Appreciator Innovation Company Limited (“Appreciator.io,” “we” or “us”) is committed to protecting your privacy. We ensure that our policies and practices in relation to the collection, use, retention, disclosure, transfer, security and access of your Personal Data (discussed in section 1 below) comply with the requirements under the Personal Data (Privacy) Ordinance (Chapter 486) under the laws of the Special Administrative Region of Hong Kong (“Hong Kong”), as well as the relevant code of practice and guidance issued by the Office of the Privacy Commissioner for Personal Data of Hong Kong.
Personal Data We Collect
As used herein, “Personal Data” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is capable of being associated with an identified or reasonably identifiable individual.
a. Personal Data we collect from you
We may collect the following categories of Personal Data directly from you:
i. Identification Information: such as name, email, phone number, postal address;
ii. Commercial Activity: such as trading activity, order activity, deposits, withdrawals, account balances;
iii. Correspondence: such as information you provide to us in correspondence, including account opening and customer support; and
iv. Sensory Information: such as images that you upload to your User Profile;
b. Personal Data we collect automatically
We may collect the following categories of Personal Data automatically through your use of our services:
i. Online Identifiers: such as IP address, domain name;
ii. Device Information: such as hardware, operating system, browser;
iii. Usage Data: such as system activity, internal and external information related to Appreciator.io pages that you visit, clickstream information; and
iv. Geolocation Data.
c. Personal Data we collect from third parties
We may collect and/or verify the following categories of Personal Data about you from third parties, including service providers and our affiliates:
i. Identification Information: such as name, email, phone number, postal address
ii. Transaction Information: such as public blockchain data (bitcoin, ether, and other digital assets are not truly anonymous. We, and any others who can match your public digital asset address to other Personal Data about you, may be able to identify you from a blockchain transaction because, in some circumstances, Personal Data published on a blockchain (such as your digital asset address and IP address) can be correlated with Personal Data that we and others may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Data about you);
iii. Financial Information: such as bank account information, routing number, credit card number, debit card number; and
iv. Additional Information: at our discretion to comply with legal obligations.
d. Accuracy and retention of Personal Data
We take reasonable and practicable steps to ensure that your Personal Data held by us is
i. accurate with regard to the purposes for which it is to be used, and
ii. not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.
How We Use Your Personal Data
We collect Personal Data about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Data to:
b. Comply with legal and regulatory requirements: we process your Personal Data as required by applicable laws and regulations.
c. Detect and prevent fraud: we process your Personal Data to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
d. Protect the security and integrity of our Services: we use your Personal Data, including information about your device and your activity on Appreciator.io to maintain the security of your account and the Appreciator.io platform.
e. Provide you with customer support: we process your Personal Data when you contact our support team with questions about or issues with your account.
f. Market our products: we may contact you with information about our Services. We will only do so with your permission, which can be revoked at any time.
g. Other business purposes: we may use your Personal Data for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.
How We Share Your Personal Data
We will not share your Personal Data with third parties, except as described below:
a. Service Providers: we may share your Personal Data with third-party service providers for business or commercial purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, information technology, advertising and marketing, network infrastructure, storage, transaction monitoring. We share your Personal Data with these service providers only so that they can provide us with the services, and we prohibit our service providers from using or disclosing your Personal Data for any other purpose. You authorize us to collect and share with our payments provider your Personal Data including full name, email address and financial information, and you are responsible for the accuracy and completeness of that data.
c. Affiliates: we may share Personal Data about you with our affiliates in the ordinary course of business and offering our Services to you.
d. Law Enforcement: we may be compelled to share your Personal Data with law enforcement, government officials, and regulators.
e. Corporate Transactions: we may disclose Personal Data in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
f. Professional Advisors: we may share your Personal Data with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
g. Consent: we may share your Personal Data with your consent.
a. ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities;
b. assess and improve our services and advertising campaigns.
You also can learn more about cookies by visiting http://www.allaboutcookies.org , which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note that if you reject cookies, you will not be able to use some or all of Appreciator.io. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use Appreciator.io.
Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or about you. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide your Personal Data for those third parties’ direct marketing purposes without your consent.
No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect Appreciator.io and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Data we collect and store. Measures we take include encryption of the Appreciator.io website communications with SSL; periodic review of our Personal Data collection, storage, and processing practices; and restricted access to your Personal Data on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.