contents of these Terms of Use, and if you cannot understand the main contents of these Terms of Use or have any questions, please read the entire Terms of Use carefully.

When a visitor enters the member's account, password, and other information that matches the login information provided to the company to use the company's services and accesses the company's mobile and web pages, all transactions made during the relevant access period The conduct is considered to be due to the true intention of the member. Therefore, members must maintain the security of their accounts, passwords and other information, and must be careful of damage caused by financial accidents or crimes themselves.

In the case of cryptocurrencies such as bitcoin, the issuer does not exist, so no third parties inside or outside Korea (including companies) guarantee value or guarantee payment. Therefore, cryptocurrencies such as bitcoin may have very large volatility depending on the law of the Republic of Korea, the interpretation of the authority of the administrative agency, and the economic environment, and the interpretation of legal actions for transactions of cryptocurrencies such as bitcoin differs from country to country. Since there are inherent risks, members must pay attention to this point.

In the case of Aladdin Exchange transaction service, it is a service provided by the company so that members can trade cryptocurrencies with third parties using blockchain technology. Currently, blockchain technology is evaluated as non-modifiable by a third party, but this can be changed at any time due to technological advances or other unforeseen circumstances.

When a member trades cryptocurrency using the company's service, the transaction details of the cryptocurrency are recorded in the blockchain, allowing cryptocurrency users around the world to check the truth of the transaction. However, if the consistency of the blockchain for which transaction details are confirmed is damaged due to reasons attributable to a third party such as a communication service provider, inspection of the server in the company, or errors in the blockchain itself, transactions are made by the company or a third party other than the company. History can be restored to a specific point in the past.

The company makes efforts to provide 365 days, 24 hours service, but this is not a guarantee. In the event of a problem such as a temporary suspension of the service or an error in the service due to illegal acts of a member or a third party, the company resolves the problem and resumes the service. In this case, the member may request the company to recover based on the transaction record held by the company, but the company may in any case compensate for the profit from the recovery of the transaction record or damage the member with other types of cryptocurrency or KRW points. Does not compensate.

Recently, there have been cases of using cryptocurrencies such as bitcoin as a means of electronic financial fraud such as smishing and pharming. Therefore, members must take care of themselves so that damage does not occur due to electronic financial fraud, and if an investigation by an investigative agency, judiciary, administrative agency, or other public authority is required due to an electronic financial fraud, the account and electronic wallet need to be frozen, The company may freeze the account and electronic wallet without the consent of the member.

In the event of damage to the company due to the member's illegal activity, the company may exercise the right to claim damages against the member according to the law. Therefore, please be sure to follow the laws and regulations to use the company's services.

1. Purpose

  • These terms and conditions are for the purpose of stipulating the rights, obligations and matters of the company and members, and other necessary matters for the use of Aladdin Exchange and all Aladdin Exchange-related services that Aladdin Exchange (hereinafter referred to as the “Company”) is responsible for. Do it.

2. Definition

The definitions of terms used in these terms and conditions are as follows:

  • "Service" means Aladdin Exchange's digital asset transaction service and related services that can be used by members regardless of terminal (including various wired and wireless devices such as PCs and portable terminals).
  • "Member" refers to a customer who accesses the service, signs a use contract with the company in accordance with these terms and conditions, and uses the service provided by the company.
  • "ID (ID or account)" refers to a combination of letters or numbers that the company gives to the member to identify the member and provide the service after the member agrees to these terms and conditions and privacy policy.
  • "Digital asset" refers to information that exists electronically in the blockchain, such as Bitcoin and Ethereum that can be traded in the service, and refers to the object of the service.
  • "External Digital Asset Address" means any digital asset address or account owned or used by a Member or another person, outside of the Service. Addresses of external digital assets are not owned, controlled or operated by the company.
  • "Aladdin Exchange Wallet" means a digital asset wallet used by Aladdin Exchange to store digital assets associated with a Member's Aladdin Exchange ID. Members can send and receive digital assets with "External Digital Asset Address" through "Aladdin Exchange Wallet".
  • "Post" refers to information or materials in online digital form, such as codes, letters, figures, colors, voices, sounds, images, and images (including complexes of these) provided by the company to members.
  • "Market" refers to a virtual space where members can buy and sell digital assets according to their will.
  • "Important Affiliate" refers to a company that provides some important functions of the "Service" by entering into an alliance contract with the "Company".
  • “Mileage” is an event reward executed by a member on the Aladdin exchange and can be changed with TNC coins in the future.

3. Posting and Revision of Terms and Conditions

  • The company posts the contents of this agreement within the service or through the connection screen so that members can easily understand.
  • If necessary, the company may revise these terms and conditions to the extent that it does not violate relevant laws and regulations.
  • If the company revises this agreement, the service will notify you from 7 days before the effective date to the day before the effective date by specifying the revised content and application date. However, in the case of changes that are unfavorable to members, it will be notified from 30 days before the effective date.
  • In the event that the member does not expressly express his or her intention to reject it, even though the company clearly informs the member that the expression of intention is deemed to have been expressed if the member does not express his or her intention by the day before the application date while notifying in accordance with the preceding paragraph, I see you agree.
  • If the member does not agree to the revised terms and conditions, the member may express his or her intention to reject the service by the day before the effective date and terminate the service use contract.

