Safeheron 用户及隐私协议

Safeheron 用户协议

更新于：2023 年 03 月 16 日

更新日志

版本号	更新内容	更新时间	生效时间
V1.0.0	创建文档	2022.05.16	2022.05.16
V1.0.1	新增如下条款： 十五、您个人信息的安全 我们使用管理、物理和技术安全措施来保护我们收集和处理的个人信息。我们的安全控制旨在维护您个人信息的机密性、完整性和可用性，并防止合理预期的威胁。	2022.11.11	2022.11.11
V1.0.2	修改如下条款： 十五、您个人信息的安全 条款改为“您的个人信息安全”，内容中细化了关于数据安全性、隐私性的描述	2022.11.21	2022.11.21
V2.0.0	全新版本用户协议	2023.3.16	2023.3.16

1. Acceptance of Terms

1.1 In these terms and conditions which may be amended from time to time (“Terms”), references to “SAFEHERON”, “we”, or “us” refer to SAFEHERON Pte. Ltd., a company duly incorporated under the laws of Singapore, and the term “our” shall be construed accordingly.

1.2 “You” refers to any person accessing and/or using the Services pursuant to the Account Subscription (as defined herein), and includes a person, company, corporation, or any other organization that has an Account Subscription (collectively with SAFEHERON, the “Parties”, and each, a “Party”).

1.3 We may revise these Terms from time to time in our sole and absolute discretion, with any changes published and made available on our website or mobile application. We will also notify you of such changes via push notifications through the App and/or email. These changes shall take effect from the date of publication of the new terms or such other date stated in the notice, and your continued access or use of our Services from such date shall be deemed to constitute acceptance of the new Terms in their entirety. It shall be your sole responsibility to check our website for such changes from time to time. Please review these Terms periodically to ensure that you understand all of the Terms.

1.4 Your access and use of our Services is subject to these Terms, any applicable laws and other notices, policies or conditions uploaded by SAFEHERON to https://blog.safeheron.com/blog/v/jian-ti-zhong-wen-2/chan-pin/bang-zhu/safeheron-yong-hu-ji-yin-si-xie-yi By accessing and using any part of the Services, or clicking the checkbox acknowledging acceptance of these Terms, you irrevocably and unconditionally agree to be bound by the latest version of the Terms without variation or modification. If you do not agree to these Terms, please exit the website and cease usage of the Services immediately.

2. Definitions

“Account” refers to the account created in accordance with the process described in Clause 3.1 which will be controlled and secured by you, and used to access the Services.

“Account Subscriptions” has the meaning given in Clause 4.1.

“Actual Monthly Uptime Percentage” means the percentage of minutes during the month in which SAFEHERON actually made available to you the Services, in the manner calculated in Clause 7.1.

“App” means the SAFEHERON mobile application, API Co-signer, browser extension or web console application provided by us.

“API” means application programming interface which enables applications to interact with each other.

“Authorised Users” has the meaning given in Clause 3.1.

“Business Day” means a day other than a Saturday, Sunday, or public holiday in Singapore, when banks in Singapore are open for business.

“Claim” has the meaning given in Clause 13.1.

“Committed Monthly Uptime Percentage” means the percentage of minutes during the month in which SAFEHERON shall make available to you the Services, set out in Clause 7.1.

“Confidential Information” has the meaning given in Clause 15.1.

“Discloser” has the meaning given in Clause 15.1.

“Documentation” refers to the documents made available to you by SAFEHERON online via https://blog.safeheron.com/blog/ or such other web address notified by SAFEHERON to you from time to time which sets out a description of the Services and the user instructions for the Services.

“Duration” has the meaning given in Clause 16.1.

“Force Majeure Event” means any event beyond SAFEHERON’s reasonable control (and which does not relate to or arise by reason of SAFEHERON’s default or negligence) which renders impossible or hinders SAFEHERON’s performance of these Terms, including without limitation:

(a) war, riot, civil unrest or revolution, sabotage, terrorism, insurrection, acts of civil or military authority, imposition of sanctions, embargo, breaking off of diplomatic relations or similar actions;

(b) terrorist attacks, civil war, civil commotions or riots;

(c) acts of God, epidemic, pandemic, flood, earthquake, typhoon or other natural disasters or adverse weather or environmental condition;

(d) any act of state or other exercise of sovereign, judicial or executive prerogative by any government or public authority, including expropriation, nationalization, imposition of an export or import restriction, quota or prohibition, or compulsory acquisition or acts claimed to be justified by executive necessity;

(e) fire, explosion or accidental damage;

(f) collapse of building structures or failure of plant machinery, computers or vehicles;

(g) interruption in telecommunications or Internet services or network provider services, or failure of equipment or software;

(h) hacks, mining attacks (including but not limited to double-spend attacks, majority mining power attacks and “selfish-mining” attacks), smurfing, phishing, sybil attacks, distributed denial of service, a “fork” of the blockchain which may result in more than one version of the Supported Digital Asset, cyber-attacks, and any fraudulent activity on the part of a third party;

(i) interruption or failure of utility service, including but not limited to electric power, gas or water; or

(j) any labour disputes, including but not limited to strikes, industrial action or lockout.

“Indemnified Parties” has the meaning given in Clause 13.1.

“Initial Duration” has the meaning given in Clause 16.1.

“Key Shards” means a group of random numbers generated by our MPC algorithm.

“Privacy Policy” refers to our privacy policy which we may amend from time to time, accessible at https://blog.safeheron.com/blog/v/jian-ti-zhong-wen-2/chan-pin/bang-zhu/safeheron-yong-hu-ji-yin-si-xie-yi#safeheron-yin-si-zheng-ce.

“Quarter” means a period of three (3) calendar months

“Recipient” has the meaning given in Clause 15.1.

“Renewal Duration” has the meaning given in Clause 16.1.

“Service Credit” is a dollar credit, calculated in the manner set forth in Clause 7.2 that we may credit to your Account.

“Services” means the service(s) provided by SAFEHERON to you via https://www.safeheron.com/console or the App or any other website notified to you from time to time, as more particularly described in Clause 6.

“Software” means any software or application developed and released by SAFEHERON as part of the Services, which includes, for the avoidance of doubt, the Apps.

“Subscription Fee” means the aggregate subscription fees payable by you to SAFEHERON for Account Subscriptions, as set out in a separate quotation we will provide to you, and which may be amended and modified from time to time.

“Supported Digital Assets” means any digital asset which is a digital representation of value based on (or built on top of) a cryptographic protocol of a computer network which has been approved by and/or supported by SAFEHERON for use in connection with the Services from time to time. Please refer to https://blog.safeheron.com/blog/product-and-solution/integration-currencies for the list of Supported Digital Assets.

“User Data” means the data inputted by you, the Authorised Users, or SAFEHERON on your behalf for the purpose of using the Services, or facilitating your use of the Services, other than personal data.

“User Key Shard” has the meaning given in Clause 6.2.2.

“Virus” means any thing or device (including any software, code, file or programme) which may: prevent, impair or otherwise adversely affect the operation of any computer software, hardware or network, any telecommunications service, equipment or network or any other service or device; prevent, impair or otherwise adversely affect access to or the operation of any programme or data, including the reliability of any programme or data (whether by re-arranging, altering or erasing the programme or data in whole or part or otherwise); or adversely affect the user experience, including worms, trojan horses, viruses and other similar things or devices.

“Vulnerability” means a weakness in the computational logic (for example, code) found in software and hardware components that when exploited, results in a negative impact to the confidentiality, integrity, or availability of the Services, and the term “Vulnerabilities” shall be interpreted accordingly.

3. Account Creation, Closure and Suspension

3.1 Account Creation: To use the Services, you must create an Account by providing SAFEHERON with the requested information necessary for us to comply with applicable laws (including anti-money laundering and countering the financing of terrorism laws) in connection with the provision of Services to you. During your application, you must notify us of the number of users which are authorised to use your Account, the Services, Software and the Documentation (“Authorised Users”). The number of Authorised Users per Account shall not exceed thirty (30). We may, in our sole discretion, refuse to allow you to establish an Account, limit the number of Authorised Users per Account, or limit the number of Account Subscriptions. If there is any change to the number of Authorised Users or Account Subscriptions at any point in time, you must notify SAFEHERON immediately and the applicable Subscription Fee shall apply. Such Subscription Fee shall be pro-rated from the date of activation or deactivation of the Account Subscriptions.

3.2 The Account will track the information regarding balances associated with the public blockchain addresses registered in the Account and any other transactions you effect through the use of the Services, such as transaction history, pending and posted transfers. The Account will also reflect the Supported Digital Assets balance associated with the respective blockchain addresses linked to your Account.

3.3 Save for such persons notified to SAFEHERON as Authorised Users of the Account, you shall not grant permission to any third party or non-permissioned user access or connection to your Account, whether through the third party’s product or service or through our website. You acknowledge that granting permission to such third party or non-permissioned user to take specific actions on your behalf does not relieve you of any of your responsibilities under these Terms and will instead violate the Terms, including but not limited to Clause 4.2. You are fully responsible for all acts or omissions of any third party or non-permissioned user with access to your Account. You further acknowledge and agree that you will not hold SAFEHERON responsible for, and will indemnify SAFEHERON from, any liability arising out of or related to any act or omission of any third party or non-permissioned user with access to your Account. You shall use all reasonable endeavours to prevent any unauthorised access to, or use of, the Services, Software and/or Documentation. In the event of such unauthorised access or use, you undertake that you will promptly notify the SAFEHERON support team.

