About this Privacy Policy

Goldshell Privacy Policy describes how INTCHAINS PTE.LTD.as well as its affiliates (collectively, “we”, “us” or  “our”) collects, uses, and shares your personal information when you use our  websites (including but not limited to https://www.goldshell.com/) ,application, products and services.

This Privacy Policy applies in conjunction with other notices, contractual clauses and consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override them unless we expressly state otherwise.

Under this Privacy Policy, “personal information” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information we have access to about that individual, except as otherwise specifically provided by applicable laws in your region. We will use your personal information strictly in accordance with this Privacy Policy or applicable laws and regulations. Where the context requires, personal information shall also include sensitive personal data or information, as may be categorized under applicable law.

1 What information is collected by us and how do we use it?

1.1 What information is collected by us?

In order to provide you with our products and services, we will ask for necessary personal information. We will only collect information that is necessary for clearly lawful purposes, and ensure that such information is not further processed in a manner incompatible with these purposes. You have the right to decide whether or not to provide us with the information we request, but in most cases, if you do not provide personal information, we may not be able to provide you with products or services or reply to your inquiries.

When you create an ID, purchase and/or activate a product or device, download a software update, connect to our services, contact us (including by social media), participate in an online survey, or otherwise interact with us, we may collect a variety of information, including:

1.1.1 Information you provide to us

• Goldshell ID data, such as your Goldshell ID and related account details, including email address, devices registered, account status, and time spent engaging and using our products, services, website and/or application
• Identity data, such as your name, gender, and date of birth;
• Contact data, such as billing address, delivery address, postcode, email address and phone numbers;
• Account data, such as bank account details, bank statements, credit card details, cryptocurrency wallet account and payment details (such account data may also be collected directly by our affiliates and/or third party payment service providers);
• Transaction data, such as details about orders and payments, and other details in relation to the products and services you purchased;
• Profile data, such as your username and password, orders you have made, your interests, preferences, feedback and survey responses;
• Fraud Prevention Information, such as data used to help identify and prevent fraud, including a device trust score.
• Government issued identification (e.g. passport, ID cards) or other information or documents (such as validity period of passport/ID cards and other necessary and relevant information) required for us to conduct customer due diligence, know your customer checks, identity verification, or for fraud prevention purposes; and
• Additional information which we may request for due diligence checks as required for identity verification (such as your facial recognition data, copies of government issued identification, e.g. passport, ID cards, etc.) or if we believe that you have violated our Privacy Policy or any other terms and conditions referred to on our website or application.

1.1.2 Information that we collect in your use of services

• Device or related information. For example, IMEI number/OAID number, GAID number, MAC address, serial number, ROM version, operating system and platform, Android/IOS ID, browser type and version, screen display information, device keypad information, device manufacturer details and model name, device activation time, network operator, connection type, basic hardware information, sales channel and usage information (such as CPU, storage, battery usage, screen resolution and device temperature, camera lens model, times of screen brightened and times of screen unlocked).
• Information specific to you that may be assigned by third party service providers and business partners: We may collect and use the information such as your advertising ID assigned by third party service providers and business partners.
• Information related to your application usage, including unique identifiers for application (e.g. VAID number, OAID number, AAID number, Instance ID), application basic information, such as application list, application ID information, SDK version, system update settings, application settings (region, language, time zone, font), the time the application enters/exits the foreground and application status record (e.g. downloading, installing, updating, deleting).
• Location information: various types of information on your accurate or approximate location if you use location-related services. For example, region, country code, city code, mobile network code, mobile country code, cell identity, longitude and latitude information, time zone settings, language settings. If you would like to opt-out of providing location information, you are able to withdraw your permission for us to acquire this information on your location through your device settings on most mobile devices. If you have questions about how to disable your mobile device’s location services, please contact your mobile device service provider or the device manufacturer..
• Log information: information related to your use of certain features, apps, and websites. For example, cookies and other identifier technologies, IP addresses, network request information, temporary message history, standard system logs, crash information, log information generated by using the services (such as registration time, access time, activity time, etc.).
• Usage information: information on how you use our website, application, products and services or view any content on our website and application, including the time spent, items and data searched for on the website and application, access times and dates, as well as websites you were visiting before you accessed our website and other similar statistics;
• Marketing and communications data, such as your preferences in receiving marketing materials from us and our third parties, your communication preferences and your chat, email or call history on our website or with third party customer service providers;
• Other information: Environmental characteristics value (ECV) (i.e. value generated from Goldshell ID, device ID, connected Wi-Fi ID, and location information).

