imToken Privacy Policy
Last Updated: January 23, 2025
imToken PTE. LTD. ("imToken", "we", "our company" or "our") respects and protects the privacy of users ("you", "your" or "users") and users' control over their data. Due to the decentralized nature, imToken minimizes the collection of personal information and will never collect your private keys under any circumstances. When we deem it necessary to provide a better user experience, imToken may collect, use, disclose and process your personal information in accordance with this Privacy Policy ("this Policy"), including but not limited to when you:
- access or use our official websites, applications and support services; and/or
- provide us with your personal information, regardless of the medium through which such information is provided.
Where there is any inconsistency between the definition of any term in this Policy and the definition of the term in the imToken Terms of Use, the definition of the term in this Policy shall prevail.
By providing us with your personal information, you consent to our collection, use, disclosure (including transfer) and processing of your personal information in accordance with this Policy. If you do not agree with this Policy, please do not provide us with any personal information.
Our applications may link to third-party websites, applications or smart contracts, which are not managed by us. Such links are provided for your convenience only. When using third-party services, imToken's Terms of Use and this Policy will no longer apply.
We reserve the right to update this Policy online at any time without notice to you. Once the revised policy is published on our official website or application, the new policy will take effect and replace the old version. You can determine whether revisions have been made by checking the date this notice was last updated. The revised policy will apply to personal information you have previously provided. In particular, if you do not agree with the revised policy, please immediately stop using our official website and applications. Continued use of our official website or applications will be deemed as your acceptance of the revised policy.
How We Collect Information
- You provide your personal information through interactions with our products;
- You contact us or interact with our employees through various communication channels;
- You authorize us to obtain your personal information from third parties;
- You choose to subscribe to our emails, notifications or contact lists;
- We may automatically collect certain information as a result of your access to or use of the products;
- We may receive information provided by affiliates to which you have consented.
Information We Collect
- User-Generated Data: We collect data related to blockchain addresses and transactions that you initiate or participate in through our products.
- Browser Information: To enhance your experience, we collect information about your browser interactions for analysis purposes.
- IP Address Processing: For security purposes, to prevent malicious activities, and to comply with legal requirements, we may temporarily process or store your IP address.
Although we minimize the collection of personal information, we may collect personal information including but not limited to your name, contact information (such as phone number, email address) or other personal information to meet your needs or requests for specific product features.
We do not collect financial payment or banking information, but certain features provided by third parties may require you to provide such information.
How We Use Your Information
The purposes for which we collect, use or disclose your personal information include but are not limited to:
- To provide you with the products and/or support you request;
- To create accounts or profiles for you to use the products, if necessary;
- To improve your experience with the products and enable you to interact with third-party platforms;
- To manage our relationship with you;
- To associate your wallet through the unique serial number of your mobile device;
- To push important notifications to you, such as software updates, terms and policy changes;
- To assist with your inquiries, feedback, complaints and requests;
- To notify you of our products, projects, events and promotional information;
- To resolve any disputes, investigate any complaints, claims or disputes;
- To conduct internal audits, behavior tracking, data analysis and research;
- To comply with our legal and regulatory obligations and cooperate with regulatory authorities;
- To comply with international sanctions and applicable securities regulations, and combat money laundering or terrorist financing;
- To perform our obligations and contractual terms; or
- Any other reasonable purpose related to the above purposes.
Accuracy of Personal Information
We generally rely on personal information provided by you (or your authorized representatives). To ensure that your personal information is current, complete and accurate, please inform our Data Protection Officer through the following contact information if your personal information changes: [email protected].
How You Control and Update Your Personal Information
You have the right to control the personal information provided to imToken and have the responsibility to ensure that all personal information you provide to us is true, accurate and complete. Our applications may provide you with functionality to exercise the controls described in this section. If you wish to exercise these controls, please contact our Data Protection Officer through the following means: [email protected]. We will respond to your request within a reasonable time whenever possible.
If you choose not to provide us with the required personal information, you may not be able to use our applications, or we may not be able to contact you or provide you with the products or support you need.
- Right of Access or Right to Know: You have the right to access your personal information and request that we provide details about how we process that information, including why we process it.
- Right of Rectification or Correction: You have the right to correct, update or supplement inaccurate or incomplete personal information.
- Right of Erasure: You may request anonymization, deletion or destruction of your personal information if there are no other legitimate interests.
- Right to Restrict Processing: In certain circumstances, you have the right to stop us from processing your personal information, except for storage purposes.
- Right to Portability: You can import other wallets into imToken, or export your wallet from imToken to other token management wallets.
- Right to Withdraw Consent: You have the right to withdraw your consent to the processing of personal information at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal.
- Right to Opt-Out of Targeted Advertising, Sale or Sharing: You may request to stop the use of your personal information for targeted advertising.
Information We May Share or Transfer
In order to provide our products and services and to provide you with a better and more secure experience, we need to share your personal information in certain circumstances, including sharing with our group companies, service providers and other third parties. We will not sell, exchange or otherwise transfer your personal information to third parties without your consent.