3.4 Suspension of Services: SAFEHERON reserves the right to suspend your access to your Account without any refund and you agree and acknowledge that we shall have no liability in respect thereof if:

3.4.1 you have breached any of any of your undertakings or obligations in these Terms, including for the avoidance of doubt, Clauses 3.3, 4.2 and 8.3;

3.4.2 any of your representations or warranties in these Terms turn out to be false, misleading, inaccurate or incomplete, including for the avoidance of doubt, Clauses 8.3 and 9.2.1;

3.4.3 you have failed to pay any amount due under these Terms on the due date for payment and remain in default not less than thirty (30) days after being notified in writing to make such payment;

3.4.4 we are required to do so under any applicable law(s) or pursuant to any request by any governmental or regulatory body, and we may reinstate your access once the issue has been resolved to our satisfaction.

3.5 You may also request that SAFEHERON suspend the access to your Account for any reason, and such request will be effected within three (3) Business Days from the time we receive your request to suspend the Account. For such purposes, only Authorised Users with the required privileges may initiate such suspension requests and SAFEHERON shall be entitled to deem that such Authorised Users have the requisite authority to suspend access to the Account. You may request that access to your Account be restored by contacting our support team via the instant messaging application on our website or App, or by emailing us at [e-mail].

3.6 Upon suspension of your Account for any reason, you will have seven (7) calendar days (unless otherwise agreed with us in writing) to export all information and records previously stored in your Account. Thereafter, the Key Shards stored with us will be destroyed and your (as well as your Authorised Users’) access to the Account will be terminated. We may keep records and copies of the data stored in such Account for record-keeping purposes and compliance with applicable laws.

3.7 Upon closure of your Account for any reason, the Key Shards stored with us will be immediately destroyed and your (as well as your Authorised Users’) access to the Account will be terminated. We may keep records and copies of the data stored in such Account for record-keeping purposes and compliance with applicable laws.

4. Account Subscriptions

4.1 Subject to you purchasing the account subscription(s) pursuant to the payment terms set out in Clause 5 each of which entitles you to register up to thirty (30) Authorised Users to access and use the Services, Software and the Documentation in accordance with these Terms (“Account Subscriptions”), SAFEHERON hereby grants you a limited, revocable, non-exclusive, non-transferable right and licence, without the right to grant sublicences, to use the Services, Software and Documentation for your own personal or internal business operations. Neither you, nor your Authorised Users, employees, directors, contractors or affiliates shall use the Services, Software and Documentation for any purpose other than the aforementioned purpose.

4.2 You hereby undertake the following:

4.2.1 you will not allow or suffer any Account Subscription to be used by more than thirty (30) individual Authorised Users (for the avoidance of doubt, nothing in this Clause shall prevent you from reassigning in its entirety, user privileges and access to the Account held by an existing Authorised User to a new user);

4.2.2 the maximum number of Authorised Users that you authorise to access and use the Account, the Services, Software and the Documentation shall not exceed thirty (30) Authorised Users per Account Subscription you have purchased from time to time;

4.2.3 each Authorised User will keep secure their password(s) for their use of your Account, the Services, Software and Documentation, and that each Authorised User shall keep their password confidential;

4.2.4 you shall maintain a written, up to date list of current Authorised Users and provide such list to SAFEHERON within five (5) calendar days of SAFEHERON’s written request at any time or times;

4.2.5 during the course of your use of the Account, Services, Software and/or Documentation, you shall not access, store, distribute or transmit any Viruses or any material that:

4.2.5.1 is unlawful, harmful, threatening, defamatory, obscene, infringing, harassing or racially or ethnically offensive;

4.2.5.2 facilitates illegal activity;

4.2.5.3 depicts sexually explicit images;

4.2.5.4 promotes unlawful violence;

4.2.5.5 is discriminatory based on race, gender, colour, religious belief, sexual orientation, disability; or

4.2.5.6 is otherwise illegal or causes damage or injury to any person or property;

4.2.6 you shall not attempt to obtain, or assist third parties in obtaining, access to your Account, the Services, Software and/or Documentation in a manner circumventing these Terms; or

4.2.7 introduce or permit the introduction of, any Virus or Vulnerability into SAFEHERON’s or its subcontractors’ network, servers and information systems,

and we reserve the right, without liability or prejudice to our other rights against you, to disable your access to the Account and terminate your Account Subscription without any refund of the Subscription Fee upon your breach of any of the above undertakings.

5. Payment Terms

5.1 You shall pay the Subscription Fee to SAFEHERON for the Account Subscription(s) you wish to purchase in accordance with this Clause 5. Please refer to the price list set out in the quotation sent to you for the applicable Subscription Fee payable.

5.2 The Subscription Fee and billing cycle may be revised by us in our sole and absolute discretion from time to time, save that we shall provide you with at least seven (7) calendar days prior notice before the revised Subscription Fee and billing cycle takes effect. If you do not agree to the revised Subscription Fee and/or revised billing cycle, your sole and only recourse shall be to terminate your Account Subscription(s) in accordance with Clause 16.2.2.3 and cease all usage of the Account, Services, Software and/or Documentation. Any copies of the Documentation or materials and information obtained from the use of the Services or Software must be destroyed.

5.3 As at the date of these Terms, the billing cycle is on a quarterly basis. We will issue you an invoice by the seventh (7th) day of each Quarter by sending an electronic invoice to the email address you have registered with us. Each invoice must be paid within thirty (30) calendar days.

5.4 Payment may be made by wire transfer or other such payment methods as designated by SAFEHERON pursuant to the billing instructions to be provided to you by SAFEHERON.

5.5 If we have not received payment by the due date stated in Clause 5.3, without prejudice to any other rights and remedies available to us in these Terms:

5.5.1 we may, without liability to you, disable your Account and access to all or part of the Services, Software and/or Documentation and we shall be under no obligation to provide any or all of the Services, Software and/or Documentation while the invoice(s) concerned remain unpaid (and during such time, Clause 3.6 may be applied by us);

5.5.2 interest shall accrue on a daily basis on such due amounts at a monthly rate of 1.5%, commencing on the due date and continuing until fully paid, whether before or after judgment; and

5.5.3 we expressly reserve the right to determine whether to permit you to renew your Account Subscription(s) following full payment and settlement of the overdue invoice.

5.6 All amounts and fees stated or referred to in these Terms:

5.6.1 shall be payable in US dollars;

5.6.2 are non-cancellable and non-refundable (save as provided in Clause 16.2.3); and

5.6.3 are exclusive of goods and services tax which shall be added to our invoice at the appropriate prevailing rate.

5.7 All fees payable under these Terms shall not be subject to any set-off or deduction.

6. Services Provided

6.1 SAFEHERON shall, during the Duration provide the Services described in Clauses 6.2 and 6.3 to you if our onboarding processes have been completed and your application for an Account has been approved.

6.2 Private Key Self-Management Services:

6.2.1 Private key sharding service: Our in-house developed algorithm enables you to generate three (3) Key Shards from your private key. When transactions need to be signed, the signature of the original private key will be computed from all of the Key Shards which make up the private key by running it through our multi-party computation protocol. You may recover your original private key through our offline recovery tool, further described below.

6.2.2 Private Key Shard storage service: SAFEHERON will only have access to and control over two (2) of the Key Shards generated from your original private key, which Key Shards will be stored online on our cloud server, secured by encryption and other security management measures. You will have sole access to and control over the remaining Key Shard (“User Key Shard”). Each Key Shard (including the User Key Shard) will be secured by secret mnemonic phrases, which phrases can be backed up and stored offline on separate devices controlled by the relevant Authorised Users via the App. You are solely responsible for the safekeeping of the User Key Shard (and relevant secret mnemonic phrase), which will not be stored or accessible by us at any point in time. We will not be able to recover your private key even if you have lost or lost access to your User Key Shard or secret mnemonic phrase securing your User Key Shard.

6.2.3 Private Key Shard backup service: All three (3) Key Shards may be secured and backed up through the use of separate mnemonic phrases via our App. You may generate a unique set of mnemonic phrases for each Key Shard and will be solely responsible for the safekeeping of such mnemonic phrases. While we will be able to recover your access to the mnemonic phrases securing the two (2) Key Shards stored by us, we will not be able to do so for the User Key Shard as we do not have access to it. In the event that you lose the mnemonic phrases associated with the two (2) Key Shards held by us, we can recover it if you contact our support team via the instant messaging application on our website or App, or by emailing us at [e-mail].

6.2.4 Private key recovery tool: After you complete a local backup of user key shard’s mnemonic phrase, SAFEHERON will automatically and regularly email the private key recovery toolkit download link and backup recovery file to your registered email address. Using the private key recovery toolkit, you may recover your original private key offline with the three (3) mnemonic phrases associated with all three (3) Key Shards. For the avoidance of doubt, SAFEHERON does not, and will never, hold your original private keys and/or the Key Shards in a complete, singular form at any point of time.