1.1.3 Information from third-party sources

When permitted by law, we will collect information about you from third-party sources. For example:

• for certain services that might include account and financial transactions, with your authorization, we may validate the information provided by you (such as phone number) through legitimate third-party sources for security and fraud prevention purposes;
• we may receive designated identifier symbols (such as IMEI/OAID/GAID from an advertiser) to provide advertising services to you;
• we may also obtain certain information such as account IDs, nicknames, avatar, and email address from third-party social network services (e.g. when you use a social network account to sign in to a Goldshell service);

technical data from analytics providers or advertising networks and social media platforms; information about you that others provided to us (e.g. your delivery address that other users may provide to us when they buy products for you via https://www.goldshell.com/ ).Where we collect personal data from third party sources, we will only collect your personal data, where permitted by law, for or in connection with the purposes for which those third parties are engaged, for the purposes of our collaboration with the third parties, or to carry out customer verification or due diligence checks. You agree and grant your consent (whether to us and third party service providers) to the transfer of your personal data from third parties to us for the purposes set out in this Privacy Policy and our other terms and conditions during the course of your use of our website, application and our provision of the products and services.

1.1.4 Non-personally identifiable information

We may also collect information that is not directly or indirectly linked to an individual and may not be classified as personal information under applicable local laws. This type of information is referred to as non-personally identifiable information, and we may collect, use, transfer, and disclose it. Here are some examples of the non-personally identifiable information we collect and how we may use it:

• We may collect statistical data generated when you use a specific service, such as non-identifiable device-related information, daily usage events, page access events, page access time events, and session events;
• We may collect network monitoring data, such as request times, number of requests, or error requests;
• We may collect application crash events, such as automatically-generated logs after an application crashes.

The purpose of collecting this information is to improve the services we provide to you. The type and amount of information collected depend on how you use our products and/or services.

We aggregate this information to provide you with more useful information and to understand which parts of our websites, applications, products, and services you are most interested in. For example, we may only need to know the number of active users in a day, and we do not need to know who those active users are, so aggregate data is sufficient for statistical analysis. We will make every effort to ensure that your personal data is separated from non-personally identifiable information and that the two types of data are used separately. However, if we combine non-personally identifiable information with personal information, the combined information will be treated as personal information for as long as it remains combined.

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

1.1.5 How do we collect your personal information?

We collect your Personal Data:

• Directly from you. For example, when you use our website or applications, register your Goldshell ID/Account, enter into a contract with us or use our Services, apply for or enquire about our website or products, participate in a promotion, survey, event or other marketing campaign organised by us, subscribe to our newsletters or alerts, request for marketing materials to be sent to you or contact us (for example, for the purposes of giving us feedback);
• From your authorised representatives. We may also collect your personal information from your authorised representatives. These include persons whom you have authorised and persons who have been validly identified as acting on your behalf pursuant to our security procedures;
• When you interact with our website or applications. When you interact our use with our website or applications, we may automatically collect your technical data or any personal data that you submit. We may also collect such personal data by using website cookies.

PLEASE NOTE, YOU ARE NOT REQUIRED TO PROVIDE THE PERSONAL INFORMATION THAT WE HAVE REQUESTED. HOWEVER, IF YOU CHOOSE NOT TO DO SO, IN MANY CASES WE WILL NOT BE ABLE TO PROVIDE YOU WITH OUR PRODUCTS OR SERVICES OR RESPOND TO REQUESTS YOU MAY HAVE.

1.2 How will this personal information be utilized?

We use personal information to process your transactions, power our services, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal information for other purposes with your consent.

