華夏國寶

 

Privacy Policy

Updated June 2024

 

 

Treasures of the Silk Road Limited ("TOTSR Limited") is committed to protecting the privacy of people who use our services (including clients and subscribers to online services), job applicants and current employees, contacts, business partners and users to the TOTSR Limited website and TOTSR Wallet. This Privacy Policy details how TOTSR Limited collects, uses, discloses, transfers and stores your personal information.

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This Privacy Policy applies to personal information about you that we collect, use and otherwise process in connection with your relationship with TOTSR Limited and TOTSR Wallet.

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Personal information processed by TOTSR Limited in connection with this Privacy Policy is controlled by a "data officer" (as provided for under applicable data protection laws). The information collected through the website and the data officer for personal information collected by TOTSR. Limited is listed in the Data Officer page at the end of this Privacy Policy. As set out in this Privacy Policy it may be necessary for regulatory reasons for TOTSR Limited to share your personal data. In such circumstances business partners, advisers and sub-advisers of TOTSR Limited may be joint data officers of your personal information. If you have any questions about any aspect of this Privacy Policy please contact us at info@treasuresofthesilkroad.com and we will do our best to attend to your query.

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Please note that throughout this Privacy Policy the word "website" refers to any web page and TOTSR Wallet dApp directly controlled and managed by TOTSR Limited.

 

1. IP Addresses and Other Technical Information

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1.1 An IP address is a unique address that identifies a device on the internet or a local network. IP stands for "Internet Protocol," which is the set of rules governing the format of data sent via the internet or local network. In essence, IP addresses are the identifier that allows information to be sent between devices on a network for communication purposes. In addition to your IP address, we may also collect: your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your visit including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), pages viewed, download errors, page interaction information (such as scrolling clicks) and methods used to browse away from the website.

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1.2 TOTSR Limited uses this information for its legitimate reasons to compile statistical data on the use of our website and to track how users navigate through our website in order to enable us to evaluate and improve it.

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2. Information Collected by Using Our Website

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2.1 You are not required to provide any personal information when accessing our website for general review ("read-only access")

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2.2 If you accept our Terms and Conditions and User Policy to use our services (ie. creating an embedded wallet, providing your own wallet for Account Abstraction, procuring a Freemium or Premium TOTSR Wallet NFT) and to subscribe to our products, you will be required to upload information for KYC (Know-Your-Customer) and ID Verification purposes. This is required by regulators as part of the client’s onboarding process. Personal information such as names, addresses, email addresses, telephone numbers, date of birth and other personal details including your financial status will be collected for evaluation purposes. Such information are collected from users of the website who voluntarily input such information. Furthermore, your personal information will be recorded on an encrypted but open-source and composable blockchain layer named idOS. Your personal information recorded on idOS will form W3C Verifiable Credentials 

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2.3 The idOS is a place to store your identity data and credentials in a self-sovereign and decentralized way. The data is stored across multiple distributed nodes and is encrypted using the user's public keys. idOS has two key elements: 1) A compliant dStorage Network of Nodes, managed by Node operators that host user-encrypted data, usually in the form of W3C Verifiable Credentials 2) An Access Management Protocol, allowing users to manage their own data and grant/revoke access to third parties like dApps. By accepting our Terms and Conditions and User Policy to use our services, you agree to the creation of an idOS profile for ongoing AML monitoring, and evolving legal and regulatory compliance of our governing jurisdiction. Your profile will typically contain but not limited the following information: 

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• KYC/AML (verified)

• Proof-of-personhood (verified)

• Linked wallet addresses (verified)

• User inputs, like social profiles, gaming achievements, participation certificates, etc. (verified/unverified)

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2.4 If you communicate with TOTSR Limited via our online enquiry form, we may add you to our contact database unless you do not wish to be added.

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3. Contact Database

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3.1 Information that we typically hold in our database includes your contact information, including your name, job title, organisation's name, address, phone number(s), email address(es) and other identifier information;

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3.2 From time to time we may ask you by email to review your contact details and mailing list preferences, and update them as necessary. This not only helps us to keep the contact information we hold about you up-to-date, it also ensures that we only send you information that you have requested and/or is relevant to you.

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4. Interactions With TOTSR Limited

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4.1 We retain personal information relating to interactions between TOTSR Limited and people who use our services (including clients and subscribers to TOTSR Wallet), job applicants and current employees, alumni, contacts and business partners, including information relating to the services that we provide. We only retain information that is necessary for the purposes set out in this Privacy Policy.

