> For the complete documentation index, see [llms.txt](https://support.safeheron.com/help-center/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://support.safeheron.com/help-center/jian-ti-zhong-wen/chan-pin/bang-zhu/safeheron-yin-si-zheng-ce.md).

# Safeheron 隐私政策

**更新于：2026 年 7 月 15 日**

**更新日志**

<table><thead><tr><th width="115.0234375">版本号</th><th width="364.51953125">更新内容</th><th>更新时间</th><th>生效时间</th></tr></thead><tbody><tr><td>V1.0.0</td><td>创建文档</td><td>2022.05.16</td><td>2022.05.16</td></tr><tr><td>V1.0.1</td><td><p>更新如下条款： </p><p>二、使用收集的个人信息 </p><p>1）新增采集数据保留期限 </p><p>2）新增采集数据明细 七、我们如何使用 Cookie </p><p>1）新增Cookie类别以及保留期限 </p><p></p><p>新增如下条款： </p><p>九、数据跨境传输</p></td><td>2022.11.16</td><td>2022.11.16</td></tr><tr><td>V1.1.0</td><td><p>条款更新:</p><p><strong>引言</strong> — 明确了本隐私政策与《Safeheron License Agreement》及《Safeheron Product Specific Terms》之间的关系；更新了"平台"的范围定义</p><p><strong>一、信息收集</strong> — 新增通过第三方 API 及 SDK 收集信息的说明</p><p><strong>二、所收集个人信息的使用</strong> — 新增关于"用户数据"(User Data) 的澄清说明</p><p><strong>三、个人数据的共享与转移</strong> — 新增与关联公司、服务提供商、第三方服务及第三方 SDK 共享信息的说明；修正了条款编号；新增第三方、SDK 及 API 列表</p><p><strong>四、保护您的个人信息</strong> — 安全事件通知时限与《许可协议》保持一致</p><p><strong>七、我们如何使用 Cookie</strong> — 新增第三方 SDK 披露说明</p><p><strong>八、我们保留您个人数据的期限</strong> — 新增账户暂停或注销后的数据处理说明</p></td><td>2026.07.15</td><td>2026.07.15</td></tr></tbody></table>

## Introduction

Thank you for using our application and/or visiting our website. We take our data protection responsibilities very seriously and have designed our website in a way that users can browse without having to provide any personal data.

The Privacy Policy (this "**Privacy Policy**") describes how SAFEHERON PTE. LTD. and how our affiliates ("**Safeheron**" or “**We**”) will collect, use, maintain, share and store information collected in connection with the use of our website <https://safeheron.com/>, any other related domain or subdomain thereof ("**Site**"), the use of our platform's mobile wallet application, browser extension, web console application, API Co-Signer, Open APIs and SDKs, and any other software applications we license ("**Platform**"). This is in connection with our role as controller of your personal information (where applicable under data protection laws), and in instances where data is collected and processed. Additional details are provided in this Privacy Policy.

This Privacy Policy forms part of, and should be read together with, the Safeheron License Agreement (Software-as-a-Service) and the Safeheron Product Specific Terms (together, the "Agreement"). Capitalised terms used but not defined in this Privacy Policy have the meanings given to them in the Agreement. Where the Agreement (including the Product Specific Terms) describes specific data collection or sharing in connection with particular features — including Third Party Services, Compliance Integrations and the API Co-Signer — that description supplements this Privacy Policy.

For the purposes of this Privacy Policy, "**personal information**" refers to information relating to an identified or identifiable individual. For the purposes of this Privacy Policy, personal information does not include de-identified or aggregated information and, to the extent permitted by law, does not include information that is lawfully available to the public or lawfully available in government records.

**Our services are not available to users in mainland China.**

## I. Information Collected

In the course of using Safeheron services, we may collect information that is voluntarily provided while using our services or as a result of using our services in the following manner:

**1.1. Institutional Data**: Employer identification number (or other similar government-issued number) and/or personal identification information for all significant beneficial owners and/or a list of current directors of the institution, size of the institution's personnel, and type of business conducted.

**1.2. Contact Information**: Telephone number and/or e-mail.

**1.3. Geographic Location Data**: IP address, country code, postal code, working address of the institutional customer.

**1.4. Account Information**: Account name, customer ID, password and/or user name.

**1.5. Transaction Data**: Information about transactions made on our Platform, such as details of trade orders, amounts and/or timestamps of virtual assets held in your account.