We use your personal information only when we have a valid legal basis to do so. Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal information where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. The personal data we collect from you or via third parties may be used for certain purposes, such as:

• Register your Goldshell ID/Account.
• Process Your Transactions. We use your personal information to take and handle orders, process payments, and communicate with you about orders and services, and promotional offers. For example, to deliver goods and provide after-sales service, you need to fill in the consignee’s address, name, and mobile phone number, and we may share it with third-party warehousing, logistics and service providers. When you pay, we need to collect your order number, payment serial number, order amount, and payment method, and such information may need to be shared with the To provide after-sales service, we need to record the information of the equipment you purchased.
• Communicate with You. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies.
• Manage our relationship with you
• Power Our Services. For example, we collect personal information necessary to power our services, which may include personal information collected to improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting. Sometimes we collect user feedback. The feedback you choose to provide is important to help us improve our services. To process your feedback, we may use the personal information you provide to contact you and keep records. In addition, we troubleshoot when you send us error reports.
• Provide personalized user experience and content, including ads. To protect your privacy, we do use a unique identifier rather than your name, email, or other information by which you can be directly identified, to provide you with personalized products, services and activities, including advertising.
• Security and Fraud Prevention. To protect individuals, employees, and us and for loss prevention and to prevent fraud, including to protect individuals, employees, and us for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
• Comply with Law. For example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request. In certain cases, we collect and use your personal information to comply with laws and regulations. For instance, we collect bank account information for identity verification and other purposes.
• Providing push service. Goldshell Account ID , GAID, FCM token, Android/IOS ID will also be used to provide the Goldshell push service and notification service to evaluate advertising performance and send notifications about software updates or new product announcements, including information about sales and promotions. To provide the above service for you, application relevant information (app version ID, app package name), and device relevant information (model, brand) will also be collected. We may use your personal information for the purpose of sending you push messages (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties. This is only done with your consent, where required under applicable laws. You may opt-out from receiving marketing information from us and third parties at any time by changing your preferences in the settings of your devices, or managing your preferences through the third-party app/website.
• Sending notices. From time to time, we may use your personal information to send important notices, such as notices about purchases and changes to our terms, conditions, and policies.
• Other purposes in connection with the above
• Other purposes with your consent or as otherwise permitted by applicable laws and regulations without your consent.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If there is any change in the purposes for which we collect your personal information, we will inform you of such change.  If we need to use your Personal Data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so.

We do not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review. We retain personal information only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal information collected and, if retention is required, work to retain the personal information for the shortest possible period permissible under law.

2 Cookies and other technologies

We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements. To enable our systems to recognize your browser or device and to provide services to you, we use cookies. We generally treat data we collect using these cookies and similar technologies as nonpersonal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information in those regions.

Cookies

Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive. We use cookies and similar tools to provide our services, for example:

Recognizing you when you sign-in.

• Displaying features and services which might be of interest to you, including ads on our services.
• Preventing fraudulent activity and improving security.
• Keeping track of your preferences such as currency and language.

We also use cookies to understand how users use our services so we can make improvements. With cookies, we can collect information about your use of our websites and applications, either for a single visit (using a session cookie) or for repeated visits (using a persistent cookie).

We will not use cookies for any purpose other than those described in this Privacy Policy. You can manage or delete cookies at your own preference. The settings on your browser will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable and remove cookies, and when cookies will expire. Find out how to manage cookie settings for your browser here: < Internet Explorer>、< Google Chrome>、< Mozilla Firefox>、< Safari> and  <Opera>。

Cookies allow you to take advantage of some of our essential features. If you block or otherwise reject operational cookies through your browser settings, some features and services may not work.

Similar Tools

In addition to cookies, we and some third parties may also use web beacons and pixel tags on websites, other local storage technologies (such as local shared objects and HTML5 local storage) and Do Not Track function. These technologies will be used for various purposes, including analysing service usage (together with cookies) and providing more satisfactory content and advertisements to you, record some information about your activities and preferences and etc.

3. How do we share, transfer, and publicly disclose your personal information?

3.1 Sharing

Information about our users is an important part of our business and we are not in the business of selling our users’ personal information to others. We may share personal information with our affiliated companies, service providers who act on our behalf, our partners, developers, and publishers, or others at your direction. They are obliged to process personal information in accordance with the provisions of this Privacy Policy and our instructions, and they cannot use the personal information for their own purposes. Once we have fulfilled our requirements, they must delete or return the data. Further, we do not share personal information with third parties for their own marketing purposes.