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5. Use of Your Personal Information

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5.1 TOTSR Limited shall only collect and process personal information where it has a legal basis for doing so. This includes:

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• using the personal information for the regulatory and compliance purpose, where TOTSR Limited has a legal duty to comply;

• circumstances where you consent to the collection and use, and where TOTSR Limited has a legitimate interest in collecting and processing the personal information; and

• where the basis of processing is in accordance with relevant data privacy laws, whereby it is our legal obligation to meet such requirements

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5.2 TOTSR Limited uses personal information which we have collected from you in order to:

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• provide you with a more tailored and effective customer service;

• perform customer due diligence to the extent as necessary in accordance to the governing jurisdiction(s) of which the services are performed and to ensure compliance with all applicable regulatory requirements and applicable law;

• communicate with you via various channels such as electronic mails for administrative matters such as providing investment updates and billings;

• communicate with you in connection with any services that we are providing to you and otherwise perform the services for you that you have engaged us to provide;

• provide subscription and redemption information;

• carry out related administrative matters, which may include audit matters; and

• market our services and products to you where TOTSR Limited has a legitimate interest, or you have consented to us doing so and in accordance with your preferences

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5.3 TOTSR Limited shall only collect, use and otherwise process information revealing your physical and mental health, sexual orientation, political opinions, religious or other beliefs and commission or alleged commission of a criminal offence which is treated by applicable data protection laws as a "sensitive" or "special" category of personal information, where and only if it is relevant to our services. Such information shall be processed under applicable data protection laws. TOTSR Limited will only collect such information where this is necessary in connection with compliance and regulatory requirements or necessary for reasons of public interest.

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5.4 TOTSR Limited may need to collect and process personal information for certain legal compliance purposes before TOTSR Limited can perform certain services for you. This includes due diligence checks relating to anti-fraud, anti-money laundering, countering of financing of terrorism and other know-your-customer obligations. If you choose not to give us this personal information then it may delay or prevent TOTSR Limited from meeting our obligations and we may not be able to perform such services for you

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6. Marketing

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6.1 We may wish to use the personal information that we collect about you, to provide you with relevant marketing communications. We shall only send such marketing communications to you to the extent that doing so is in the legitimate business interests of TOTSR Limited or where you have consented to us doing so.

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6.2 You may withdraw that consent at any time by contacting us at info@treasuresofthesilkroad.com. In addition, each electronic marketing communication that you receive shall have an "unsubscribe" option, which will allow you to stop receiving similar communications in the future.

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7. Change of Ownership

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7.1 In the event of a re-organization, change in ownership, or transfer of all or part of our business, we reserve the right to transfer all of TOTSR Limited's data, including personal information, to a new entity or to third parties through which the business of TOTSR Limited will be carried out. We will use all reasonable efforts to notify you of such change by posting on our website, via an email sent to the email address you provide, and through secure in TOTSR Wallet app communication.

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8. Transfer of Information to Third Parties

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8.1 TOTSR Limited has business relationships with third parties. In some instances we may disclose your personal information to third parties such as regulators, legal counsels, auditors etc. where this is necessary to perform the services for which you have engaged TOTSR Limited for. Under such circumstances, TOTSR Limited will ensure that the third party is contractually bound to only process personal information in accordance with applicable data protection laws and with TOTSR Limited's specific instructions and requirements, and at all times in a manner that protects your rights under applicable data protection laws. Our business partners and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this Privacy Policy.

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8.2 In relation to any other third parties, TOTSR Limited will only disclose or transfer your information where you have given your consent or where we are required to do so by law or other regulatory code or practice, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.

 

9. Transfer of Information Abroad (International Transfers)

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9.1 As part of the transfers of personal information under Clause 8, personal data may be transferred to or accessed from countries whose laws provide a level of protection for personal data not always equivalent to the level of protection that may be provided in your own country. 

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9.2 TOTSR Limited ensures that cross border transfers comply with all relevant laws and regulations and such transfer is necessary for the performance of the services for which TOTSR Limited has been engaged in your interests, or the transfer is otherwise permitted by applicable data protection laws.