6.3 Wallet Management Services:

6.3.1 We will provide you with a user interface accessible through your Account to enable you to manage your digital wallet. You may only carry out transactions from the Account once the Key Shards have been generated and you have completed your User Key Shard’s mnemonic phrase backup. Through the user interface, you may interact with the relevant supported blockchain and enjoy the following functions:

6.3.1.1 Receiving assets: You may use the App to generate a QR code as well as a blockchain address to receive Supported Digital Assets. Given the risk that the address may be tampered with or replaced during transmission, SAFEHERON recommends that you confirm the receiving blockchain address with the sender after the sender has received it.

6.3.1.2 Address whitelist: You may save recipient blockchain addresses on the App through the “whitelist” function. If there is more than one person operating the Account, we recommend that at least two Authorised Users with the “administrator” role check and verify that the whitelist address is accurate.

6.3.1.3 Sending assets: You may transfer Supported Digital Assets out of your linked digital asset wallet through the user interface to external recipients. You may set up and choose your preferred 2-factor authentication method for added security and where the Account is managed by multiple persons, the App may prompt Authorised Users with the relevant permissions for approval on the App. You should ensure that you have sufficient funds for the transfer, taking into account any transaction or network fees which may be incurred. These transaction fees are set by the third party blockchains and networks and SAFEHERON does not have any control or influence over such fees. We do not charge any fees for such transfers.

6.3.1.4 Transaction record: The App will also provide you with a record of the status of your transactions or your recent transaction history which may be downloaded or exported as a excel sheet for your own records.

6.3.1.5 Policy engine: Our policy engine enables you to customize and set your approval policies for transactions which may be carried out through the Account. You may configure triggering conditions based on up to five (5) dimensions (initiator, asset source, destination, asset type and amount). Specific member roles may be assigned and set by you. Once set, Authorised Users with the requisite permissions may modify the policies with the approval of Authorised Users with the “administrator” role. For the avoidance of doubt, SAFEHERON will not be able to make any changes to your approval policies. Please refer to Clauses 5.1 and 5.2 for further details on the Subscription Fee.

6.3.1.6 Web3 interaction: SAFEHERON provides a full suite of Web3 interaction solutions, including the App, browser extension and APIs. You may interact with Web3 applications through these Web3 interaction solutions while benefiting from the multi-party security processes and approval policies set in your Account.

6.3.1.7 API: You can configure your Account and thus the associated digital wallet using the APIs provided by SAFEHERON. As an example, you may automate transaction submissions or signature approvals. These APIs may be utilized either directly or, if applicable, indirectly within an independently developed application. However, all API-based services are subject to usage limits, which limits may be adjusted from time to time in our sole and absolute discretion. If you exceed such usage limits, or are unwilling to abide by such usage limits, we will include the fees payable for such excess use in the next billing cycle.

6.3.1.8 Audit log: The App will also keep an audit log which records all the in-application activities of Authorised Users managing the Account, including records of all interactions with the SAFEHERON support team. You may access and retrieve these records at any time.

6.4 Software and App Updates

6.4.1 SAFEHERON may from time to time provide updates and upgrades to Software. Such updates and upgrades (if any), and their frequency, will be determined and implemented at SAFEHERON’s sole discretion. You are responsible for ensuring that the latest version of the Software is installed on your device(s). Any use of outdated versions of the Software or incompatible devices will be at your sole risk and without prejudice to the generality of Clause 14.

6.4.2 If the blockchain of a Supported Digital Asset forks, we may temporarily suspend the use of our Services in relation to such affected digital asset. We reserve the sole and absolute discretion to determine whether or not to support the forked protocol. In any event, you may opt to transfer the affected digital asset out of your digital wallet.

7. Service Level

7.1 Service Commitment: SAFEHERON will use commercially reasonable efforts to make the Services available for a Committed Monthly Uptime Percentage of at least 99.90%, save that SAFEHERON shall have the sole and absolute discretion to revise such Committed Monthly Uptime Percentage. You shall be provided at least thirty (30) calendar days’ advance notice of such revision to the Committed Monthly Uptime Percentage. In the event of non-agreement, your sole and only recourse shall be to terminate your Account Subscription(s) in accordance with Clause 16.2.2.4 and cease all usage of the Account, Services, Software and/or Documentation. The Actual Monthly Uptime Percentage is calculated by expressing the Actual Monthly Total Minutes of Operation (defined below) as a percentage of the Committed Monthly Total Minutes of Operation.

$$Actual\ Monthly\ Uptime\ Percentage = \frac{Actual\ Monthly\ Total\ Minutes\ of\ Operation}{Committed\ Monthly\ Total\ Minutes\ of\ Operation}$$

Where:

7.1.1 “Actual Monthly Total Minutes of Operation” means the total number of minutes per calendar month during which the relevant Services are made available to you.

7.1.2 “Committed Monthly Total Minutes of Operation” means 1,440 minutes multiplied by the number of calendar days in the month of assessment (save that such number will be calculated on a pro-rated basis for partial billable months), less the minutes during which the Services are unavailable due to any of the following events:

7.1.2.1 planned service outage announced at least one (1) calendar day in advance (including for upgrading, maintenance, troubleshooting works and upgrading or recovery of blockchain nodes);

7.1.2.2 planned service outages initiated by SAFEHERON at your request or direction for maintenance, activation of configurations, backups or other purposes that require the service to be temporarily taken offline;

7.1.2.3 unscheduled maintenance provided that SAFEHERON has used reasonable endeavours to provide you with at least one (1) hour’s –notice in advance;

7.1.2.4 service disruptions due to any force majeure events, such as regional network failures, denial of service attacks, shutdown events triggered by third parties unauthorized by SAFEHERON, accidents, negligence, abnormal physical or electrical stress, abnormal environmental conditions, abuse or misuse of our Services, use of our Services other than in accordance with our Documentation or in violation of these Terms, any attack on SAFEHERON’s servers or networks or any other blockchain networks, any malfunctioning of your devices, equipment or other technology;

7.1.2.5 repair, maintenance or modification of the Software or App by persons other than SAFEHERON’s authorised third parties;

7.1.2.6 service disruptions attributable to, or in connection with use of your equipment, software or other technology or third party equipment, software or other technology (other than third party equipment within our sole and direct control), or from combining or merging our API with any hardware or software not supplied by us (unless identified by us in writing as compatible with our API), or from modifications in any version of our API not made or authorized by us in writing, or from your actions or inactions other than normal use of our API, Software or App; and/or

7.1.2.7 actions or inactions that constitute your breach of these Terms, or that result from a suspension or termination permitted under these Terms.

7.2 Subject to Clauses 7.3 and 7.4, in the event that the Actual Monthly Uptime Percentage does not meet the Committed Monthly Uptime Percentage, you may be entitled to receive Service Credits that may be offset against the quarterly fee payable in the next billing cycle in accordance with the tiers set out below:

Tier	Actual Monthly Uptime Percentage	Maximum amount of Service Credits
1	Greater than or equal to 99.00% but less than 99.90%	10% of the monthly payable Subscription Fees in the next billing cycle
2	Below 99.00%	20% of the monthly payable Subscription Fees in the next billing cycle

7.3 To apply to receive the Service Credits described above, you must:

7.3.1 notify SAFEHERON’s support team at [e-mail] within thirty (30) days of the end of the Quarter in which the incident affecting the Actual Monthly Uptime Percentage occurred; and

7.3.2 submit all information necessary for us to validate your claim, including but not limited to:

7.3.2.1 a detailed description of the event(s);

7.3.2.2 information regarding the time, date and duration of such event(s); and

7.3.2.3 the affected Account and your request logs that document the errors and corroborate your claimed outage (any confidential or sensitive information in these logs should be removed or replaced with asterisks).

7.4 The SAFEHERON team will assess your claim for the Service Credits within thirty (30) calendar days from receipt of such request from you or such longer time as may be necessary for SAFEHERON. If the Actual Monthly Uptime Percentage of such request is confirmed by us and is less than the Committed Monthly Uptime Percentage, we will issue such number of Service Credits as we may determine in our sole and absolute discretion to you within the next billing cycle following the month in which your claim is confirmed by us. Your failure to comply with these Terms (including Clause 7.3 above) will disqualify you from receiving a Service Credit.

8. Warranties

8.1 SAFEHERON’s Warranties:

8.1.1 SAFEHERON undertakes that the Services will be performed substantially in accordance with the Documentation and with reasonable care. This undertaking shall not apply to the extent of any non-conformance which is caused by use of the Services contrary to our instructions, or modification or alteration of the APIs or Software by any party other than SAFEHERON or our duly authorised contractors or agents. If the Services do not conform with the foregoing undertaking, we will, at our own expense, use commercially reasonable endeavours to correct any such non-conformance promptly, or provide you with an alternative means of accomplishing the desired performance. Such correction or substitution constitutes your sole and exclusive remedy for any breach of the undertaking set out in this Clause 8.1.1.