• Your information may be shared within our affiliates, but only for explicit, and legitimate purposes, and the sharing is limited only to information required by services.
• Service Providers. We may engage third parties to act as our service providers and perform certain tasks on our behalf, including supplier, third parties provide infrastructure technical services, logistics and distribution services, payment services, data processing services, etc. Our purpose of sharing this information is to realize the functions of products and services. For example, we must share your order information with logistics service providers to arrange delivery. In addition, we may also hire a third party to process or store data related to your use of our services and delivery of products, including personal information.
• Business Partners. we may sometimes cooperate with third parties to provide services or other products.
• Potential Purchasers. Buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by us about our users is among the assets transferred; or to a counterparty in a business asset transaction that we or any of our affiliates or related corporations are involved in
• Our subsidiaries, affiliates and related corporations
• Governmental or regulatory authorities having jurisdiction over us or as otherwise
• We may share your personal information with others in accordance with your instructions or with your consent.
• We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.

In addition, we may share your personal information with:

• Our accountants, auditors, lawyers, or similar advisors when we request their professional advice.
• Investors and other relevant third parties if actual or potential sales or other corporate transactions  related to entities within our Group.
• Other third parties as detailed in this Privacy Policy or as otherwise notified to you, such as disclosing specific information with your authorization.

3.2 Transfer

Except in the following circumstances, we will not transfer your information to any subject:

• Where we have obtained your explicit consent.
• If we are involved in the mergers, acquisitions, or sales (including asset, business and share sales) of all or part of our assets which may affect your personal information, we will notify you of any changes in ownership or use rights regarding your personal information through prominent notices by email and/or on our website or other appropriate means.
• In cases explained in this Privacy Policy or otherwise notified to you.

3.3 Public Disclosure

We may publicly disclose your personal information in the following circumstances:

• When we need to disclose the winners of promotions, contests or sweepstakes, we will only disclose limited information.
• When we have obtained your explicit consent, or you have disclosed information through our services such as on social media pages or public forums.
• Public disclosure based on law or reasonable grounds: including laws and regulations, legal procedures, litigation or government regulatory requirements.

4. How we store and protect your personal information?

4.1 Goldshell’s security measures

We are committed to protecting the security of your personal information. To prevent unauthorized access, disclosure or other similar risks, we have implemented all legally required physical, electronic and managerial measures and processes to safeguard the information we collect from your mobile devices and the Goldshell website and application. We will ensure that your personal information is protected in accordance with applicable laws.

We will ensure that the personal information collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We retain your personal information for no longer than is necessary for the purposes stated in this Privacy Policy, or for a period that may be required for tax and accounting purposes, unless extending the retention period is required or permitted by law.

While we use encryption to protect personal information transmitted online, we also protect your information offline. We implement trusted protection mechanisms to protect data and data storage servers from attacks. All of your personal information is stored on secure servers and protected in controlled facilities.We have dedicated access control measures for data storage, and we regularly review information collection, storage and processing practices, including physical security measures, to prevent any unauthorized access and use.

We strictly select business partners and service providers, and require them to protect your personal information in accordance with this Privacy Policy. In addition, employees, third-party service providers and business partners who access your personal information are bound by strict contractual confidentiality obligations.

We hold security and privacy protection training courses and tests to enhance employees’ awareness of the importance of protecting personal information.

We handle personal data breaches in accordance with applicable data protection regulations and notify relevant regulatory authorities and data subjects of data breach incidents in a timely manner, if necessary.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

4.2 What can you do?

We value your trust in providing us your personal information, thus we strive to use standard commercial means of protecting it. However, please note that no security measure is perfect and no product, service, website, data transfer, computing system, or network connection is absolute secure. For you, the most important thing is to prevent unauthorized access to your personal account password. You can set a unique password for Goldshell account to prevent password leaks from other websites, without disclosing your login password or account information to anyone unless they are authorized by you. Whenever possible, please do not disclose the verification code you received to anyone (including those who claim to be Goldshell customer service). Whenever you log in to the Goldshell website and application as a Goldshell account user, especially on someone else’s computer or public internet terminal, you should always log out of the session after it ends.