**1.6. Usage Data**: Authentication data, clickstream data, cookies, pixel tags and other similar tools that uniquely identify your browser, as well as your consent to collect any of the data mentioned thereof.

**1.7. Technical Information**: Device type, classification and model number, unique device identification number (e.g. OAID, AndroidID, IDFV, IDFA, GAID, IMEI), source of submission (Web or App), telecommunication carrier information, browser type and version, browser plug-in type and version, application version and SDK version, operating system and platform, language settings, privacy preferences, time zone settings, diagnostic data, such as crash logs and any other data we collect to obtain your consent when required and other information stored or available to measure technical diagnostics on the devices that allow us access when you visit the Site or use service/application, the full URL clickstream to, through and from the service, cookie identifiers and your activity.

**1.8. Marketing and Communications Data**: Marketing communications preferences, survey responses, information provided to our support, business, sales team and/or user research team.

**1.9. Risk Management Data**: Personal credit information, including payment history, credit information and debt information, etc. legal data, litigation-related, case-involved information, compliance assessment, risk assessment, risk level, KYC certification results and reasons for KYC failure.

**1.10. Financial Data**: Bank account information (e.g. account number, sort code), remittance account, bank account type (SWIFT/ABA), SWIFT code, ABA number, legal tender deposit certificate information, currency, deposit amount, withdrawal amount, payment card master account number (PAN), cryptocurrency deposit address.

1.11. Information Collected Through APIs and SDKs: Some of the information described above (in particular Technical Information and Usage Data) may be collected automatically through application programming interfaces ("APIs") and software development kits ("SDKs") provided by us or by third parties and integrated into our Site, App or Services (for example, analytics, diagnostic and crash-reporting tools). Please see Section III and Section VII for further details on third-party collection and sharing.

## II. Use of Personal Information Collected

Information collected may be used for the following purposes:

| Purpose of Collection                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Categories of Personal Information                                                                                                                                                                                                              | Information Retention                                           |
| --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------- |
| Registering a new client                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | <p>• Account Information<br>• Contact Information<br>• Financial Data</p>                                                                                                                                                                       | Duration of relationship + 5 years after cancellation           |
| Implementation and compliance with anti-money laundering requirements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | <p>• Account Information<br>• Contact Information<br>• Financial Data<br>• Institutional Data</p>                                                                                                                                               | Duration of relationship + 5 years after cancellation           |
| Processing and providing our services and any application functionality to you, including the execution, management and processing of any instructions or orders placed by you                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | <p>• Contact Information<br>• Financial Data<br>• Transaction Data<br>• Marketing and Communication Data</p>                                                                                                                                    | 10 years                                                        |
| Ensuring proper management of our payments, fees and charges, as well as the recovery and collection of monies due to us                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              | <p>• Account Information<br>• Contact Information<br>• Financial Data</p>                                                                                                                                                                       | 10 years                                                        |
| Managing risk and preventing crime, including conducting anti-money laundering, counter-terrorism, sanctions screening, fraud and other background checks, detecting, investigating, reporting and preventing financial crimes broadly defined, complying with laws and regulations that apply to us and responding to and resolving complaints                                                                                                                                                                                                                                                                                                                       | <p>• Contact Information<br>• Account Information<br>• Financial Data<br>• Technical Information<br>• Transaction Data<br>• Data that may be disclosed through KYC or other background checks (Ex: Reported in media or available publicly)</p> | Duration of relationship + 6 years after cancellation           |
| To enable users to properly engage and use our services, and in the event of unusual usage scenarios, use this data to locate and resolve any issues. We can also recommend more suitable products/services based on the needs of your organization                                                                                                                                                                                                                                                                                                                                                                                                                   | <p>• Contact Information<br>• Account Information<br>• Technical Information<br>• Usage Data<br>• Marketing and Communication Data</p>                                                                                                          | Duration of relationship + 6 years after cancellation           |
| Collecting marketing data to study customer behavior, including their preferences, interests and how they use our products/services to determine our marketing campaigns and grow our client base                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | <p>• Account Information<br>• Contact information<br>• Technical Information<br>• Usage data<br>• Marketing and Communication Data</p>                                                                                                          | Duration of relationship + 5 years after cancellation           |
| <p>Managing and protecting our services and social media channels, including bans, troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting<br>We collect your personal information to improve security, monitor and verify identity/service access, combat spam/ malware/security risks, and to comply with applicable security laws and regulations. The threat landscape online is constantly evolving, making it essential that we have accurate and updated information regarding your use of our services. Without processing your personal information, we may not be able to ensure the security of our services</p> | <p>• Account Information<br>• Contact Information<br>• Financial Data<br>• Technical Information<br>• Usage Data<br>• Transaction Data</p>                                                                                                      | Duration of relationship + 5 years after cancellation           |
| To provide you with relevant services and advertisements and to measure or understand the effectiveness of the advertisements provided to you                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         | <p>• Account Information<br>• Contact information<br>• Technical Information<br>• Marketing and Communication Data</p>                                                                                                                          | Duration of relationship + 5 years after cancellation           |
| Using data analytics to improve our services, marketing, customer relationships and experience                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        | <p>• Technical Information<br>• Usage Data</p>                                                                                                                                                                                                  | Duration of relationship + 5 years after cancellation           |
| Use of services on social media platforms or advertising platforms, some of which may involve using the data received for their own purposes, including marketing                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     | <p>• Technical Information<br>• Usage Data</p>                                                                                                                                                                                                  | Duration of relationship + 5 years after cancellation           |
| Use of services on financial institutions, crime and fraud prevention companies, and risk measurement companies to proactively prevent crime and fraud                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | <p>• Account Information<br>• Contact information<br>• Risk Management Data<br>• Financial Data<br>• Transaction Data<br>• Technical Information<br>• Usage Data</p>                                                                            | Duration of relationship + 5 years after cancellation           |
| Recording voice calls and communications for compliance, customer relationship maintenance, quality assurance and training purposes                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | <p>• Account Information<br>• Contact information<br>• Financial Data<br>• Transaction Data</p>                                                                                                                                                 | Duration of relationship + 5 years after cancellation           |
| Diagnosing and resolving faults as soon as possible in the event of any malfunction affecting your use of the service (e.g. program crashes, functional abnormalities, display abnormalities) in order to enhance your user experience                                                                                                                                                                                                                                                                                                                                                                                                                                | • Technical data (including diagnostic data)                                                                                                                                                                                                    | Duration of relationship + more than 5 years after cancellation |