8.1.2 SAFEHERON represents and warrants that we, or our contractors and agents shall use commercially reasonable efforts to provide the Services without introducing errors.

8.1.3 Save as expressly set out in this Clause 8, SAFEHERON makes no other warranties in respect of the Services, Software and/or the Documentation.

8.2 SAFEHERON’s Warranty Disclaimer:

8.2.1 To the maximum extent permitted under applicable laws, and except as expressly provided in these Terms, SAFEHERON makes no warranties of any kind, express or implied, regarding the Services and the Software. We disclaim to the full extent permitted by law all warranties of merchantability, fitness for a particular purpose, and any warranties arising out of the course of dealing between the Parties.

8.2.2 You agree that the Services and the Software are provided on an “as is” and “as available” basis without warranty of any kind.

8.2.3 We make no warranties or representations regarding the use of the Software and the App with third party products or services, including, for the avoidance of doubt, Web3 applications.

8.2.4 We do not warrant that:

8.2.4.1 your use of the Services will be uninterrupted or error-free;

8.2.4.2 the Services, Documentation and/or the information obtained by you through the Services will meet your requirements; or

8.2.4.3 the Software or the Services will be free from Vulnerabilities or Viruses.

8.3 Your Warranties and Responsibilities:

8.3.1 You have the full and sufficient legal capacity and authority to enter into and be bound by these Terms and the person executing or otherwise accepting these Terms on your behalf has full legal capacity and authorization to do so.

8.3.2 (If you are a corporate entity,) you are duly organized, validly existing and in good standing under the laws of the jurisdiction in which you are organized.

8.3.3 No petition has been presented, no proceeding has been commenced, no order has been made, and no resolution has been passed for your bankruptcy (if you are an individual), or for the appointment of an, administrator, trustee or similar officer of it or of all or a substantial part of its business or assets (if you are an entity).

8.3.4 You and each of your Authorised Users are not included in any list of sanctions issued by European Union, any country in the European Union, the United Nations, United States of America, Singapore, the Financial Action Task Force, or any other country or international organization.

8.3.5 The digital asset wallet linked with the Account is owned, held and fully controlled by you and you hold and have full control of the private key and all other credentials in respect of the digital asset wallet.

8.3.6 If you are a corporate entity, you will ensure that your directors, employees, representatives, agents, affiliates and/or contractors (including for the avoidance of doubt, Authorised Users) do comply with these Terms.

8.3.7 All information provided by you to us in the course of onboarding you as our client and user of the Services is complete, true, and accurate in all material respects, including, where you are a corporate entity, no material information about the ownership and control over you and your operations has been excluded; and no other person or entity has an ownership interest in you except for those disclosed in connection with such onboarding.

8.3.8 You represent and warrant to SAFEHERON that activities that you carry out through your Account comply with all applicable laws and regulations, including but not limited to anti-bribery, anti-corruption, anti-fraud, anti-money laundering or anti-terrorism laws and regulations.

8.3.9 You further represent and warrant to SAFEHERON that we will be immediately notified of any Vulnerabilities found in our Services, Accounts, Apps or Software. You shall, and shall procure that your representatives, agents and subcontractors cooperate with SAFEHERON in good faith during SAFEHERON’s investigations of any illegal operations and any Vulnerabilities.

8.3.10 You shall maintain adequate security and control over any and all your private keys, your mnemonic phrases, registered email account(s), passwords, API keys, 2-factor authentication devices or backups, or any other codes that you use to access the Services. Any loss or compromise of the foregoing information and/or your personal information may result in unauthorized access to your Account by third parties and the loss or theft of digital assets from your digital wallet. You are responsible for keeping your registered email address(es) up to date in your Account profile in order to receive any notices or alerts that we may send to you. You are responsible for ensuring that that the generated mnemonic phrases are stored securely offline by each Authorised User who is permitted access and/or control over them.

8.3.11 You shall ensure that the destination blockchain address is accurate before effecting any transfers from your Account.

8.3.12 You shall only receive or transfer Supported Digital Assets to the Account. The Supported Digital Assets are listed and displayed in the App. You must not attempt to receive or transfer any digital assets unsupported by SAFEHERON through our Services.

8.3.13 You shall not receive or send any digital asset types which do not support SAFEHERON’s signature algorithm before receiving our written approval.

8.3.14 You shall ensure that upon the activation of a new Account and setting of permissions and privileges for each Authorised User, you shall conduct a sanity test by using the App to receive and send a Supported Digital Asset.

9. Intellectual Property Rights

9.1 Intellectual Property:

9.1.1 You acknowledge and agree that we and/or our licensors own all right, title, and interest in and to the Services, Software, Documentation, and all related technology and intellectual property rights. No other entity is entitled to grant or procure the grant of the limited licence set out in Clause 4.1. Except as expressly provided in Clause 4.1, you obtain no other rights under these Terms in respect of the Services and Documentation including any related intellectual property rights.

9.1.2 You agree not to, and shall procure that your Authorised Users, employees, directors, contractors or any other affiliate do not reverse engineer, decompile, disassemble, modify, update, create derivative works of, or otherwise tamper with Software or enable, assist or cause any third party to do so. You agree to and shall procure that your Authorised Users, employees, directors, contractors and any other affiliate keep the intellectual property in the Software confidential and not transfer, broadcast, publish, rent, license, lend, sell or otherwise distribute any Software or related licences in whole or in part.

9.1.3 For the avoidance of doubt, nothing in these Terms shall be interpreted to grant any implied licences under these Terms.

9.2 User Data:

9.2.1 You represent and warrant that you and your Authorised Users own all right, title and interest in your User Data and shall have sole responsibility for the legality, reliability, integrity, accuracy and quality of all such User Data. By using our Services, Software and/or Documentation, you grant us a worldwide, non-exclusive licence to use, process, display, copy and store your User Data (including, for the avoidance of doubt, your Key Shards) for the purposes of providing our Services, enabling your use of the Software and/or Documentation, enabling us to improve on our Services, Software and Documentation, and to collect and analyse anonymous information.

9.2.2 You may back up your User Data (including mnemonic phrases), transaction information and audit logs from your Account. Please refer to our Privacy Policy for further details on how we may collect, use and treat User Data and your personal data.

10. Privacy and Personal Data

10.1 Privacy Policy: You acknowledge that you have read, and agree to our Privacy Policy.

11. Risk Warning

PLEASE READ THIS SECTION CAREFULLY AS IT COVERS THE RISKS ASSOCIATED WITH THE USE OF OUR SERVICES AND SOFTWARE

1.1 Blockchain technology and other associated and related technologies are new. As with such developing technology, they come with various risks including those set out in this Clause 11. Prior to entering into these Terms with us, you acknowledge that you have been warned of the risks associated with the use of the Services, Software and/or Documentation and agree that subject always to Clause 14, SAFEHERON is not responsible, and assumes no liability for the following risks:

1.1.1 Price Fluctuation: There is a risk that you may suffer losses due to changes in macroeconomic policies, laws and regulations in any jurisdiction which result in changes in the value of the digital assets held by you.

1.1.2 Unconfirmed Digital Assets Transfer: There are risks that the blockchain network of the digital asset you wish to transfer may be suffering from any delays or malfunction which result in the failure to confirm any transfer of such digital assets.

1.1.3 Risk of Transfer to Wrong Blockchain Address: There is a risk of erroneously inputting the wrong destination blockchain address which result in the irreversible loss of digital assets.

1.1.4 Risk of Loss or Theft of Offline Mnemonic Phrase: There is a risk that the mnemonic phrase associated with the User Key Shard may be lost or stolen by nefarious hackers which may result in you losing access to the digital assets stored at such associated blockchain addresses.

1.1.5 Risk of Security Weaknesses in the Blockchain Network and Protocol: There is a risk that the software or infrastructure underlying the blockchain network, digital assets or protocol may unintentionally include weaknesses or bugs in the source code interfering with the use of or causing the loss of digital assets. As SAFEHERON cannot influence the overall security of any network or blockchain protocols which you interact with, we do not assume any responsibility for any risks associated with such blockchain networks and protocols, and cannot guarantee its function, security and availability.

1.1.6 Non-App Transfers: As transfers of digital assets can be made without the use of our Services through your original private key, if you do transfer digital assets from your digital wallet, such transfers will not be protected by our multi-party security processes and there is a higher risk that the digital assets being transferred may be stolen or transferred to the wrong wallet address.

1.1.7 Risk of Service Disruptions: There is a risk that disruptions to the use of the Services, may prevent you from, inter alia, successfully utilising or interacting with time restricted functions which Web3 protocols and decentralized finance applications may have. SAFEHERON does not assume any responsibility for any risks associated with disruptions to our Services and your sole and only recourse for such disruptions to Services are set out in Clause 7 above.

1.2 You also acknowledge that the use of digital assets and blockchain based solutions, networks and blockchain protocols may involve serious risks. Any reminders we give to you of the above risks shall not be taken as an admission or assumption of responsibility to issue further reminders of similar nature or of any other risks.

12. Third Party Providers

12.1 You acknowledge that the Services may enable or assist you to access the website content of, interact with the protocols, applications or platforms, and purchase or use services provided by third parties via third party websites, protocols or applications and that you do so solely at your own risk.