4. Interpretation of Terms and Conditions

  • The company may have a separate operating policy in addition to these terms and conditions.
  • Any matters or interpretations not specified in these terms and conditions shall be in accordance with the operating policy, usage guide, and related laws.

5. Conclusion of use contract

  • In terms of use contract, a person who wants to become a member (hereinafter referred to as "subscription applicant") agrees to the terms and conditions provided by the company, and then completes the application for subscription according to the procedure set by the company, and the company responds to such application. It is concluded upon acceptance.
  • The Company may not approve the application of the applicant for subscription if there is a reason falling under each of the subparagraphs below, and if the reasons for each of the following subparagraphs are confirmed even after signing up, the company may cancel the acceptance or suspend the contract of use.
    • ①.If the applicant for membership has previously lost membership in accordance with these terms and conditions
    • ②. In case of using the name other than the real name or the name of another person
    • ③. When false or incorrect information is entered or provided, or when the company does not provide information
    • ④. In case the application cannot be approved due to reasons attributable to the applicant or in violation of all other matters specified in this agreement
    • ⑤. If you intend to use the service for an illegal purpose or a separate business purpose
    • ⑥. When the application is made for the purpose of violating related laws or impeding social order or morals
    • ⑦. If the applicant is a US citizen or under the age of 19
  • The timing of establishment of the use contract is when the company indicates the completion of account creation in the application process or when a notification in accordance with the method of Article 19 reaches the applicant.
  • In order to check whether the information provided by the member is consistent with the facts, the company may request real name verification or self-certification through a professional organization within the scope permitted by law

6. Change of member information

  • Members can view and modify their personal information at any time through the service. However, the ID required for service management cannot be modified.
  • If the information entered at the time of membership application is changed, the member must correct the change directly in the service or notify the company of the change through the customer center.
  • The company is not responsible for any disadvantages caused by the member not notifying the company of the changes in the preceding paragraph.

7. Management of member information

  • The company is concerned that the member's information may leak personal information, may be misunderstood as someone other than the member himself, or be against antisocial or public morals, infringe on the rights of a third party, or be mistaken for the company and its operator. If there is, you can restrict the use of the member information. In addition, even in other cases, the company may restrict the use of the exchange if it is deemed necessary by the company's reasonable judgment.
  • If the account and password registered by the member match those registered with the company, the company regards the user as a member without a separate verification procedure.
  • Members are responsible for keeping all information necessary for account access, including passwords, securely to prevent unauthorized third parties from accessing the member's account.
  • If the member recognizes that the account access information has been lost, stolen, or disclosed to a third party, the member must immediately notify the company. The company may immediately take measures such as suspension of account use.
  • The company is not responsible for any damages caused to members due to the loss, theft or disclosure of access information such as the member's account password. However, this is not the case in the case of intentional or negligence of the company.

8. Protection of personal information

The Company strives to protect the personal information of members in accordance with relevant laws such as the Act on Promotion of Information and Communication Network Utilization and Information Protection, and the Personal Information Protection Act. Regarding the protection and use of personal information, relevant laws and regulations and the company's personal information processing policy are applied. However, the company's personal information processing policy does not apply to screens linked to the outside of the screens produced and provided by the company.

9. ompany's obligations

  • The company complies with the relevant laws and regulations and these terms and conditions, and makes every effort to provide continuous and stable service.
  • The company may have a security system to protect personal information (including credit information) so that members can safely use the service, and disclose and comply with the personal information processing policy.
  • If the company deems that opinions or complaints raised by members in relation to the service use are legitimate, they must handle them, and can deliver the processing process and results to members through 1:1 inquiries or e-mail.

10. Member's obligations

  • Members must not do the following actions.
    • Theft of information from others
    • ②. Change of information posted by the company
    • ③. Transmission or posting of information (computer programs, etc.) other than the information set by the company
    • ④. Infringement of intellectual property rights such as copyrights of the company and other third parties
    • ⑤. Acts that damage the reputation of the company and other third parties or interfere with business
    • ⑥. Disclosure or posting of obscene or violent messages, images, voices, false facts, and other information contrary to public order and good manners.
    • ⑦. Using the service for profit without the prior consent of the company
    • ⑧. Access to the service through automated means such as Agent, Script, Spider, Spyware, Toolbar, or other illegal methods without prior consent of the company, exposure Unlawfully generating or increasing the number of times and clicks, applying for service use, and causing load on the company's server
    • ⑨. Collecting personal information and account information of other members
    • ⑩. Disrupting the sound trading order by unfairly affecting the market price of digital assets
    • ⑪. Other illegal or unfair practices
  • Members must comply with related laws, these terms and conditions, information notified or notified by the company in relation to the service, and must not engage in any other acts that interfere with the company's business.