For the avoidance of doubt, we do not use User Data (as defined in the Safeheron License Agreement), including your Key Shards and the contents of your wallets, or any information derived therefrom, for advertising, marketing or profiling purposes or for the benefit of any third party, nor do we sell or otherwise commercialise User Data.

## III. Sharing and Transfer of Personal Data

### 3.1. Sharing

We will not share your user information with other organizations and individuals, except for the following:

3.1.1. Sharing with explicit consent: We may share your information with other parties after your explicit consent.

3.1.2. Sharing under legal circumstances: We may share your information with the public in accordance with the provisions of laws and regulations, the need for litigation or arbitration settlement, or as requested by administrative or judicial authorities in accordance with the law.

3.1.3. Sharing with our affiliates: We may share your information with our affiliates and members of our corporate group where necessary to provide the Services and for the purposes described in this Privacy Policy. Our affiliates are bound by this Privacy Policy.

3.1.4. Sharing with service providers: We may share your information with third-party service providers that process it on our behalf and under our instructions, including cloud infrastructure and hosting providers (on whose servers the two Key Shards held by us and other data are stored), analytics providers, communication and email delivery providers, customer support tools, identity verification and KYC vendors, and our professional advisers and auditors. These providers may only access and process your information to the extent necessary to perform their functions for us and are bound by contractual obligations of confidentiality and data protection.

3.1.5. Sharing in connection with Third Party Services you enable: The Services may allow you to enable, activate or use optional services provided by external and independent third parties, as described in the Safeheron Product Specific Terms — for example, compliance analytics and screening providers under the Compliance Integrations feature. If you elect to use a Third Party Service, you authorise us to share your information (including, without limitation, wallet addresses and Transaction Data) with the relevant third party to the extent necessary to enable, integrate, use or access that Third Party Service. Such third parties act as independent controllers and process your information under their own privacy policies, which we recommend you review before enabling the relevant service. The current list of third-party providers, together with links to their privacy policies, is set out in the Product Specific Terms (Schedule 1 — Third Party List). Where you make the Services or any Third Party Service available to your own end users, you are responsible for notifying those end users and obtaining all required consents before their information is shared.