12.2 We make no representation, warranty or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or interaction with, any such third party website, protocol (including for the avoidance of doubt, decentralized finance and Web3.0 protocols), platform or application or any transactions completed, and any contract entered into by you, with any such third party.

12.3 Use of such third party services through the Services may be subject to additional terms and conditions imposed by such third party service provider(s), which terms SAFEHERON is not party to and has no control or influence over. We recommend that you read the terms and conditions and privacy policy of such third party service providers before using their services, purchase their products or interact with their protocols and platforms and comply with them. SAFEHERON does not endorse or approve any third party website, protocol, platform or application, nor the content of any of the third party website, platform or application made available via the Services.

13. Indemnification

13.1 You shall indemnify and hold harmless SAFEHERON, its affiliates, vendors and service providers, and each of its or their respective officers, directors, agents, employees, and representatives (collectively the “Indemnified Parties”), from and against any liabilities, damages, losses, costs and expenses, including but not limited to reasonable legal fees and costs and any fines, fees or penalties imposed by any regulatory authority, arising out of or incurred in connection with any third party claim, demand, action or proceeding (a “Claim”) arising out of or related to:

(a) your access or use of the Services and/or Documentation;

(b) your breach of these Terms;

(c) any material breach or inaccuracy of any of your representations, warranties or covenants in these Terms;

(d) your failure to provide true and accurate information in connection with the onboarding process or any failure to promptly update such information; or

(e) your violation of any applicable laws, or the rights of any third party,

except where such Claim arises from the gross negligence, fraud or willful misconduct of SAFEHERON and/or its affiliates, and provided always that you are given reasonable notice of such Claim. Any liabilities, damages, losses, costs and expenses, fines, fees or penalties shall be paid to the Indemnified Parties on demand.

14. Limitation of Liability

PLEASE READ THIS SECTION CAREFULLY AS IT COVERS THE LIMITATIONS OF OUR LIABILITY.

14.1 To the fullest extent permitted by applicable law and subject always to Clause 14.4:

14.1.1 in no event shall SAFEHERON, and/or any of its affiliates be liable for any indirect, special, incidental, consequential or exemplary damages of any kind (including, but not limited to, where related to loss of revenue, income or profits, loss of use or data, or damages for business interruption) arising out of or in any way related to the provision or use of the Services, or otherwise related to these Terms, regardless of the form of action, whether based in contract, tort (including, but not limited to, simple negligence, whether active, passive or imputed), or any other legal or equitable theory (even if SAFEHERON has been advised of the possibility of such damages and regardless of whether such damages were foreseeable); and

14.1.2 in no event will SAFEHERON’s liability and that of our affiliates, suppliers and contractors, in aggregate, arising from or relating to the Services and these Terms exceed the greater of: (a) the amount you paid for the Services during the twelve-month period immediately preceding the incident giving rise to that liability; and (b) five hundred United States dollars (US$500.00).

14.2 Without prejudice to the generality of Clause 14.1 above, you agree that:

14.2.1 we shall not bear any liability, whatsoever, for any damage, losses or interruptions caused by any Viruses, spyware, scareware, Trojan horses, worms or other malware that may affect your devices or other equipment, or any phishing, spoofing or other attack, unless such damage or interruption directly resulted from our gross negligence, fraud, or willful misconduct;

14.2.2 we shall not be liable for any loss that you may sustain due to compromise of login credentials, loss of mnemonic phrases, and/or failure to follow or act on any notices or alerts that we may send to you;

14.2.3 we shall not be liable for any losses or liabilities arising from the input of wrong destination or recipient blockchain addresses; and

14.2.4 we shall not be liable for any losses or liabilities arising from or relating to a breach of your own obligations set out in these Terms.

14.3 The limitations set forth in this Clause 14 will not limit or exclude liability for the gross negligence, fraud or intentional or wilful misconduct of SAFEHERON or its affiliates.

15. Confidentiality

15.1 As used in these Terms, “Confidential Information” means any information and data of any kind that a disclosing Party (“Discloser”) designates as being confidential or which, under the circumstances surrounding disclosure, ought to be treated as confidential whether disclosed before, on or after the date of the latest version of these Terms by the Discloser or any of its representatives, to the receiving Party (“Recipient”) or any of its representatives, and includes without limitation, technology, information and/or personal data provided by the Discloser, its related corporations, affiliates, representatives, employees, agents, representatives, independent contractors, advisors or consultants, whether disclosed or communicated verbally, in writing, or in any other tangible form, and whether relating to the Discloser’s business, operations, processes, plans, strategies, requirements, inventions, product or service information, pricing, know-how, design rights, trade secrets, software, systems, negotiations, discussions, and contracts with other companies, customers, the existence, nature, status and content of discussions or negotiations between the parties, including any termination of those discussions or negotiations, any copy, report, forecast, valuation, analysis, compilation, study, memorandum, note or other document or material prepared by or for the Recipient or any of its representatives that contains or reflects or is otherwise based upon (whether in whole or in part) any of the information described herein. including, without limitation information relating to the Discloser’s business operations or business relationships, financial information, transaction records, fee arrangements, transactions, accounts, personal data, pricing information, business plans, customer lists, data, records, reports, trade secrets, software, formulas, inventions, techniques, strategies and any data or information designated as confidential by the Discloser or which would be understood by a reasonable person as being of a confidential nature.

15.2 A Recipient will not disclose any Confidential Information to any third party without the prior written consent of the Discloser, except as provided to such third party’s officers, directors, agents, employees, consultants, contractors and professional advisors who need to know the Confidential Information for the purposes of performance of these Terms and who are informed of, and who agree to be or are otherwise bound by obligations of confidentiality no less restrictive than, the obligations set forth herein. The Recipient will protect such Confidential Information from any unauthorized access, use and disclosure and shall exercise in relation to such Confidential Information no lesser security and control measures and degree of care than those which the Recipient applies to its own Confidential Information. The Recipient shall not use the Discloser’s Confidential Information for any purpose other than to perform its obligations or exercise its rights under these Terms. The obligations herein shall not apply to:

15.2.1 any information that is or becomes generally publicly available through no fault of the Recipient;

15.2.2 any information that the Recipient obtains from a third party (other than in connection with these Terms) that, to the Recipient's best knowledge, is not bound by a confidentiality agreement prohibiting such disclosure; and

15.2.3 any information that is independently developed or acquired by the Recipient without the use of or reference to Confidential Information of Discloser.

15.3 Confidential Information includes all documents and other tangible objects containing or representing Confidential Information and all copies or extracts thereof or notes derived therefrom that are in the possession or control of the Recipient and all of the foregoing shall be and remain the property of the Discloser. At the Discloser’s request, the Recipient shall return or destroy all Confidential Information; provided, however, the Recipient may retain one copy of Confidential Information:

15.3.1 if required by applicable laws; or

15.3.2 pursuant to a bona fide and consistently applied document retention policy; provided, further, that in either case, any Confidential Information so retained by the Recipient shall remain subject to the confidentiality obligations of these Terms.

15.4 If the Confidential Information disclosed under these Terms or any other agreement that we may enter into with you includes the personal data of the Discloser and/or personal data of any individual:

15.4.1 the Discloser hereby consents to the collection, processing, use and disclosure of its personal data by the Recipient in accordance with these Terms and our Privacy Policy; and

15.4.2 the Discloser hereby undertakes, represents and warrants to the Recipient that the Discloser has notified such individual of the purposes for which the Recipient may use his/her personal data and has obtained such individual’s consent for the collection, processing, use and disclosure of his/her personal data by the Recipient in accordance with these Terms and our Privacy Policy.

15.5 The Discloser acknowledges and agrees that any consent given pursuant to these Terms in relation to personal data shall survive death, incapacity, bankruptcy or insolvency of any such individual and the termination or expiration of these Terms.

16. Term and Termination

16.1 Validity: These Terms shall apply on the date that you subscribe for and/or use our Services and will continue for such period notified to you in the quotation containing the Subscription Fee, unless earlier terminated in accordance with these Terms (the “Initial Duration”). After the Initial Duration, the Terms will automatically renew for successive one-year periods (each a “Renewal Duration”), unless either Party notifies the other of its intention not to renew at least 30 days prior to the expiration of the then-current Duration. “Duration” means the Initial Duration and any Renewal Duration.

16.2 Termination:

16.2.1 SAFEHERON may terminate this agreement and your Account Subscription(s) with immediate effect by notice in writing if:

16.2.1.1 you have breached any of any of your undertakings or obligations in these Terms, including for the avoidance of doubt, Clauses 3.3, 4.2 and 8.3;

16.2.1.2 any of your representations or warranties in these Terms turn out to be false, misleading, inaccurate or incomplete, including for the avoidance of doubt, Clauses 8.3 and 9.2.1;

16.2.1.3 you have failed to pay any amount due under these Terms on the due date for payment and remains in default not less than thirty (30) days after being notified in writing to make such payment;

16.2.1.4 you have breached Clause 6.3.1;

16.2.1.5 you have committed a material breach of any of these Terms and (if such breach is remediable) fail to remedy that breach within a period of seven (7) calendar days after being notified in writing to do so; or

16.2.1.6 we are required to do so under any applicable law(s) or pursuant to any request by any governmental or regulatory body.