11. Retribution of rights

  • Copyright and intellectual property rights for the service belong to the company.
  • In relation to the service, the company grants only the right to use the service according to the terms of use set by the company, and the member cannot transfer, sell, or dispose of it.

12. Provision of Services, etc.

  • The company can divide the service into a certain range and specify the available time separately for each range. However, in such cases, the contents will be notified in advance.
  • In principle, the service is provided 24 hours a day, 365 days a year.
  • The Company may temporarily suspend the provision of services in the event of maintenance, inspection, replacement or breakdown of information and communication facilities such as computers, communication disruptions, or operational reasons. In this case, the company notifies the member through the initial service screen or notice board in advance. However, if there is an unavoidable reason that the company cannot notify in advance, it may be notified afterwards.
  • The company may inspect if necessary to provide the service, and the inspection time will follow the notice on the service provision screen.

13. Change of service

  • The company may change the contents of the service, operational and technical matters in order to provide stable service.
  • When changing the service, the company notifies in advance by specifying the details of the change and the date of application. However, if there is an unavoidable reason that the company cannot notify in advance, it may be notified after the fact.
  • If the member does not agree to the service change, the member may express his or her intention to reject the service and terminate the use contract.

14. Use of service

  • The member must submit an order for buying and selling digital assets to the company according to the method determined by the company.
  • When a member submits a digital asset trading order, he/she must have the digital assets necessary to conclude the trading order in the Aladdin Exchange wallet.
  • The company provides order confirmation information that summarizes the quantity, price, and commission of digital assets the member intends to buy or sell before the member submits the order. Members agree that even if the Company fails to provide such order confirmation information, orders submitted by members will not be affected.
  • Members agree that the company is not responsible for changes in the price of digital assets. In the event of an interruption in the digital asset market or an unavoidable event such as Article 23, Paragraph 2, the Company may take one or more of the following actions, and the Company shall not be held liable for any losses incurred to the members due to such actions.
    • Suspension of access to services
    • Suspension of all activities in the service
  • In order to check whether the information provided by the member matches the facts when depositing and withdrawing cash and digital assets, the company may request real name verification or identity verification within the range permitted by law.
  • If the balance of the digital asset in the Aladdin Exchange wallet is greater than the amount corresponding to the outstanding order, the member can send the amount minus the fee to the external digital asset address. The member is responsible for the accuracy of the external digital asset address provided by the member, and the company is not responsible for sending digital assets to the external digital asset address incorrectly entered by the member.

15. Notes on service use

  • The company has the reasons for each subparagraph of Article 5 (2), Article 17 (1) and (2), or if necessary to prevent damage to members due to such reasons, orders submitted through the service You can reject or place restrictions on the transaction amount and other transaction terms. For example, you can limit the number of open orders that can be set through the service, or limit transactions with members in certain regions. In this case, the company notifies the member in the manner pursuant to Article 19.
  • Members can cancel an order only before the order submitted to the service is concluded. For partially executed orders, you can cancel the remaining unfulfilled orders. The company may reject a request for cancellation if a member submits an order at the market price.
  • If the digital assets available in the member's Aladdin Exchange wallet are insufficient for the amount to execute the order submitted by the member, the company will cancel the entire order or fulfill a partial order corresponding to the digital assets available to the member's Aladdin Exchange wallet.
  • The company may suspend all services if it is difficult to continue the service due to serious business reasons such as abolition of business due to business transfer, division, merger, expiration of contracts with important affiliates, or significant deterioration in profits of the service. In this case, unless there is other unavoidable reason, the member will be notified of the date of suspension, the reason for the suspension, and the method of transferring digital assets held by the user by the method of Article 19 (1) up to 30 days before the suspension date. However, the company supports the transfer (withdrawal) of the member's digital assets in accordance with Article 15, Paragraph 5 of these Terms and Conditions so that the member can safely transfer (withdraw) his or her digital assets even if transaction support is stopped.
  • The company can use the service if there is a reason for stopping the provision of inevitable services such as defects in the digital asset itself, bankruptcy or dissolution of important affiliates, termination of digital asset transaction support, related laws and regulations Individual digital assets can be added or excluded. The company will make reasonable efforts to notify members in advance whether or not to remove digital assets. When certain digital assets are excluded from the service provided by the company, the company may transfer digital assets to personal wallets issued by exchanges other than Aladdin Exchange for at least 30 days from the date of notification of suspension of digital asset transaction support. ) Support.
  • The content provided by the service is an auxiliary material for the use of the service, and is not a solicitation or suggestion of investment or transaction. The company does not guarantee the accuracy of the content and information provided by other information providers.
  • The company can support the transaction of new digital assets according to its operating policy.