3.1.6. Collection and sharing through third-party APIs and SDKs: Our Site, App and Services integrate certain third-party APIs and SDKs (for example, Google Analytics and other analytics, diagnostic and crash-reporting tools), which may collect certain information described in Section I directly from your device. Please see Section VII (How We Use Cookies) for further details.

The principal third parties, SDKs and APIs currently integrated into, or made available through, the Site, App and Services are set out in the table below. We will update this table from time to time as our integrations change:

| **Third Party**               | **Type**                                          | **Purpose**                        | **Data Involved**                  | **Privacy Policy**                                                                            |
| ----------------------------- | ------------------------------------------------- | ---------------------------------- | ---------------------------------- | --------------------------------------------------------------------------------------------- |
| Google Analytics (Google LLC) | Cookies / analytics SDK                           | Statistical analysis of Site usage | Technical Information; Usage Data  | [www.google.com/policies/privacy/partners/](http://www.google.com/policies/privacy/partners/) |
| MistTrack (SlowMist)          | Compliance Integration (optional; enabled by you) | Compliance analytics / screening   | Wallet addresses; Transaction Data | <https://sso.slowmist.com/en/privacy/>                                                        |
| Elliptic                      | Compliance Integration (optional; enabled by you) | Compliance analytics / screening   | Wallet addresses; Transaction Data | <https://www.elliptic.co/privacy-policy/>                                                     |
| Chainalysis                   | Compliance Integration (optional; enabled by you) | Compliance analytics / screening   | Wallet addresses; Transaction Data | <https://www.chainalysis.com/privacy-policy/>                                                 |

### 3.2. Transfer

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

3.2.1. Transferring with express consent: We may transfer your information to other parties after obtaining your express consent.

3.2.2. In the event of a merger, acquisition or liquidation of Safeheron with another legal entity, or other merger, acquisition or liquidation involving the transfer of user information, we will require the new company or organization holding your data to continue to be bound by this Policy, or we will require that company, organization or individual to seek your authorized consent again.

### 3.3. Exceptions for sharing and transferring user information with prior authorized consent

Your prior authorized consent is not required to share or transfer your user information in the following cases:

3.3.1. Related to national security and national defense security.

3.3.2. Related to public safety, public health, and significant public interest.

3.3.3. Related to crime investigation, prosecution, trial and sentence enforcement, etc.

3.3.4. For the purpose of safeguarding yours or another individual's significant legal rights and interests, such as life or property, including circumstances where it is difficult to obtain your consent.

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

## IV. Protecting Your Personal Information

We strive to safeguard the security of our users' information against loss, misuse, alteration, and unauthorized access or disclosure.

4.1. We will use a variety of security protections to safeguard information within a reasonable level of security. For example, we will use encryption technology (e.g., SSL), MPC, de-identification, anonymization processing, etc. to protect your personal information.

4.2. We’ve established special management systems, operating procedures and organizations to safeguard information. For example, we strictly limit the scope of people who can access your information, as we require them to comply with confidentiality obligations and conduct routine audits.

4.3. In the unlikely event of a personal information leak, we will promptly notify you by email, push notification, and other forms of communication in a timely manner, and in any event within any specific notification period agreed with you (including the twenty-four (24) hour Security Incident notification commitment under the Safeheron License Agreement, where applicable) or required by applicable law, and we will bear the corresponding legal responsibility. At the same time, we will also take the initiative to report the disposition of the incident in accordance with the requirements of the regulatory authorities.

4.4. We have met the requirements of ISO27001 certification standard in terms of information security and have obtained the corresponding certification.

4.5. We will take all reasonable steps to ensure that no unrelated personal information is collected. We will only retain your personal information for as long as is necessary to achieve the purposes described in this policy, unless an extended retention period is required or permitted by law.

## V. Your Rights

You are entitled to certain rights in relation to your personal information.

5.1. You’re allowed two requests per calendar year for the following:

> a) Specific personal information we collect about you
>
> b) Categories of personal information we collect about you
>
> c) Categories of sources from which we collect your personal information
>
> d) Business purposes for which we collect your personal information

5.2. If you believe that the personal information we have collected is inaccurate, you can request a correction on the personal information collected.

5.3. To receive the personal information you provide to us in a structured, common and machine-readable format and transfer it to other data controllers (data migration).

5.4. To restrict or object to the processing of your personal information for compelling and legitimate reasons related to your particular situation, unless such processing is expressly provided for by law.