16.2.2 You may terminate this agreement and your Account Subscription(s) with immediate effect by notice in writing if:

16.2.2.1 SAFEHERON discontinues support for any of the digital assets which you hold in the digital wallet linked to your Account;

16.2.2.2 SAFEHERON discontinues support for the signature algorithm you intend to rely on for any Supported Digital Assets;

16.2.2.3 SAFEHERON revises the Subscription Fee and/or billing cycle and you indicate that you do not wish to continue such Account Subscription(s) within fourteen (14) calendar days of such notice; or

16.2.2.4 SAFEHERON revises the Committed Monthly Percentage.

16.2.3 In the event of termination pursuant to any of the events listed in Clause 16.2.2, we may, in our absolute discretion, refund you the pro-rated amount of the Subscription Fee paid for the relevant calendar month.

16.2.4 On termination of these Terms for any reason:

16.2.4.1 all licences granted under this agreement shall immediately terminate and you shall immediately cease all use of the Services, Software and/or the Documentation;

16.2.4.2 each Party shall return and make no further use of any Confidential Information, Documentation and other items (and all copies of them) belonging to the other Party;

16.2.4.3 we may destroy or otherwise dispose of any of the User Data in our possession unless we receive, no later than ten days after the effective date of the termination of these Terms, a written request for the delivery to you of the then most recent back-up of your User Data. We shall use commercially reasonable endeavours to deliver the electronic back-up to you within 30 days of our receipt of such a written request, provided that you have, at that time, paid all fees and charges outstanding at and resulting from termination (whether or not due at the date of termination). You shall pay all reasonable expenses incurred by us in returning or disposing of your User Data; and

16.2.4.4 any rights, remedies, obligations or liabilities of the Parties that have accrued up to the date of termination, including the right to claim damages in respect of any breach of these Terms which existed at or before the date of termination shall not be affected or prejudiced.

16.2.5 Clauses 10, 11, 12, 13, 14, 15, 16.2.3, 16.2.4, 16.2.5 and 18 shall survive any termination or expiry of these Terms.

17. Force Majeure

17.1 We shall not be liable for any delays, failure in performance or interruption of the Services which result directly or indirectly from any Force Majeure Event.

17.2 The Party not affected by the Force Majeure Event may terminate these Terms with immediate effect by providing written notice to the other Party if the other Party remains unable to perform due to the Force Majeure Event for a period of more than fifteen (15) days following the date of the Force Majeure Event.

17.3 For the avoidance of doubt, neither occurrence of a Force Majeure Event or the termination of these Terms in connection therewith shall relieve either Party from any accrued obligations then subsisting prior to the occurrence of the Force Majeure Event or termination of these Terms in connection therewith (including any payment obligations for outstanding sums).

18. Miscellaneous

18.1 Notices:

1.1.1 Any notices, demands or other communications hereunder shall be in writing and may be served, in the case of SAFEHERON only, by way of publication on our website accessible at www.safeheron.com, in-application notification, text messages, instant messaging and/or other electronic means or sent or distributed via email:

If to SAFEHERON, to:

Name: SAFEHERON Pte. Ltd.

Email: [e-mail]

If to you, to:

Name: Name of person subscribing for the Account Subscription

Email: Your email address as notified to SAFEHERON during the account opening and onboarding process and updated from time to time

Mobile: Your mobile phone number as notified to SAFEHERON during the account opening and onboarding process and updated from time to time

18.1.2 Any such communication shall be deemed duly given:

18.1.2.1 in the case of publication on our website (applicable only to SAFEHERON), to you by close of business on the date of publication of such notice, demand or communication on our website, provided that if such day is not a Business Day or such time not a normal business hour then delivery shall be deemed to have occurred on the following Business Day;

18.1.2.2 in the case of communication via in-application notification, text messaging, instant messaging and/or other electronic means, on the day such notification, text message, instant message and/or other electronic medium was sent;

18.1.2.3 in the case of communication via email, when sent to SAFEHERON’s or your email address, by close of business of the date of transmission by the email server used by us or you and/or our or your service provider subject to confirmation of successful transmission, provided that if such day is not a Business Day or such time not a normal business hour then delivery shall be deemed to have occurred on the following Business Day.

18.1.3 SAFEHERON shall not be liable for any failures or delays in the delivery of such notice to you due to reasons not attributable to SAFEHERON (including but not limited to the provision of inaccurate or invalid contact details, and network failures by third party service providers).

18.2 Entire Agreement: These Terms constitutes the entire agreement between the Parties with respect to the subject matter hereof and supersedes all prior oral and written discussions, memoranda, understandings and undertakings between them.

18.3 Remedies: No remedy conferred by any of the provisions of these Terms is intended to be exclusive of any other remedy which is otherwise available at law, in equity, by statute or otherwise, and each and every other remedy shall be cumulative and shall be in addition to every other remedy given hereunder or now or hereafter existing at law, in equity, by statute or otherwise, provided always that the Parties shall not be entitled to rescind these Terms on grounds of misrepresentation. The election of any one or more of such remedies by any of the Parties shall not constitute a waiver by such Party of the right to pursue any other available remedies.

18.4 Waiver: The rights and remedies of each Party shall not be affected by any failure to exercise or delay in exercising any right or remedy or by the giving of any indulgence or by anything whatsoever except a specific waiver or release in writing and any such waiver or release shall not prejudice or affect any other rights or remedies of such Party. No single or partial exercise of any right or remedy shall prevent any further or other exercise thereof or the exercise of any other right or remedy.

18.5 Time of Essence: Any time or period mentioned in any provision of these Terms may be extended by mutual agreement between the Parties but as regards any time, date or period originally fixed or any time, date or period so extended as aforesaid time shall be of the essence.

18.6 Successors and Assigns: No Party shall have the right to assign all or any part of its interest in these Terms without the prior written consent of the other Party. These Terms shall be binding upon and shall inure to the benefit of the Parties and their successors and permitted assigns.

18.7 Severability: If any provision or any portion of any provision of these Terms or the application of any such provision or any portion thereof to any person or circumstance, shall be held invalid or unenforceable, the remaining portion of such provision and the remaining provisions of these Terms, and the application of such provision of portion of such provision as is held invalid or unenforceable to persons or circumstances other than those as to which it is held invalid or unenforceable, shall not be affected thereby.

18.8 Third Party Rights: A person who is not a party to these Terms has no right under the Contracts (Rights of Third Parties) Act 2001, to enforce any Terms, but our assignees, affiliates, third party vendors and contract service providers shall be deemed beneficiaries of these Terms as if they are parties thereto and shall have the rights to enforce the provisions of these Terms.

18.9 Governing Law: These Terms shall be governed by and construed in accordance with the laws of Singapore.

18.10 Dispute Resolution:

18.10.1 Parties shall first attempt to resolve any dispute, controversy or claim arising under, out of, in connection with or in relation to these Terms, including any dispute as to its existence, validity, interpretation, performance, breach or termination and any dispute relating to any non-contractual obligations arising out of or in connection with it (“Dispute”) shall, so far as possible, amicably by mutual consultation between Parties. The amicable resolution should be commenced as soon as possible after a disputing Party delivers a notice of dispute to another disputing Party (“Dispute Notice”).

18.10.2 Failing an amicable settlement within 30 calendar days from the date of the Dispute Notice, the disputing Parties agree that the Dispute shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force, which rules are deemed to be incorporated by reference in this Clause 18.10. The seat of the arbitration shall be Singapore. The arbitration tribunal shall consist of one (1) arbitrator appointed by the President of the Court of Arbitration for the time being of the Singapore International Arbitration Centre. The language of the arbitration shall be English.

Safeheron PTE. LTD.

© 2022 Safeheron PTE. LTD. All rights reserved.