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9.3 Subject to your express consent, TOTSR Limited will only transfer your personal information to a country that is deemed to have an adequate level of protection under the applicable data protection law or otherwise where TOTSR Limited has put in place adequate safeguards to protect the personal information. In particular where TOTSR Limited sends your personal information outside of Hong Kong Special Administrative Region, China, TOTSR Limited shall only do so where the recipient of the information is subject to data protection regime approved under applicable law.

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10. Retention of Data

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10.1 TOTSR Limited shall only retain your personal information for so long as there is a legal need to retain the information for the purposes set out in this Privacy Policy. TOTSR Limited’s retention period is aligned with mandatory requirements under the applicable laws.

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11. Security

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TOTSR Limited is committed to protecting the security of your personal information. We engage reputable IT service providers and Web3 B2B relationships that has robust security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.

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12. Your Rights

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You have various rights in respect of the personal information that we collect, use, disclose and transfer concerning you. These rights are set out below. Should you wish to exercise your rights please contact us at info@treasuresofthesilkroad.com

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• Right of Access

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You are entitled to obtain from us details concerning the processing of your personal information. This includes details of the data being processed, the purposes of the processing, any recipients of that information, the period for which the information is processed, the source of the information (if it is not provided by you), any international transfers of the information and the protections we put in place to protect your information. You are also entitled to details of any automated decision making, including profiling, involving your information. You are entitled to a copy of the personal information we process about you (including in electronic form). Additional copies may be subject to a reasonable administrative fee.

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• Right to Rectification

 

You are entitled to have any incomplete and inaccurate personal information held by us rectified.

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• Right to Erasure ("be forgotten")

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In certain circumstances you are entitled to have personal information erased, including where this is no longer necessary for the purposes for which it was collected and/or processed; or you withdraw consent to our use of the information. We may continue processing the information in certain circumstances, including: if there are grounds other than consent for processing the information; where processing is in compliance with a legal obligation or for reasons of public interest; or for the exercise or defence of legal claims. If you request that we erase your personal information we shall advise you if we consider that there are on-going grounds permitting us to continue processing your information.

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• Right to Restrict Processing

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You can ask us to restrict the processing of personal information that TOTSR Limited holds if: you contest the accuracy of the personal information we process about you; you consider that the processing is unlawful but you do not want us to erase the information; we do not require to continue processing the information but you wish the information to be retained in connection with a legal claim; or you have objected to the grounds upon which we process the information. Where you have asked us to restrict processing the information we shall only hold, process and erase the information as permitted by you or as permitted by applicable data protection laws. We will advise you if we do not agree with your request to restrict processing and our reasons.

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• Right to Data Portability

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Where you provide personal information to us and consent to us using it and the processing is carried out by automatic means you are entitled to receive a copy of that information in a machine-readable format and for that to be provided to another data officer, where technically possible.

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• Right to Object

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You are entitled to object to TOTSR Limited collecting, using and otherwise processing your personal information where the basis for the processing is TOTSR Limited’s legitimate interests or the processing is in the public interest. In such circumstances we shall cease processing your personal information unless: we are legitimately processing the information on a different basis; there are compelling legitimate grounds for continuing to process the personal information; or we are otherwise permitted to process the information under applicable data protection laws. If applicable, we will advise you of the basis upon which TOTSR Limited continues to process your personal information. If you are not clear of the ground(s) upon which we collect, use and process your personal information you can ask us to confirm this to you, as part of the Right of Access outlined above.

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• Right to Withdraw Consent

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Where you have given us consent to make use of your personal information for any of the purposes outlined in this Privacy Policy you shall be entitled to withdraw that consent. You may do this by emailing us at info@treasuresofthesilkroad.com

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• Right to Complain

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In the event that you have any questions, concerns or complaints regarding this Privacy Policy or the manner in which TOTSR Limited collects, uses and otherwise processes your personal information we shall always seek to address the same promptly and to your satisfaction. However if you consider that we have not done so you are entitled to lodge a complaint to your local supervisory authority. If you are unclear who the appropriate supervisory authority is for you, please contact us at info@treasuresofthesilkroad.com

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Cookies

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Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device.

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Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

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Updates

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This Privacy Policy may be updated from time to time and was last updated in June 2024. The current version of this Privacy Policy shall be displayed at TOTSR Limited’s website or may otherwise be requested at info@treasuresofthesilkroad.com

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Contact information

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If you have any questions in relation to this Privacy Policy please contact us at info@treasuresofthesilkroad.com