16. Service Fee

More information about the Fee Structure can be found on this page: https://aladdin25.com/info/fees

1. Fees disclaimers

  • Fees may be incurred for part of the Services provided by us to the Users. By using our Services, you agree to incur these fees.
  • Aladdin Exchange has the right to set and modify our fee structure and at our own discretion. We may also start charging fees on free services. Any fee changes shall be announced in advance.
  • If you do not agree with any fees charged, You should stop using the Service immediately. You are still responsible for any fees previously incurred.
  • Unless otherwise stated or agreed, the User agrees that we have the right to automatically and without prior notice deduct the above-mentioned service fees directly from the assets of the User account.
  • If You do not pay in full and on time, we reserve the right to interrupt, suspend or terminate the service.

2. Fee Structure

Withdrawals
  • Users must follow the Minimum Withdrawal Amount and Minimum Deposit Amount specified on our website.
  • Users must pay the set amount of Withdrawal Fees set for each cryptocurrency.
Trading
  • Makers must pay a fixed fee of 0.20%
  • Takers must pay a fixed fee of 0.20%

17. Deposits and Withdrawals

  • Users may fund their Aladdin Exchange account by depositing Digital Currency. The Digital Currency deposited in your Aladdin Exchange account can only be used to buy and sell Digital Currency using Aladdin Exchange.
  • Deposits and withdrawals are subject to limitations and will incur fees.
  • Users must deposit more than the minimum deposit amount specified on our Fee Structure Page.
  • If users deposit less than the minimum amount, the balance will not be credited.
  • If users deposit multiple times, it can accumulate up to the minimum amount, once this happens, the accumulated balance will be credited.
  • All fees will be displayed clearly in your Aladdin Exchange Account.

18. Restrictions on use, etc.

  • The company may restrict the member's service login if it falls under any of the following items.
    • ①. In case of hacking and fraud
    • ②. In case of suspected identity theft
    • ③. When a national agency requests service restriction in accordance with relevant laws and regulations
    • ④. When it is reasonably suspected of being involved in market price manipulation, money laundering, unfair trade, criminal activity, etc.
    • ⑤. If the case of membership is confirmed as a minor
    • ⑥. If you are verified as a member of a registered U.S. citizen (US citizens cannot join or use the exchange.)
    • ⑦. When it is confirmed that the member is making a deposit and withdrawal transaction in KRW to an account in the name of another person
    • ⑧. When any other reason occurs, or when measures are necessary to prevent such occurrence.
  • The company may withhold or restrict the member's use of transactions, deposits, and withdrawals in the following cases.
    • ①. If the case of membership is confirmed as a minor
    • ②. If you are verified as a member of a registered U.S. citizen (US citizens cannot join or use the exchange.)
    • ③. Hacking and fraudulent accidents have occurred or are suspected to have occurred
    • ④. In case of suspected identity theft
    • ⑤. When a national agency requests service restriction in accordance with relevant laws and regulations
    • ⑥. If you are involved in or reasonably suspect that you are involved in market price manipulation, money laundering, unfair trade, criminal activities, etc.
    • ⑦. When it is confirmed that the member is making a deposit and withdrawal transaction in KRW to an account in the name of another person
    • ⑧. In the event of any other reason corresponding to each of the subparagraphs, or when measures are necessary to prevent such occurrence
    • ⑨. When deposits are made to trade digital assets on behalf of others such as purchasing agents
    • ⑩. When it is difficult for the company to check the IP that the member actually accessed, such as when connecting using a VPN
    • ⑪. If the account is presumed to be used for crime (voice phishing, etc.)
  • Accounts that are likely to be abused for crimes such as voice phishing and money laundering (small amounts, long-term unused accounts, etc.) may have their security level adjusted according to the operating policy.
  • The conditions and details of restrictions within the scope of use restrictions in this article shall be determined by the company in the operation policy and usage guide.
  • In the event of restricting the use of the service or terminating the use contract pursuant to this Article, the Company shall notify the member by the method pursuant to Article 22.
  • Members may file an objection to the restriction of use pursuant to this Article through the Aladdin Exchange Customer Center. At this time, if the company admits that the objection is justified, the company immediately resumes using the service.
  • The company may request a member to clarify the source of the fund in order to determine whether the reason for the restriction on use applies.