Safeheron 隐私政策

更新于：2022 年 11 月 16 日

更新日志

版本号	更新内容	更新时间	生效时间
V1.0.0	创建文档	2022.05.16	2022.05.16
V1.0.1	更新如下条款： 二、使用收集的个人信息 1）新增采集数据保留期限 2）新增采集数据明细 七、我们如何使用 Cookie 1）新增Cookie类别以及保留期限 新增如下条款： 九、数据跨境传输	2022.11.16	2022.11.16

介绍

我们很高兴你选择使用我们的应用程序或访问我们的网站。我们非常认真地承担我们的数据保护责任，我们设计了我们的网站，以便你可以浏览和使用我们的网站，而无需提供个人数据。

本隐私政策（本“隐私政策”）描述了SAFEHERONPTE.LTD.和我们的关联公司（以下简称“Safeheron”或“我们”）将如何收集、使用、共享、维护和存储我们收集的你的与你使用我们的网站https://www.safeheron.com/ 及其任何相关域名或子域（“网站”）、与你使用我们的平台的钱包移动应用程序和我们许可的任何其他软件应用程序（“平台”)、我们作为你的个人信息的控制者（该术语用于适用的数据保护法中）以及与我们收集和处理你的个人信息的其他场合有关的个人信息，在本隐私政策中进一步详述。

就本隐私政策而言，“个人信息”指与已识别或可识别个人的相关信息。就本隐私政策而言，个人信息不包括去识别化或汇总信息，并在法律允许的范围内，不包括合法向公众提供的公开信息或政府记录合法提供的信息。

服务不适用于中国大陆用户。

一、收集您的个人信息

在你使用 Safeheron 服务的过程中，我们会按照如下方式收集你在使用服务时主动提供或因为使用服务而产生的信息。

1.1. 机构数据：雇主识别号码（或政府颁发的其他类似号码）和/或所有重要受益所有人的个人识别信息和/或机构现任董事名单、机构人员规模、从事业务类型。

1.2. 联系数据：电话号码和/或电子邮件。

1.3. 地理位置数据： IP 地址、国家代码、邮政编码、机构客户的工作地址。

1.4. 帐户数据：帐户名称、客户 ID、密码和/或用户名。

1.5. 交易数据：有关您在我们的服务上进行的交易的信息，例如交易订单的详细信息、您在账户中持有的虚拟资产的金额和/或时间戳。

1.6. 使用数据：身份验证数据、点击流数据、Cookies、像素标签和其他类似技术，用于唯一标识您的浏览器，您同意此类技术需要您的同意。

1.7. 技术数据：设备类型、分类和型号、唯一设备标识号（如 OAID、AndroidID、IDFV、IDFA、GAID、IMEI）、提交来源（Web 或 App）、电信运营商信息、浏览器类型和版本、浏览器插件类型和版本, 应用程序版本和 SDK 版本, 操作系统和平台, 语言设置, 隐私偏好, 时区设置, 诊断数据, 例如崩溃日志和我们收集的任何其他数据, 以在需要时征得您的同意和存储或可用的其他信息来衡量技术诊断在您访问网站或使用服务或应用程序时允许我们访问的设备上，到、通过和来自服务的完整 URL 点击流、cookie 标识符和您在我们服务上的活动。

1.8. 营销和传播数据：营销传播偏好、调查回复、提供给我们的支持团队、交易团队、销售团队和/或用户研究团队的信息。

1.9. 风险管理数据：个人信用信息，包括还款历史、信用信息和债务信息等。司法数据、诉讼相关、涉案信息、合规评估、风险评估、风险等级、KYC 认证结果和失败原因。

1.10 财务数据：银行账户信息（如账号、分类代码）、汇款账户、银行账户类型（SWIFT/ABA）、SWIFT代码、ABA编号、法定货币存款证明信息、币种、充值金额、取款金额、支付卡主账号（PAN）、加密货币存款地址。

二、使用收集的个人信息

我们出于如下目的，使用你提交以及我们收集的用户信息：

处理目的	个人资料类别	数据保留
将您注册为新客户	账户资料 联系方式 财务数据	关系持续时间 + 取消后 5 年
执行和遵守反洗钱要求	账户资料 联系方式 财务数据 机构数据	关系持续时间 + 取消后 5 年
处理并向您提供我们的服务和任何应用程序功能，包括执行、管理和处理您发出的任何指令或订单	联系方式 财务数据 交易数据 技术资料 营销和传播数据	关系持续时间 + 取消后 6 年
管理、处理、收取和转移付款、费用和收费，以及收取和收回欠我们的款项	账户资料 联系方式 技术资料 交易数据 营销和传播数据	10 年
确保妥善管理我们的付款、费用和收费，以及收回和收回归我们所有的款项	账户资料 联系方式 财务数据	10 年
管理风险和预防犯罪，包括进行反洗钱、反恐、制裁筛查、欺诈和其他背景调查，发现、调查、报告和预防广义上的金融犯罪，遵守适用于我们的法律法规并回应投诉并解决	联系方式 账户资料 财务数据 技术资料 交易数据 可能通过 KYC 或其他背景调查披露的数据（例如，因为它已在媒体上报道或在公共登记册中可用）	关系持续时间 + 取消后 6 年
为使您能够正常参与和使用我们的服务，并且在出现异常使用场景时，我们将使用这些数据来定位和解决问题。同时，我们也会根据您的业务数据为您推荐更合适的产品和服务	联系方式 账户资料 技术资料 使用数据 营销和传播数据	关系持续时间 + 取消后 6 年
收集市场数据以研究客户的行为，包括他们的偏好、兴趣以及他们如何使用我们的产品/服务，确定我们的营销活动和发展我们的业务	账户资料 联系方式 技术资料 使用数据 营销和传播数据	关系持续时间 + 取消后 5 年
管理和保护我们的服务和社交媒体渠道，包括禁令、故障排除、数据分析、测试、系统维护、支持、报告、数据托管 我们处理您的个人信息是为了提高安全性、监控和验证身份或服务访问、打击垃圾邮件或其他恶意软件或安全风险，并遵守适用的安全法律和法规。互联网上的威胁形势在不断发展，这使得我们拥有有关您使用我们服务的准确和最新信息比以往任何时候都更加重要。如果不处理您的个人信息，我们可能无法确保我们服务的安全性	账户资料 联系方式 财务数据 技术资料 使用数据 交易数据	关系持续时间 + 取消后 5 年
向您提供相关服务和广告，并衡量或了解我们为您提供的广告的有效性	账户资料 联系方式 技术资料 营销和传播数据	关系持续时间 + 取消后 5 年
使用数据分析来改善我们的服务、营销、客户关系和体验	技术资料 使用数据	关系持续时间 + 取消后 5 年
使用社交媒体平台或广告平台的服务，其中一些将使用他们收到的个人数据用于自己的目的，包括营销目的	技术资料 使用数据	关系持续时间 + 取消后 5 年
使用金融机构、犯罪和欺诈预防公司、风险测量公司的服务来主动预防犯罪和欺诈	账户资料 联系方式 风险管理数据 财务数据 交易数据 技术资料 使用数据	关系持续时间 + 取消后 5 年
为合规、维护客户关系、质量保证和培训目的记录语音通话和通信	账户资料 联系方式 财务数据 交易数据	关系持续时间 + 取消后 5 年
在出现任何影响您使用服务的故障（如程序崩溃、功能异常、显示异常）时，尽快诊断和解决故障，以提升您的用户体验	技术数据（包括诊断数据）	关系持续时间 + 取消后 5 年以上

三、我们如何共享、转让你的用户信息

3.1. 共享

我们不会与其他组织和个人共享你的用户信息，但以下情况除外：

3.1.1. 在获取明确同意的情况下共享：获得你的明确同意后，我们会与其他方共享你的用户信息；

3.1.2. 在法定情形下的共享：我们可能会根据法律法规规定、诉讼、仲裁解决需要，或按行政、司法机关依法提出的要求，对外共享你的用户信息。

3.2. 转让

我们不会将你的用户信息转让给任何公司、组织和个人，但以下情况除外：

3.2.1. 在获取明确同意的情况下转让：获得你的明确同意后，我们会向其他方转让你的用户信息；

3.2.2. 在Safeheron与其他法律主体者发生合并、收购或破产清算情形，或其他涉及合并、收购或破产清算情形时，如涉及到用户信息转让，我们会要求新的持有你用户信息的公司、组织继续受本政策的约束，否则我们将要求该公司、组织和个人重新向你征求授权同意。

3.3. 共享、转让用户信息时事先征得授权同意的例外

以下情形中，共享、转让你的用户信息无需事先征得你的授权同意：

3.3.1. 与国家安全、国防安全有关的；

3.3.2. 与公共安全、公共卫生、重大公共利益有关的；

3.4.3. 与犯罪侦查、起诉、审判和判决执行等有关的；

3.4.4. 出于维护你或其他个人的生命、财产等重大合法权益但又很难得到本人同意的；

3.4.5. 你自行向社会公众公开的个人信息。

四、我们如何保护你的个人信息

我们努力为用户的信息安全提供保障，以防止信息的丢失、不当使用、篡改、未经授权访问或披露。

4.1. 我们将在合理的安全水平内使用各种安全保护措施以保障信息的安全。例如，我们会使用加密技术（例如，SSL）、MPC、去标识化、匿名化处理等手段来保护你的个人信息。

4.2. 我们建立专门的管理制度、操作规程和组织以保障信息的安全。例如，我们严格限制访问信息的人员范围，要求他们遵守保密义务，并进行审计。

4.3. 当不幸发生个人信息安全事件时，我们将及时以邮件、推送等形式及时通知到你，并将承担相应的法律责任。同时，我们还将按照监管部门要求，主动上报个人信息安全事件的处置情况。

4.4. 在信息安全方面已达到ISO27001认证标准的要求，并已获得了相应的认证。

4.5. 我们会采取一切合理可行的措施，确保未收集无关的个人信息。我们只会在达成本政策所述目的所需的期限内保留您的个人信息，除非需要延长保留期或受到法律的允许。

五、你的权利

你有权享有与你的个人信息相关的某些权利。

5.1. 每公历年要求两次，了解a）我们收集的关于你的具体个人信息；b）我们收集的关于你的个人信息类别；c）我们收集你个人信息的来源类别；d）我们收集你的个人信息的商业目的；