5.5. To file a complaint with the regulatory authority where you live or where the issue of the subject of the complaint arose. We will not discriminate against you for exercising any of these rights. If you wish to make a request for additional information, please contact us using the information provided in the "Contact Us" section below.

5.6. You may make a request to us to delete personal information in the following cases:

> 1\) If our handling of personal information violates laws and regulations.
>
> 2\) If we collect and use your personal information without your consent.
>
> 3\) If our processing of personal information is in breach of our agreement with you.
>
> 4\) If you no longer use our products or services, or if you wish to terminate your account.
>
> 5\) If we no longer provide products or services to you.

5.7. For security purposes, you may need to provide a written request or otherwise to prove your identity. We may ask you to verify your identity before we process your request. We will respond within thirty days, and if you are not satisfied, you may also reach out by submitting an email to <feedback@safeheron.com> to make a complaint. In principle, we do not charge a fee for reasonable requests, but we may charge a fee for repeated requests that exceed reasonable limits, as we deem appropriate. We may deny requests that are unwarrantedly repetitive, require excessive technical configuration (Ex: Requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (Ex: Involving the backup of information to be stored on tapes).

5.8. We will not be able to respond to your request in the following cases:

> 1\) Obligations of a controller of personal information under laws and regulations.
>
> 2\) Directly related to national security and/or national defense security.
>
> 3\) Directly related to public safety, public health, and significant public interest.
>
> 4\) Directly related to criminal investigation, prosecution, trial and enforcement of sentences.
>
> 5\) Where the controller of personal information has sufficient evidence of subjective malice or abuse of rights by the subject of personal information.
>
> 6\) For the purpose of safeguarding the life, property, and other significant legitimate rights and interests of the subject of personal information or other individuals, but where it is difficult to obtain the consent of the individual.
>
> 7\) When responding to the request of the subject’s personal information will result in serious damage to the legitimate rights and interests of the subject’s personal information or other individuals or organizations; involving commercial interest.

## VI. Collection of Information on Minors

6.1. Our products, websites, and services are primarily intended for adults. Minors should not create their own personal information accounts without the consent of their parents or legal guardians.

6.2. In the case of personal information collected from minors with parental consent, we will only use or publicly disclose this information as permitted by law, with the express consent of the parent or legal guardian, or as necessary to protect the minor.

6.3. Although local laws and customs define minors differently, we consider any person under the age of 13 to be a minor.

6.4. If we find that we have collected personal information from a minor without prior verifiable parental consent, we will seek to delete the relevant data as soon as possible.

## VII. How We Use Cookies

We collect certain information through tracking technologies used on the Site, such as cookies (data files placed on devices used to access the Site), mobile analytics software, and pixel tags (transparent graphic images, sometimes called web beacons or tracking beacons, placed on web pages or emails that indicate that a page or email has been viewed and may tell your browser to fetch content). We do this to analyze trends, track users' movement around the Site, gather demographic information, and generally collect information that we believe to be insightful or useful. For security purposes, we or our third-party service providers may place cookies or similar files on your device to facilitate site navigation. We may use social media platform cookies to improve our user experience.

Most browsers allow you to control cookies, including whether to accept them and how to delete them. You can set most browsers to notify you when you receive a cookie, or you can choose to block cookies using your browser; however, please note that some features of the Site may not function properly or may be slowed down if you reject cookies. If you block or delete a cookie, not all of the tracking we described in this Privacy Policy will stop.

We use cookies provided by **Google Analytics** to collect statistical information about the use of the Site. We use Google Analytics to learn more about the types of users who visit the Site, their activities on the Site, and to help improve the Site. In order to provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to: information about your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you access the Site, and other information about you. You can visit [www.google.com/policies/privacy/partners/](https://www.google.com/policies/privacy/partners/) to learn more about Google Analytics and how it collects and processes data, including how it controls the information sent to Google. You can opt out of Google Analytics here [tools.google.com/dlpage/gaoptout](https://tools.google.com/dlpage/gaoptout) (this requires you to install a browser plug-in).

In addition to cookies and similar technologies used on the Site, our App and Services may integrate third-party SDKs and APIs, such as analytics, performance monitoring and crash-reporting tools. These third-party SDKs may collect Technical Information and Usage Data described in Section I directly from your device in order to provide their functions. We review the data practices of such providers before integrating their SDKs. The principal third-party SDKs and services, and links to their privacy policies, are set out in the table in Section 3.1.6 above; third-party services that you may elect to enable are further listed in the Product Specific Terms (Schedule 1 — Third Party List).

