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Privacy Policy

Version 2026-10-11

Foreword

NoviOne (hereinafter referred to as "We" or "the Platform") firmly believes that personal information security and privacy are your fundamental rights. To protect your rights during the use of our services (hereinafter collectively referred to as "the Services"), We have established this User Privacy Agreement (hereinafter "the Agreement") to clearly outline how We collect, use, store, share, and protect your personal information, as well as to explain your relevant rights. Please carefully read and fully understand all terms of this Agreement before using the Services. By using or continuing to use the Services, you expressly acknowledge and agree to our handling of your personal information in accordance with the provisions of this Agreement.

I. Scope of Information We Collect

To provide you with safe, efficient, and personalized services, We will collect and obtain your relevant information in the following business scenarios, if you choose to use it or if it is required by law:

1. Account registration and verification information: When you register a NoviOne account, you may need to provide us with your phone number, email address, name, ID information, biometric information, and other information to complete real-name verification and create your personal account.

2. Service Usage and Transaction Information: When you use this Service, We automatically collect and log information from your browser, computer, and mobile device. This includes, but is not limited to, your IP address, device identifiers (e.g., IMEI/IMSI), hardware model, operating system version, software list, network type, access date and time, browsing and click records, transaction instructions, transaction amount, and recipient information.

3. Location information: To comply with anti-money laundering laws and provide regional services, We may collect your approximate or precise location information through IP address or GPS technology with your authorization.

4. Information obtained from third-party partners: In order to jointly provide services to you or improve the quality of services, We may obtain supplemental information from cooperating financial institutions, identity authentication service agencies, and other business partners with your authorization or legally shareable information, subject to laws and regulations.

5. Identity-verification information: If you choose identity verification, We collect the residence country, nationality, legal name, date of birth, international phone number, account email, identity-document type and number, and the required document images. Passport verification uses the identity page; supported two-sided documents use front and back images. We do not collect a selfie or biometric template in this workflow.

II. How We Use Your Information

We strictly comply with laws and regulations and agreements with users, and use the collected information for the following purposes:

  • Provide, maintain, and optimize the Service, and process your instructions;
  • For identity verification, customer service, security, fraud monitoring, archiving, and backup purposes to ensure the security of the products and services We provide to you;
  • Conduct manual NoviOne identity review and, only when the identity-verification screen offers it and you explicitly agree, prepare and send the consented submission to the card provider's sandbox identity-review service;
  • Design new products, conduct market research, and perform data analysis to improve the content and quality of our services;
  • Send you important service notifications (such as transaction confirmation and policy changes) and information about products and services that may interest you (such as promotional activities). If We want to send commercial advertisements to you, We will ask for your explicit consent separately;
  • Perform our legal obligations and comply with applicable laws, regulations, judicial rulings, regulatory provisions, etc.

III. How We Share, Transfer, and Publicly Disclose Your Information

We understand the importance of personal information and are obligated to keep it confidential. We will not share your personal information with any company, organization, or individual except in the following cases:

  • Get your explicit consent: We will share your information with third parties only with your explicit consent.
  • Sandbox card-provider identity review: If you explicitly accept the provider-sharing disclosure on the identity-verification screen, We may share that submission's identity details and document images with the card provider for sandbox identity checks. Consent is bound to that submission and is not carried to replacement or historical submissions. Provider approval does not approve NoviOne KYC; an authorized NoviOne owner reviewer makes the separate NoviOne decision.
  • Sharing for purposes described in the "How We Use Your Information" section: We may share necessary personal information with our affiliates and partners (such as banks, payment institutions, and telecommunications carriers), but only for the purpose of providing services to us and subject to this Agreement.
  • Disclosure is required under legal mandates or to protect rights: When necessary under laws, litigation, arbitration, or requests from administrative or judicial authorities, We must disclose information. In emergencies, We may disclose information as permitted by law to safeguard our, your, or other users' personal and property safety or public interests.
  • Business transfer: In the event of a merger, acquisition, asset transfer, or other transaction, We may transfer your information as part of the transaction and require the new company or organization holding your personal information to continue to be bound by this Agreement.

IV. How We Protect Your Information

We have taken security measures in accordance with industry standards, including but not limited to:

  • Protect data transmission with encryption technologies (e.g., TLS/SSL);
  • Your password is encrypted irreversibly to ensure that even We cannot directly access it;
  • Establish a strict internal data management system and permission control process to limit unauthorized access by employees.
  • Retained NoviOne KYC details and document images are protected with a dedicated, versioned authenticated-encryption keyring. Access is limited to the identity-review workflow, and an authorized owner reveal is audited. Uploaded document images are decoded, re-encoded without original metadata, and are not exposed through public file URLs.

Despite the aforementioned security measures, please understand that there is no "perfect" security technology in the Internet field. In the event of a personal information security incident, We will activate the emergency plan in accordance with the requirements of laws and regulations, and fulfill the obligation of notification and reporting in accordance with the law.

V. Your Rights and Choices

You have the following rights to your personal information:

  • Access & Edit: You can access and update your profile information through your account settings.
  • Delete: In certain circumstances (such as when We process your information in violation of the law), you may request us to delete your personal information.
  • Withdraw consent: You can withdraw a consent you have granted by changing device permissions or unsubscribing from emails or SMS, but this does not affect the validity of personal information processing activities based on the consent before withdrawal.
  • Delete account: You can apply to delete your account through the official channels provided by this Platform. After account deletion, We will stop providing you with products and services, and delete or anonymize your personal information in accordance with applicable laws.
  • KYC retention: Before submission, the Privacy reader on the identity-verification screen states the effective retention policy reported by the service. Under account-lifetime retention, encrypted identity details and document images remain while the member account exists, including pending, approved, and rejected submissions, for identity review, security, and administration; finalized account deletion erases KYC evidence and private review notes from the live database. Under a bounded after-review policy, review may take up to 30 days and retained live evidence is removed after the disclosed zero- or 30-day post-decision period. Existing backup copies expire under the separate backup lifecycle, and immutable financial, decision, and audit records remain where required. A future retention-policy change applies to a new submission only and requires fresh acceptance; it does not silently rewrite an earlier submission's agreed retention.

VI. How We Handle Information About Minors

Our services are primarily for adults. We do not allow minors under the age of 18 to use our services or provide us with personal information. If We discover that We have collected personal information of minors without the verifiable consent of their guardians, We will delete the relevant data as soon as possible.

VII. Update of This Agreement

We may revise this Agreement as needed due to business adjustments, regulatory changes, or technological advancements. The updated Agreement will be published on this Platform and take effect immediately. For significant changes, We will notify you through prominent means such as website announcements or push notifications. Please check regularly for the latest Privacy Policy updates.

VIII. Disclaimer

We will be exempted from liability in accordance with relevant laws and regulations under the following circumstances:

  • Service interruption or information leakage caused by force majeure (such as natural disasters, wars, riots, etc.), government actions, or third-party services (such as telecom operators, network viruses, hacker attacks, etc.);
  • If you voluntarily disclose your account password to others or share your registered account with others, personal data leakage may result;
  • Personal data leakage, loss, theft, or tampering caused by force majeure such as computer problems, hacker attacks, computer virus invasion or outbreak, temporary closure caused by government regulation, and other factors affecting the normal operation of the network.

IX. Contact Us

If you have any questions, comments, or suggestions about this Agreement, or if you find that your personal information may be disclosed, or if you wish to exercise your relevant rights, please contact us.

The final interpretation right is reserved by NoviOne.