5.2. 如果你认为我们收集的有关你的个人信息不准确，要求更正我们收集的你的个人信息。

5.3. 以结构化、通用和机器可读的格式接收你提供给我们的个人信息，并将其传输给其他数据控制器（数据迁移）。

5.4. 出于与你的特定情况相关的有说服力的合法原因，限制或反对处理你的个人信息，除非法律明确规定该处理。

5.5. 向你居住地或投诉所涉问题发生地的监管机构提出投诉。我们不会因你行使任何这些权利而歧视你。如果你想提出请求或了解更多信息，请使用下方“联系我们”部分提供的信息与我们联系。

5.6. 在以下情形中，你可以向我们提出删除个人信息的请求：

1）如果我们处理个人信息的行为违反法律法规；

2）如果我们收集、使用你的个人信息，却未征得你的同意；

3）如果我们处理个人信息的行为违反了与你的约定；

4）如果你不再使用我们的产品或服务，或你注销了账号；

5）如果我们不再为你提供产品或服务。

5.7. 为保障安全，你可能需要提供书面请求，或以其他方式证明你的身份。我们可能会先要求你验证自己的身份，然后再处理你的请求。我们将在三十天内作出答复，如你不满意，还可以通过 [e-mail] 进行投诉。对于你合理的请求，我们原则上不收取费用，但对多次重复、超出合理限度的请求，我们将视情收取一定成本费用。对于那些无端重复、需要过多技术手段（例如，需要开发新系统或从根本上改变现行惯例）、给他人合法权益带来风险或者非常不切实际（例如，涉及备份磁带上存放的信息）的请求，我们可能会予以拒绝。

5.8. 在以下情形中，我们将无法响应你的请求：

1）与个人信息控制者履行法律法规规定的义务相关的；

2）与国家安全、国防安全直接相关的；

3）与公共安全、公共卫生、重大公共利益直接相关的；

4）与刑事侦查、起诉、审判和执行判决等直接相关的；

5）个人信息控制者有充分证据表明个人信息主体存在主观恶意或滥用权利的；

6）出于维护个人信息主体或其他个人的生命、财产等重大合法权益但又很难得到本人同意的；

7）响应个人信息主体的请求将导致个人信息主体或其他个人、组织的合法权益受到严重损害的；涉及商业秘密的。

六、儿童信息的收集

6.1. 我们的产品、网站和服务主要面向成人。如果没有父母或监护人的同意，儿童不应创建自己的个人信息主体账户。

6.2. 对于经父母同意而收集儿童个人信息的情况，我们只会在受到法律允许、父母或监护人明确同意或者保护儿童所必要的情况下使用或公开披露此信息。

6.3. 尽管当地法律和习俗对儿童的定义不同，但我们将不满 14 周岁的任何人均视为儿童。

6.4. 如果我们发现自己在未事先获得可证实的父母同意的情况下收集了儿童的个人信息，则会设法尽快删除相关数据。

七、我们如何使用 Cookie

我们通过网站上使用的跟踪技术收集某些信息，例如 cookie（用于访问网站时放置在设备上的数据文件）、移动分析软件和像素标签（透明图形图像，有时称为网络信标或跟踪信标，放置在网页或电子邮件中，表示已查看页面或电子邮件，并且可能会告诉您的浏览器从另一台服务器获取内容）。我们这样做是为了分析趋势、跟踪用户在网站上的移动、收集人口统计信息，并通常收集我们认为有见地或有用的信息。为了安全起见，我们或我们的第三方服务提供商可能会在您的设备上放置 cookie 或类似文件，并方便网站导航。我们可能会使用社交媒体平台 cookie 来改善我们的用户体验。

大多数浏览器允许您控制 cookie，包括是否接受它们以及如何删除它们。您可以将大多数浏览器设置为在收到 cookie 时通知您，或者您可以选择使用浏览器阻止 cookie。但是，请注意，如果您拒绝 cookie，本网站的某些功能可能无法正常运行或速度可能会变慢。如果您阻止或删除 cookie，并非我们在本隐私政策中描述的所有跟踪都会停止。

我们使用 Google Analytics 提供的 cookie来收集有关网站使用情况的统计信息。我们使用谷歌分析来了解更多关于访问网站的用户类型、他们在网站上的活动，并帮助改进网站。为提供此服务，Google Analytics 可能会从您的计算机收集有关您的某些信息，包括但不限于：有关您访问的信息（例如您访问的页面和访问时长）、有关您设备的信息（例如您的IP 地址）、您如何访问该网站以及有关您的其他信息。您可以访问： www.google.com/policies/privacy/partners/，了解有关 Google Analytics 及其如何收集和处理数据（包括如何控制发送给 Google 的信息）的更多信息. 您可以在此处选择退出 Google 分析：tools.google.com/dlpage/gaoptout（这需要您安装浏览器插件）。

某些网络浏览器可能会提供一个选项，您可以通过该选项请求您的浏览器通知您访问的网站，您不希望您的活动被 cookie 或其他持久标识符（通常称为“不跟踪信号”）跟踪。本网站目前不对“请勿追踪”信号做出回应。

不同类型的 cookie 可用于特定目的，例如：

Cookie 类别	期限
绝对必要的 Cookie 这些 cookie 是服务运行所必需的，无法在我们的系统中关闭。它们通常仅针对您做出的相当于服务请求的操作而设置，例如设置您的隐私偏好、登录或填写表格。您可以将浏览器设置为阻止或提醒您这些 cookie，但网站的某些部分将无法正常工作。这些 cookie 不存储任何个人身份信息。	长达 365 天
性能 Cookie 这些 cookie 允许我们计算访问量和流量来源，以便我们可以衡量和改进我们网站的性能。它们帮助我们了解哪些页面最受欢迎和最不受欢迎，并了解访问者如何在网站上移动。这些 cookie 收集的所有信息都是汇总的，因此是匿名的。如果您不允许这些 cookie，我们将无法知道您何时访问了我们的网站，也无法监控其性能。	长达 2 年
功能性 Cookie 这些 cookie 使我们的服务能够提供增强的功能和个性化。它们可能由我们或我们已将其服务添加到我们页面的第三方提供商设置。如果您不允许这些 cookie，则部分或全部这些服务可能无法正常运行。	长达 365 天
定位 Cookie 这些 cookie 可能由我们的广告合作伙伴通过我们的网站设置。这些公司可能会使用它们来建立您的兴趣档案并在其他网站上向您展示相关广告。它们不直接存储个人信息，而是基于唯一标识您的浏览器和互联网设备。如果您不允许这些 cookie，您将体验到较少针对性的广告	长达 365 天
社交媒体 Cookie 这些 cookie 由我们添加到网站的一系列社交媒体服务设置，使您能够与您的朋友和网络分享我们的内容。他们能够在其他网站上跟踪您的浏览器并建立您的兴趣档案。这可能会影响您在访问的其他网站上看到的内容和消息。如果您不允许这些 cookie，您可能无法使用或查看这些共享工具。	长达 365 天

八、我们保留您的个人数据的时间

我们将在法律要求或允许的期限内或根据我们不时制定的保留政策保留您的个人信息。我们在确定此类保留期限时考虑以下因素：保留个人信息以实现业务目的所需的时间；维护相应的业务记录；提高网站和平台的性能和质量；处理您的查询；我们是否有理由相信处理任何诉讼需要这些数据；以及法律和合同义务是否对数据保留提出任何要求。

请参阅上面的“使用收集的个人信息”部分，了解每种处理目的的相关保留期限。

九、数据跨境传输

鉴于我们是一家国际企业，我们对您个人信息的使用必然涉及跨境数据传输。Safeheron在香港的服务器上处理和存储数据。当我们跨境传输数据时，我们会根据适用的数据保护法进行。例如，当我们将数据从欧洲经济区传输到被认为没有足够数据保护水平的司法管辖区时，我们可能会使用标准合同条款。如果没有充分的决定或标准合同条款或任何其他传输您的数据的权利，我们可能会依赖您的同意作为此类传输的基础。

十、取消邮件通信

你可以随时取消接收我们的营销和推广信息，方法是：

10.1. 在我们发送给你的信息中选择取消订阅链接，或

10.2. 使用下方“联系我们”部分中提供的信息与我们联系。请注意，即使你选择不接收上述电子邮件，当你出于与你使用本网站或平台相关的其他原因联系我们时，我们仍会向你发送回复通信。

十一、隐私政策的更新

未经你明确同意，我们不会削减你按照本个人信息保护政策所应享有的权利。我们会在官网或APP发布对本政策所做的任何变更。当隐私政策发生变更时，我们将以邮件和推送的形式及时通知你隐私政策所做的更改，并更改上面的“更新”日期。如果你不同意修改后的政策，你应该停止使用我们的平台和服务。我们还会将本政策的旧版本存档，供你查阅。

十二、联系我们

如果你对本隐私政策或我们的隐私惯例有任何疑问，请通过以下方式联系我们：[e-mail]。一般情况下，我们将在三十天内回复。如果你对我们的回复不满意，特别是我们的个人信息处理行为损害了你的合法权益，你还可以通过政府、法院或其他相关机构寻求解决方案。