19. Termination of Use Contract

  • Members can apply for termination of the use contract at any time through the customer center in the service, and the company must deal with it immediately as stipulated by relevant laws.
  • When the following reasons occur to the member, the company may set a time limit to use the service and request correction. Despite the request for correction, the contract of use may be terminated if the correction is not made within a considerable period of time or if the same violation is repeatedly committed two or more times.
    • ①. In the event of a violation of the member's obligations stipulated in Article 10 of these Terms and Conditions or a reason for restriction of use stipulated in Article 17
    • ②. In case of violating related laws such as illegal communication and hacking in violation of the Act on the provision and operation of illegal programs in violation of copyright law, promotion of information and communication network use, and information protection, distribution of malicious programs, and excessive access rights.
    • ③. When an act or attempt is made to hinder the smooth progress of the service provided by the company
    • ④. In the case of any other reason that cannot maintain this contract due to the reasons applicable to each subparagraph.
  • Upon termination of the use contract pursuant to the preceding paragraph, all benefits obtained through the use of the service lapse, and the company does not compensate for this.
  • In the event of termination of the service use contract pursuant to this Article, the Company shall notify the member by the method pursuant to Article 19.
  • When the termination of the use contract is completed, all information of the member except for the information that the company must hold in accordance with the relevant laws and personal information processing policy will be deleted.
  • In spite of the preceding paragraph, if the company terminates the use contract pursuant to paragraph 2, the company may keep the member's information for a certain period of time for receiving and processing the member's objection, and after that period, the member's information (however, Digital asset transactions are excluded).

20. Notice to Members

  • When the company notifies the member, it can be done using the e-mail address provided by the member unless otherwise specified in these terms and conditions.
  • If the company notifies all members, it can replace the notice in the preceding paragraph by posting it on the bulletin board within the service for more than 7 days.

21. Liability Limitation

  • If the company or member inflicts damage to the other party by violating these terms and conditions, it is liable to compensate for the damage. However, this is not the case if there is no intention or negligence of the actor.
  • In the event of any damage to a member due to the following reasons, the Company shall not be held liable for the damage if it proves that the company has taken the care of the administrator necessary to prevent the member from occurring.
    • ①.When it is unavoidable, such as wartime, incident, natural disaster, or equivalent national emergency
    • ②.In case of compliance with governmental agencies' de facto or legal administrative measures and orders
    • ③.In case of service failure of telecommunication service companies including key telecommunications business operators under the Telecommunications Business Act
    • ④.In the event of a service failure due to a defect in the outsourced system that the company cannot manage or a cause attributable to the user
    • ⑤.In case of server failure due to instantaneous increase in access to the homepage or a large number of orders for some items
    • ⑥ In the event of a failure or error in the transaction system, deposit/withdrawal system, network of each digital asset (ex : Bitcoin network) within the service
  • Necessary manager's caution in Paragraph 2 of this Article includes the following.
    • ①. Appointment and management of information protection officer
    • ②. Information protection education
    • ③. Computer room (a place where computing equipment, communication and security equipment are installed that store important information or necessary for digital asset transactions, which is the company’s essential business), facilities in the building where the computer room is located, and information protection system (information processing system Equipment and programs to protect information, etc. from leakage, forgery, tampering, or disrupting the normal service of the information processing system) and information processing systems (hardware, software and related equipment used in the information technology sector, including digital asset transactions) ) Protection measures
    • ④. Establish information security incident response plan
    • ⑤. Regular inspection of information protection measures and countermeasures against security incidents
    • ⑥. Matters prescribed by digital asset handling companies in other information protection laws

22. Important Matters

Digital assets are not endorsed by financial institutions or governments. In addition, the high level of risk associated with digital assets and digital asset trading, volatility in the cryptocurrency market, problems with internet connection or disconnection, blockchain, software errors, hacking, phishing or malicious software attacks, loss of significant or all cryptocurrencies, hard Members agree that the company or affiliates are not liable for losses arising from or incurred due to the specified risks, such as changes in laws and regulations in all jurisdictions related to forking and cryptocurrency. In no case should the company be construed as guaranteeing the financial security of the digital assets provided by the company. Members can trade digital assets to recognize the loss of some or all of their investments. Members are not responsible for any losses arising or arising from the sale of digital assets available on the website. The company is not liable in any way.

Addendum

These terms will apply from May 7, 2021.

Privacy policy

This Privacy Policy constitutes a part of Aladdin Exchange Terms of Service (the “ToS”). The terms used in this Privacy Policy shall have the same meanings as in the ToS except as otherwise provided herein.

This Privacy Policy explains how Aladdin Exchange collect, use, process, disclose, share, transfer, and protect personal information obtained through Aladdin Exchange and its partners. The terms “we,” “us,” and “our” refer to Aladdin Exchange. When we ask for certain personal information from users, it is because we are required by applicable laws or government orders to collect such information or it is relevant for our specified purposes.

Please carefully read the full content of this Privacy Policy. When visiting Aladdin Exchange, regardless of whether or not you register for or log in to the Aladdin Exchange Services, you acknowledge, understand, and consent to all articles described in this Privacy Policy. We will not use your personal information for any purpose not covered in this Privacy Policy or the ToS (including any other business rules of Aladdin Exchange) without prior notification to you and your consent.

The latest Privacy Policy has incorporated elements from the General Data Protection Regulation (GDPR) as we act in accordance with its personal information processing rules within the European Economic Area (EEA). We utilize standard contract clauses, rely on the European Commission's adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to third countries if required by applicable laws.