- If you have consented to the disclosure of your personal information to our strategic partners and affiliates, we may disclose your personal information to them. They will only use it for the purposes you have consented to.
- You agree that we may disclose or share your personal information to the following third parties:
- Service providers and data processors who provide services to us, such as conducting customer identification checks, transaction identification checks, accounting, data processing or management services, website hosting, maintenance and operational services, email services, analytics services, payment transaction processing, marketing, etc.;
- Our advisors and professional advisors, such as accountants, lawyers, auditors, etc.
- To the extent permitted by applicable laws and regulations, imToken may collect and use your personal information without your prior consent or authorization in the following circumstances:
- Information related to national security and defense;
- Information related to public safety, public health, and major public interests;
- Information related to criminal investigation, prosecution, trial and execution;
- Personal information in the public domain;
- Personal information collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;
- Personal information necessary to maintain product security and compliance, such as for detecting or resolving product issues;
- In the case of mergers and acquisitions, if personal information transfer is involved, we may require the recipient to continue to comply with this Policy;
- Other circumstances permitted by laws and regulations.
Automated Data Collection Technologies
We use automated data collection technologies in our applications. For example:
- Cookies (or Browser Cookies): Cookies are small text files set by website or application operators to identify your browser or device.
- We may use Cookies in website applications to store and track information such as user numbers, usage frequency, user profiles and their online preferences. Cookies do not capture information that directly identifies you, but the information collected can help us analyze application usage and improve your online experience.
- You can control the use of Cookies through your browser settings. Most browsers allow you to block Cookies, delete Cookies, or set preferences for certain websites. However, this may affect the functionality of the application.
- Web Analytics: Web analytics is a method of collecting and evaluating visitor behavior, including analyzing traffic patterns to determine how frequently users visit websites or mobile applications or which features they prefer to access. The web analytics functionality of our applications is provided by third-party service providers.
How to Protect Your Personal Information
- If imToken ceases operations, we will stop collecting your personal information and take measures to delete or anonymize the personal information we hold within a reasonable period.
- To protect your personal information, we may adopt data security technologies, improve internal compliance levels, provide security training for employees, and set relevant data access permissions to protect your personal information.
Data Security Measures
We are committed to protecting the security of your personal information. We have implemented appropriate technical and organizational measures to prevent your personal information from unauthorized access, disclosure, use, modification, destruction or accidental loss. These measures include:
- Sensitive data encryption;
- Secure access controls;
- Regular security audits, penetration testing and vulnerability assessments;
- Data protection training for employees;
- Emergency response plans;
- Data backup and recovery procedures.
Data Breach Notification
In the event of a data breach that may pose a high risk to the rights and freedoms of individuals, we will promptly notify affected individuals and the Personal Data Protection Commission (PDPC) in accordance with applicable laws and regulations. The notification will include the nature of the breach, the types of personal data affected, and the measures we have taken to mitigate the impact of the breach.
Personal Information Retention
We will cease to retain your personal information when we reasonably believe that the information no longer serves the purpose for which it was collected and is no longer necessary for legal or business purposes, or delete the means of associating it with you.
In accordance with imToken's data retention policy requirements, we may retain your personal information for the time necessary in connection with legal claims, complaints, litigation or regulatory proceedings.
Disclaimer
- After you use third-party services, you acknowledge that this Policy no longer applies to the collection, use, disclosure and transfer of your personal information by such third parties. We cannot guarantee that any third party will implement reasonable security measures to protect your personal information.
- You assume full responsibility for the use of third-party services and agree that you will not hold imToken liable for any loss or damage arising from the collection, use, disclosure and transfer of your personal information by such third parties.
- You acknowledge and accept that, to the maximum extent permitted by applicable law, imToken will take reasonably possible measures to protect your personal information on an "as is", "available" and "with defects" basis, based on existing technology, and try to avoid disclosure, tampering or damage to information. Since imToken transmits data through wireless networks, we cannot guarantee the privacy and security of wireless internet data transmission.
Governing Law and Dispute Resolution
- You should fully understand and comply with the laws, regulations and rules related to the use of our products in your jurisdiction.
- This Policy shall be governed by and construed in accordance with the laws of the Republic of Singapore.
- If any dispute arising from or related to this Policy, including any question regarding its existence, validity or termination, the parties should first seek to resolve the dispute. If the dispute cannot be resolved within thirty (30) days from the commencement of the dispute resolution procedure, the dispute shall be submitted to the Singapore International Arbitration Centre ("SIAC") for arbitration under the Singapore International Arbitration Centre Arbitration Rules then in effect, and the arbitral tribunal shall consist of one arbitrator appointed by the President of SIAC. The language of arbitration shall be English. Each party irrevocably consents to the non-exclusive jurisdiction of the Singapore courts to support and assist the arbitration proceedings, including providing interim relief for the outcome of the proceedings when necessary.
- Any translated version of this Policy is provided for user convenience only and is not intended to modify the original English version. If there is any inconsistency between the English version and the non-English version of this Policy, the English version shall prevail.
IMTOKEN PTE. LTD.
(Company Registration No.: 201800958N)