We are not responsible for any security breaches caused by third-party access to your personal information due to your failure to maintain the confidentiality of your personal information. Despite the above provisions, if there is any unauthorized use of your account by other Internet users or any other security vulnerabilities, you should immediately notify us. Your assistance will help us protect the confidentiality of your personal information.

4.3 Retention Policy

We retain personal information for as long as necessary for the purposes described in this Privacy Policy and in the separate privacy policies for specific products and services, or as required by applicable law. Personal information will be stopped from being retained and be deleted or anonymized after we have completed the collection purpose, or after we have confirmed your deletion or cancellation request, or after we have terminated the operation of the relevant services. Where possible, we have specifed the retention period for identified categories, types, or fields of personal information.

Depending on your jurisdiction, there may be exceptions for personal information that we process for public interest, scientific, historical research, or statistical purposes. Based on applicable law or your request, Goldshell may continue to retain such information beyond its standard retention period if necessary and permitted, even if further data processing is unrelated to the initial collection purpose.

5.Your rights

5.1 Your Rights to Your Personal Information

Under applicable laws and regulations in your country or region, you have the right to request access, correction, or deletion of any personal information we hold about you (hereinafter referred to as the request). These rights will be subject to specific exclusions and exceptions under applicable legal provisions.

You may also access and update the details relating to the personal information through https://www.goldshell.com/my-account/ or by logging into your account on your device. For additional information, you can contact us via  https://goldshellhelp.zendesk.com/hc/en-us/requests/new.

Once we obtain sufficient information to confirm that we can process your request, we will respond to your request within the time frame provided by applicable data protection laws. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable laws).

In detail:

• You have the right to be provided with clear, transparent and easily understandable information about how we use your personal information and your rights. This is why we are providing you with the information in this Privacy Policy.
• Based on the requirements of applicable laws, a copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for relevant information, we may charge a reasonable fee based on actual administrative costs according to and if permitted by the applicable laws.
• If any information we are holding on you is incorrect or incomplete, you are entitled to have your personal information corrected or completed based on the purpose of use.
• Based on the requirements of applicable laws, you have the right to request the deletion or removal of your personal information where there is no compelling reason for us to keep using it. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures. Please note that we may not be able to immediately remove the information from the backup system due to applicable law and/or technological limitations. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be deleted or be made anonymous.
• You have the right to object to certain types of processing, including processing for direct marketing (including where profiling is used), and under certain circumstances where the legal basis for processing (including profiling) is our legitimate interests.

We have the right to refuse to process requests or only comply in part with requests where an exemption applies or we are otherwise entitled to do so under applicable laws, such as if the request is manifestly unfounded or manifestly excessive or it would require the disclosure of information about third parties. In some circumstances, we may charge a fee, where permitted under applicable laws. If we believe that certain aspects of a request to delete the information may result in our inability to legally use the information for the establishment, exercise or defense of legal claims or reasons permitted by applicable law, it may also be rejected.

5.2 Withdrawal of Consent

You may withdraw your previously granted consent for specific purposes, including the collection, use, and/or disclosure of your personal information that we possess or control. Depending on the specific services you are using, you can contact us at https://goldshellhelp.zendesk.com/hc/en-us/requests/new to withdraw your consent. We will process your request within a reasonable time after receiving it, and  no longer collect, use, and/or disclose your personal information based on your request.

Depending on the scope of your withdrawal of consent, you may not be able to continue receiving the full benefit of Goldshell’s products and services. However, your decision to withdraw your consent or authorization will not affect the validity of the personal information processing activities we have carried out up until the point of withdrawal.

Please note that withdrawing consent also does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

5.3 Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing by contacting us at   or updating the details relating to your personal information through https://www.goldshell.com/my-account/ or by logging into your account on your device.

5.4 Cancellation of Services or Accounts

If you wish to cancel a specific product or service, you can contact us via https://goldshellhelp.zendesk.com/hc/en-us/requests/new.