1. INFORMATION WE COLLECT

The followings are the types of information we collect when you register for and use Aladdin

Exchange Services:

1.1 Information You Provide to Us When Registering

When you create an Aladdin Exchange Account, you provide us with your email address, name, date of birth, nationality, country code, gender, signature, utility bills, home address, password, and other information to help us identify you (“Identification Information”). You can also choose to add a phone number for SMS or Google Authenticator account for Two-Factor Authentication to improve account security.

If you agree to use biometric authentication methods to log in or use Aladdin Exchange services, such as fingerprint recognition and facial recognition, you need to provide us with the corresponding information, such as the fingerprint information and facial information, and your consent to the processing of your biometric data.

1.2 Information We Collect to Comply with Regulatory Policies

To comply with global industry regulatory standards, local industry regulatory standards, and government orders in different aspects such as Anti-Money Laundering (AML), Know-Your-Customer (KYC), and Counter-Terrorist Financing (CTF), Aladdin Exchange is required to collect personal information in addition to Identification Information, such as identity documents (including passport, driver's license, national identity card, state ID card, tax ID number, passport number, driver's license details, national identity card details, visa information, etc.), proof of address, source of fund declaration, purposes of fund documents, and source of wealth (“Regulation Information”) . We will explain to you the content and requirements of such personal information each time we collect information and we reserve the right to change the content and requirements of the collected information as the global industry regulatory standards, local regulatory standards or government orders change. This provision applies to both personal and institutional Aladdin Exchange Accounts.

1.3 Information We Collect as You Use Aladdin Exchange Services

  • Service Usage Information

    Through your access to and use of Aladdin Exchange Services, we may monitor and collect tracking information related to usage including but not limited to your phone number, access date and time, device type and device identification, operating system and hardware setting, browser type, and information derived from SIM card, network operator, IP address, GPS, base station and WLAN (“Service Usage Information”). This information may be directly obtained by Aladdin Exchange or through third-party service providers. The collection of Service Usage Information helps our systems to ensure that our interface is accessible for users across all platforms and can aid during criminal investigations.

  • Transaction Information

    For all personal and institutional user accounts, we may collect transaction information as you use Aladdin Exchange Services, including but not limited to deposit snapshots, account balances, trade history (such as transaction initiation, payment method, price, quantity, time, withdrawal, and authorization information), order activity, and distribution history (“Transaction Information”). We collect such transaction information to monitor suspicious trading activity for user fraud protection, legal case resolution, and any other purposes disclosed in this Privacy Policy.

  • Communication Information

    You agree that, for the purposes disclosed in this Privacy Policy, we are entitled to collect and use the information contained in or related to the communication that you send to us or generated through your use of Aladdin Exchange Services (“Communication Information”), which includes:

    • - All messages, requests, or other information you send in the course of your contact with Aladdin Exchange
    • - All communications and file attachments in connection with your transactions with other users or other data generated primarily through your communications with them.
  • Financial Information:

    You agree that, for the purposes disclosed in this Privacy Policy, we are entitled to collect and use the information contained in or related to your financial information when you use Aladdin Exchange Services, including without limitation, bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification. We collect such financial information to monitor suspicious financial activity for user fraud protection, legal case resolution, and any other purposes disclosed in this Privacy Policy.

2. HOW WE COLLECT INFORMATION

2.1 Information Aladdin Exchange Automatically Collects

Most of the personal information that we collect is directly provided by you. In the following

situations, we will collect and process the information about you:

  • where you register for, log in or visit Aladdin Exchange, or use any service of Aladdin Exchange;
  • where you voluntarily complete any user survey or provide feedback to us via email or any other channel;
  • where you use cookies of the browser or software in visiting or using our website or APPs;
  • other situations where we may automatically collect your information as mentioned in this Privacy Policy
    or our Terms of Service (including the Aladdin Exchange Platform Rules, the same below).

2.2 Information Collected from the Third-party Sources

We may collect information about you from third-party sources, including but not limited to, the following channels:

  • public databases, credit bureaus, and ID verification partners;
  • blockchain data;
  • marketing partners and resellers;
  • advertising partners and analytics providers.

2.3 Anonymized and Aggregated Data

Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated personal data (i.e. information about our Users that we combine together so that it no longer identifies or references an individual User).

We may use anonymized or aggregate customer data for any business purpose, including to better understand Users’ needs and behaviors, improve our products and services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties.

3. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect about you for the following purposes or in the following ways:

3.1 To Provide and Maintain Aladdin Exchange Services

  • We use the information collected to deliver, maintain, and provide better Aladdin Exchange Services (including but not limited to processing transactions) and verify Users’ identities.
  • We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and activities and provide Aladdin Exchange Services. Given our legal obligations and system requirements, we cannot provide you with all or some of Aladdin Exchange Services without data like Identification Information, Supervision Information, Service Usage Information, Communication Information, and Transaction Information.

3.2 To Protect Our Users

  • We use the information collected to protect our platforms, Users’ accounts, and archives.
  • We use IP addresses and cookies to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (DDoS) attacks.
  • We analyze trading activities with the goal of detecting suspicious behaviors as early as possible to prevent potential fraud and loss of funds to bad actors.