Some web browsers may provide an option whereby you can request that your browser notify the website you are visiting that you do not want your activity to be tracked by a cookie or other persistent identifier (often referred to as a ‘do not track’). The Site does not currently respond to ‘Do Not Track’ signals.

Different types of cookies can be used for specific purposes, e.g.

| Cookie Category                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | Period         |
| ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------- |
| <p><strong>Absolutely Necessary Cookies</strong><br>These cookies are necessary for the service to function and cannot be turned off on our system. They are typically set only for actions you take deemed as service requests, such as setting your privacy preferences, logging in, or filling out a form. You can set your browser to block or alert you to these cookies, but some parts of the Site will not work properly. These cookies do not store any personally identifiable information.</p>                             | Up to 365 days |
| <p><strong>Performance Cookies</strong><br>These cookies allow us to calculate the number of visits and sources of traffic so that we can measure and improve the performance of our Site. They help us to understand which pages are most and least popular and to see how visitors move around the Site. All information collected by these cookies are aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Site and will not be able to monitor its performance.</p> | Up to 2 years  |
| <p><strong>Functional Cookies</strong><br>These cookies enable our services to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function properly.</p>                                                                                                                                                                                                       | Up to 365 days |
| <p><strong>Location Cookies</strong><br>These cookies may be set by our advertising partners through our website. These companies may use them to build a profile of your interests and to show you relevant advertisements on other websites. They do not store personal information directly, but are based on uniquely identifying your browser and Internet device. If you do not allow these cookies, you will experience less targeted advertising.</p>                                                                         | Up to 365 days |
| <p><strong>Social Media Cookies</strong><br>These cookies are set up by a series of social media services that we add to our website to enable you to share our content with your friends and network. They enable them to track your browser on other sites and build a profile of your interests. This may affect the content and messages you see on the other sites you visit. If you do not allow these cookies, you may not be able to use or view these sharing tools.</p>                                                     | Up to 365 days |

## VIII. How Long We Retain Your Personal Data

We will retain your personal information for as long as required or permitted by law or in accordance with the retention policies that we may establish from time to time. We consider the following factors for determining the duration of such retention; the time required to retain personal information for business purposes; the maintenance of corresponding business records; improving the performance and quality of the Site and Platform; the processing of your inquiries; whether we reasonably believe that the data is needed to process any litigation; and whether legal and contractual obligations impose any requirements for data retention.

Please refer to the ‘Use of Personal Information Collected’ section above for the relevant retention periods for each Purpose of Collection.

In addition, upon suspension or closure of your Account, you will have fourteen (14) calendar days (unless otherwise agreed with us in writing) to export the information and records previously stored in your Account, after which the Key Shards stored with us will be destroyed. We may retain records and copies of the data stored in such Account for record-keeping purposes and compliance with applicable laws, in accordance with the Safeheron License Agreement.

## IX. Cross-Border Data Transmission

Given that we are an international company, our use of your personal information necessarily involves cross-border data transfers. Safeheron processes and stores data on servers in Hong Kong, China. When we transfer data across borders, we do so in accordance with applicable data protection laws. For example, we may use standard contractual clauses when we transfer data from the European Economic Area to jurisdictions that are not considered to have an adequate level of data protection. In the absence of an adequate decision or standard contractual terms or any other right to transfer your data, we may rely on your consent as the basis for such transfers.

## X. Cancellation of E-mail Services

You can unsubscribe from receiving marketing and promotional messages from us at any time by:

10.1. Selecting the unsubscribe link in the message we send you, or

10.2. Using the information provided in the ‘Contact Us’ section below to contact us. Please note that even if you choose not to receive the above emails, we will still send you a reply when you contact us for other reasons related to your use of our Site or Platform.

## XI. Update of Privacy Policy

Rights will not be reduced under the personal information protection policy without your express consent. We will post any changes made to this policy on our website or app. When changes are made to the Privacy Policy, we will promptly notify you of the changes to the Privacy Policy by email, push notification, and change the ‘last updated’ date on our blog. If you do not agree with the revised policy, we advise you to stop using our Platform and services. We will also keep an older version of this policy on file for you to review.

## XII. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at <privacy@safeheron.com>. Generally, we will respond within thirty days. If you are not satisfied with our response, especially if you believe our personal information processing practices have infringed on your legal rights, you may also seek a resolution through government, courts, or other relevant agencies.