If you wish to cancel your Goldshell account, please be cautious as this action will render you unable to use Goldshell products and services. In certain specific cases, cancellation may be blocked or delayed. For example, if you have a processing order in Goldshell website or Goldshell application and your payment has not been completed, we may not be able to immediately support your request.

6. Protection of minors’ information

Goldshell does not allow any children under the age of 13 or the equivalent age as specified by law in your jurisdiction to use Goldshell or buy Goldshell’s products. We do not knowingly collect personally identifiable information from children under the age of 13 or the equivalent age as specified by law in your jurisdiction. Should a parent or guardian have reasons to believe that a child under the age of 13 or the equivalent age as specified by law in your jurisdiction as provided Goldshell with personal information without their prior consent, please contact us to ensure that the personal information is removed and the child unsubscribes from any of the applicable Goldshell’s products or services.

7. Transfer of Personal information Between Countries

Goldshell provide products and services around the world, thus your personal information may be transferred to or accessed by entities around the world to perform processing activities such as those described in this Privacy Policy in connection with your use of our products and services. Goldshell complies with laws on the transfer of personal information between countries to help ensure your data is protected, wherever it may be.

In particular, if Goldshell transfers your data generated in the EU to our affiliates or third-party service providers outside the EU, we will adopt EU-based standard agreement terms or the security protection mechanisms in the General Data Protection Regulation (GDPR).

In particular, if Goldshell transfers your data outside of Singapore, we will make sure that your personal data is protected to at least the same standard as that in Singapore. For example, we will always ensure that there is a proper legal agreement or binding corporate rules that cover the data transfer.

8. Third-Party Websites and Services

Our Privacy Policy does not apply to products or services offered by a third party. Depending on the Goldshell’s product or service you use, it may incorporate a third parties’ products or services. Some of these will be provided in the form of links to third parties’ websites, and some will be accessed in the form of SDKs, APIs, etc. Your information may also be collected when you use these products or services. For this reason, we strongly suggest that you take the time to read the third party’s privacy policy just like you read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

We may share your personal data with our third party service providers or affiliates (e.g. payment service providers) in order for them to offer services to you other than those related to your use of our website or application or our products and services. We take reasonable and feasible measures to ensure that the personal data we share with our third party service providers or affiliates is minimal and relevant to what is necessary in relation to the purposes for which they are processed. Your acceptance and use of the third party service provider’s or our affiliate’s services shall be subject to terms and conditions as may be agreed between you and the third party service provider or our affiliate. Upon your acceptance of the third party service provider’s or our affiliate’s service offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy of the third party service provider or our affiliate, which shall be the data controller of such data. You agree that any queries or complaints relating to your acceptance or use of the third party service provider’s or our affiliate’s services shall be directed to the party named in the applicable privacy policy.

9. How this Privacy Policy is updated?

If you choose to use Goldshell, your use and any dispute over privacy is subject to this Privacy Policy and our User Agreement. If you have questions about this Privacy Policy or privacy practices including where a third-party service provider is acting on our behalf, or would like to submit a complaint, please contact us. You can also ask us questions about how to submit a privacy complaint and we will endeavor to help.

Our business changes constantly, and our Privacy Policy will change also. We advise you to review this page periodically for any changes. If you do not agree with the revised content, you shall stop accessing Goldshell’s website or application immediately. When an updated version of the Privacy Policy is released, your continued access to Goldshell means that you agree to the updated content and agree to abide by the updated Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.

Due to differences in local laws and languages, the local versions of this Privacy Policy may be different from this version. In the case of any conflicts, the local versions shall prevail.

10. Applicable Law

This Privacy Policy shall be governed by and construed in accordance with the Singapore law. In the event of any dispute or claim arising out of or in connection with this Privacy Policy or its validity, interpretation and performance, the parties shall first attempt to settle such dispute or claim by friendly negotiation. The Singapore courts shall have exclusive jurisdiction in relation to any dispute arising out of or in connection with this User Agreement, including any question regarding its existence, validity or termination.

11. Contact Us

If you have any comments or questions about this Privacy Policy, or if you have any questions about our collection, use or disclosure of your personal information, please contact us by visiting https://goldshellhelp.zendesk.com/hc/en-us/requests/new or contact our Data Protection Officer at the contact details below:

Data Protection Officer

[email protected]