3.3 To Comply with Legal and Regulatory Requirements

  • With respect to the privacy and security of personal information, we will use the information in compliance with our legal obligations, government requests, and reasonable user-generated inquiries. In cases where it is strictly necessary, such as to protect the vital interests of the Users or other natural persons, to fulfill the purpose of public interest, to pursue our reasonable interests (but not to damage the interests of the Users), we may process your personal information without your consent. Except for the situations stated in this Privacy Policy or the ToS, we will not disclose or provide any of your personal information to third parties without a review from our legal team and/or prior consent from the User.
  • Our Services are hosted across the world excluding the US region. If you choose our company’s services, with laws governing data collection and use that may differ from your country’s law, note that you are transferring your personal information outside of those regions to other countries for storage and processing. We may transfer your data from one country to other countries in connection with the storage and processing of data to operate our business. By using our company’s services and providing personal information, you give full consent to our personal information processing.

3.4 For Measurement, Research and Development Purposes

  • We actively measure and analyze data to understand the way you use and interact with Aladdin Exchange Services. This review activity is conducted by our operation teams to continually improve our Platforms’ performance and to resolve issues with the user experience. In addition, we use such information to customize, measure, and improve Aladdin Exchange Services and the content and layout of our websites and apps, and to develop new services.
  • We continuously monitor activity information within our systems and our communications with users to look for and quickly fix problems.

3.5 To Communicate with You

We use personal information collected, like your phone number or email address to interact with you directly when providing customer support on a ticket or to keep you informed on logins, transactions, account security, and other aspects. Without collecting and processing your personal information for confirming each communication, we will not be able to respond to your submitted requests, questions, and inquiries. All direct communications are properly kept at Aladdin Exchange or the service provider designated by Aladdin Exchange, to be reviewed for accuracy, to be kept as evidence, or to be used to perform other statutory or contractual obligations.

3.6 To Enforce Our ToS and Other Agreements

  • The collected information is also used to continually and actively enforce our ToS and other agreements with our Users, including but not limited to reviewing, investigating, and preventing any potentially prohibited or illegal activities that may violate the foregoing provisions, or disclose the relevant information to a third party in accordance therewith.
  • Aladdin Exchange reserves the right to suspend or terminate the provision of any Aladdin Exchange Services to any User found to be engaged in activities that violate our ToS and other agreements with our Users.

3.7 To Facilitate Corporate Acquisitions, Mergers, or Transactions

We may process any information regarding your Aladdin Exchange Account and use of Aladdin Exchange Services as is necessary for the context of corporate acquisitions, mergers, or other corporate transactions.

3.8 For Marketing and Advertising

We may share your personal information with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising.

3.9 For Rebates

We may share the information collected, including but not limited to your Identification Information and Transaction Information, for the purposes of rebates and other benefits.

3.10 For Any Other Purpose

We may disclose your personal information for any other purpose you consent to.

4. MARKETING

  • If we think you may like specific Aladdin Exchange Services or products and services of our partners, we hope to keep you informed about such products or services.
  • If you agree to receive the above marketing information, you can choose to receive it at any time in the future.
  • You have the right to ask us at any time to stop contacting you for marketing purposes or to send relevant information to you. If you do not want to be contacted for marketing purposes in the future, please click on the unsubscribe link at the bottom of the marketing email and submit your request to unsubscribe.

5. HOW WE STORE AND PROTECT USER DATA

Aladdin Exchange has kept your personal information safe using fault-tolerant secured storage with industry standard encryption and implemented a number of security measures to ensure that your information is not lost, abused, or altered, including, but not limited to:

5.1 Physical Measures

Materials containing your personal information will be stored in a locked place.

5.2 Electronic Measures

Computer data containing your personal information will be stored in the computer systems and storage media that are subject to strict log-in restrictions.

5.3 Management Measures

Only authorized employees are permitted to come into contact with your personal information and such employees must comply with our internal confidentiality rules for personal data. We have also imposed strict physical access controls to buildings and files.

5.4 Technical Measures

Encryption technology such as PCI Scanning and Secured Sockets Layered Encryption may be used to transmit and store your personal information. We use various currently available general security technologies and supporting management systems to minimize the risks that your information may be disclosed, damaged, misused, accessed without authorization, disclosed without authorization, or altered.

5.5 Other Measures

Our web server is protected by a “firewall”.

Please note that it is impossible to guarantee 100% security of information. As such, we request that you understand the responsibility to independently take safety precautions to protect your own personal information. You agree that we shall not be liable for any information leakage and other losses not caused by our intention or gross negligence, including but not limited to hacker attack, power interruption, or unavoidable technical failure, to the maximum extent permitted by law.

If you suspect that your personal information has been compromised, especially account and/or password information, please lock your Aladdin Exchange Account and immediately contact the Aladdin Exchange Customer Support team at [email protected]

Unless otherwise stipulated by law or the ToS, you agree that we have the right but not the obligation to retain all the collected personal information for the duration of your Aladdin Exchange Account for 5 more years after the account is closed.

6. TRANSFERS OF PERSONAL INFORMATION

You understand that we have the right to have all or some of the collected personal information transferred to or stored in other countries or regions than your country of nationality, your country of residence, or the country where the server is, without your specific consent, under the following circumstances:

  • if it is necessary to protect, process, analyze, reasonably use personal information;
  • if it is necessary to enforce the ToS and other agreements with our Users;
  • if it is necessary for the public interest;
  • if it is necessary to establish, exercise, or defend the rights of us, our partners, or other Users;
  • other circumstances required by law or government orders.

7. COOKIES

7.1 What Are Cookies?

Cookies are small amounts of data that are sent to your browser and stored on your computer’s hard drive to collect standard internet log information and visitor behavior information. When you visit Aladdin Exchange, we can automatically collect information from you through cookies or similar technologies.

7.2 How Do We Use Cookies?

We use cookies in a range of ways to make your experience on our Platforms more enjoyable, including but not limited to:

  • to keep you signed in;
  • to record your habits and preferences when browsing Aladdin Exchange;
  • to record our performance and verify the effectiveness of online advertising through Google Stats with cookies.

7.3 What Types of Cookies Do We Use?

We use different types of cookies, including but not limited to:

  • Functional Cookies

    We use such cookies to help us identify you and remember your previous preferences and settings, which may include your device, your operating system, your preferred language, your location, and other session data. We use a mix of first-party and third-party cookies.

  • Marketing Cookies

    We use these cookies to collect information about your visit to Aladdin Exchange, the content you view, the links you follow, and other information about your browsers, devices, your IP addresses, and referral URLs. We sometimes share certain parts of the collected information with third parties for marketing purposes. We may also share online data collected through cookies with our marketing partners. This means that when you visit another website, you may also be shown advertisements based on your browsing patterns on Aladdin Exchange.

7.4 How to Manage Cookies?

Most browsers are preset to accept cookies. You can adjust your browser setting to prevent cookies or to notify you as soon as cookies are loaded. However, stopping all cookies might mean that you cannot access or use some features of the Aladdin Exchange.

8. DATA PROTECTION RIGHTS

We hope to ensure that you are fully aware of the data protection rights that you enjoy. Unless otherwise required by law or government orders, each User has the following rights:

8.1 Right of Access

You have the right to access or obtain copies of your personal information. We may charge a reasonable fee for providing the access service.

8.2 Right to Rectification

You have the right to correct your personal information that you deem inaccurate. You also have the right to ask us to complete the personal information that you deem incomplete within a reasonable limit.

8.3 Right to Erasure

You have the right to request the erasure of your personal data.

8.4 Right to Restriction of Processing

Under certain circumstances as required by law or as specifically reminded by us, you have the right to request us to restrict the processing of your personal information; however, you understand that such restriction of the processing may prevent us from providing you with some of Aladdin Exchange Services.

8.5 Right to Object

Under certain circumstances as required by law or as specifically reminded by us, you have the right to object to the processing of your personal information; however, you understand that such objection to the processing may prevent us from providing you with some of Aladdin Exchange Services.

8.6 Right to Data Portability

Under certain circumstances as required by law or as specifically reminded by us, you have the right to request us to transmit the personal information that we collect to another body, or directly to you. We may charge a reasonable fee for providing the transmission service.

9. PRIVACY POLICIES OF OTHER WEBSITES

9.1 Privacy Policies of Non-Aladdin Exchange Websites

If you visit other third-party platforms or partner’s websites, apps via the links on Aladdin Exchange, you should agree with and abide by their separate and independent privacy policies. We are not responsible for the content or the activities therein.

9.2 Privacy Policies of TNC IT GROUP

If you visit any link to any sub-platforms of TNC IT GROUP, you should agree with and abide by the separate and independent privacy policies of such sub-platforms. If the privacy policy of any sub-platform conflicts with this Privacy Policy, the privacy policy of such sub-platform shall prevail.

10. CHANGES TO THIS PRIVACY POLICY

From time to time, Aladdin Exchange may revise this Privacy Policy to reflect changes in law or our personal data collection, processing, and use practices. Changes to this Privacy Policy will be announced by posting on the www.aladdin25.com website. You shall regularly review the Privacy Policy and pay attention to its revisions. If you do not agree with the revised content, you shall stop accessing Aladdin Exchange immediately. When an updated version of the Privacy Policy is released, your continued access to Aladdin Exchange means that you agree to the updated content and agree to abide by the updated Privacy Policy.

11. CONTACT US

We are committed to respecting the freedoms and rights of all our Aladdin Exchange Users. Should have any questions or concerns regarding this Privacy Policy, or if you would like to file a data protection request, please refer to our Frequently Asked Questions at www.aladdin25.com and contact us on our Support Channel at [email protected]

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