NiFiTi privacy policy

Proposed date: August 3, 2022

Effective date: September 1, 2022

Introduction

The software operation and service "NiFiTi" (hereinafter referred to as "NiFiTi" or "we") provided by iFREE GROUP and its affiliated companies attach great importance to protecting the personal information and privacy of users using "NiFiTi" software services (hereinafter referred to as "users" or "you").

In order to provide you with a more accurate and secure Internet environment, In accordance with the network security law of the people's Republic of China, the personal information security specification of information security technology, the personal information protection law of the people's Republic of China and other relevant laws and regulations (the "laws and regulations" in this Agreement)Refers to the current effective laws, administrative regulations, judicial interpretations, local regulations, local rules, departmental rules and other normative documents of the region / country where the user belongs, as well as the amendments and supplements to such laws and regulations from time to time, as well as relevant policies and regulations.)And the technical specifications define the principles of our collection / use / external provision of personal information, and we hope to further explain to you the relevant rights regarding your personal information through the NiFiTi privacy policy (hereinafter referred to as the "privacy policy").

Before using / continuing to use our software and services, please carefully read and fully understand this privacy policy, especially the terms and conditions marked with bold underline, to ensure that you fully understand and agree before using, and make appropriate choices according to the guidance of this privacy policy when necessary. If you do not agree with the contents of this privacy policy, it may cause our software / or services to fail to operate normally or fail to achieve the service effect we intend to achieve. You should immediately stop accessing / using our software / or services. By using or continuing to use the software and / or services provided by us, you fully understand and agree to all contents of this NiFiTi privacy policy (including the updated version).

It should be specially noted that this privacy policy is only applicable to "NiFiTi" software and services, and does not apply to other third-party products / services (including but not limited to any NFT issuer and merchants) accessed through "NiFiTi" products. Instead, it should apply to the specific agreements or similar policy statements reached by the third party and you, and it will directly collect and bear the legal responsibilities related to data from you, We do not assume any responsibility for the behavior and consequences of the aforementioned third party's collection and use of your personal information.

We will check or update the functions or services of "NiFiTi" software from time to time, and update this privacy policy. We will publish the updated version of this Privacy Policy on the relevant prominent pages of "NiFiTi" software. When you use "NiFiTi" software or services, please ensure to browse our privacy policy page to understand our updates to the privacy policy.

If you have any questions about this privacy policy or related matters, please email: support@nifiti.xyzContact us.

catalogue

This privacy policy will help you understand the following:

1.How do we collect and use your personal information

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

3.What rights can you exercise to manage your personal information

4.How do we store and save your personal information

5.How do we use cookies and similar technologies

6.How do we handle children's personal information

7.How is this Privacy Policy updated

8.How do you contact us

9.Dispute resolution

1. How do we collect and use your personal information

"NiFiTi" software is an equity and marketing platform based on NFT technology developed and operated by iFREE GROUP (hereinafter referred to as "we" or "iFREE"). In the process of using this product and service, we will collect the information that you actively provided or generated by using the service in the following ways to provide you with services, optimize our services and ensure the security of your account:

1.1 When you register your account, we will collect your mobile phone number or email to help you complete the account registration, protect your account security, and send a service notice to your mobile phone number / email. Mobile phone number and email information are your personal privacy information. The purpose of collecting such information is to confirm your network identity and provide you with corresponding information services. If you do not provide such information, you may not be able to use our services normally.

1.2 In order to complete the account registration, we will collect the avatar, nickname, user ID you set for the account and other information you actively provide. In order to better provide this service to you, we can use the above nickname, avatar and relevant operation information in your software, and show such information to you or other users. After your registration is completed, we will collect your blockchain address to issue the NFT you obtained to this address.

1.3 We register a blockchain wallet address for each registered account for free. The wallet is hosted on the "NiFiTi" platform, including its private key information, as the unique address for you to conduct NFT transactions on the "NiFiTi" platform. Under the condition that you ensure the security of your personal account information (including login password, mobile phone number, e-mail address and secure transaction password), we ensure the transaction security of the hosted blockchain wallet. This hosted blockchain wallet can only be used for NFT transactions related to the "NiFiTi" platform. It does not support any other token services. Please do not transfer your personal property to this wallet address.

1.4 In order to ensure your normal use of our services, maintain the normal operation of our services, improve and optimize your service experience and ensure the security of your account, we will collect your commonly used device identification (such as IMSI, IMEI, androidid, oaid, etc.), device MAC address, device Sn, mobile phone model, installed application list, system version, hardware parameters, network status and recordsSystem logs, multimedia files and other information. When you start the app for the first time after installation, we will read your clipboard information to obtain the source of the new installation.

1.5 We will save relevant records of your purchase of NFT and show them to you in the application. After you voluntarily agree to disclose the purchase record, other users can access it.

1.6 When you edit your avatar and upload pictures, we will access your album permission with your consent. The above information is sensitive information. If you refuse to provide this information, you will not be able to use the avatar normally. When you edit the avatar and take pictures for feedback, we will access your camera permission with your consent. The above information is sensitive. If you refuse to provide this information, you will not be able to use the normal shooting related services.

1.7 All permissions will not be opened by default. Only with your explicit consent can you be deemed as authorized. The fact that we obtain a specific permission does not mean that we will necessarily collect your relevant information; Even if we have obtained sensitive permission, we will only collect and use your relevant information according to this guide when necessary. You can view the opening status of your access rights to the above personal information through the application permission settings of this product in the system settings, and can decide to open or close these permissions. Turning on these permissions means that you authorize us to collect and use these personal information to realize the above functions. Turning off these permissions means that you cancel these authorizations, then we will not continue to collect and use your personal information, nor will we be able to provide you with the functions corresponding to these authorizations. Your decision to close the permission will not affect the processing of personal information based on your authorization.

1.8 Please understand that the functions and services we provide to you are constantly updated and developed. If a certain function or service is not included in the foregoing description and your information is collected, we will explain the content, scope and purpose of information collection to you through page prompts, interactive processes, website announcements and other means to obtain your consent.

1.9 Please note that at present, we will not take the initiative to obtain your personal information from a third party outside the "NiFiTi" platform. If we need to obtain your personal information indirectly from a third party for business development in the future, we will inform you of the source, type and scope of use of your personal information before obtaining it. If the personal information processing activities we need to carry out business exceed the scope of authorization and consent when you originally provide personal information to a third party, we will obtain your authorization and consent before processing such personal information; In addition, we will strictly abide by the provisions of relevant laws and regulations, and require third parties to guarantee the legality of the information they provide.

1.10 We will analyze the operation of our products according to the frequency and situation of your use of this product, fault information, performance information, etc., to ensure the safety of services, optimize our products and improve our service quality. We will not combine the information we store in the analysis software with the personally identifiable information you provide.

1.11 According to relevant laws and regulations, we can collect and use some necessary personal information without your authorization and consent in the following circumstances:

(1) Related to our performance of our obligations under laws and regulations;

(2) Directly related to national security and national defense security;

(3) Directly related to public safety, public health and major public interests;

(4) Directly related to criminal investigation, prosecution, trial and judgment execution and related matters;

(5) For the purpose of protecting your or other personal life, property and related major legal rights and interests, but it is difficult to obtain my consent;

(6) The personal information collected is disclosed to the public by yourself;

(7) Collect your personal information from legally disclosed information: from legal news reports, government information disclosure and relevant channels;

(8) Necessary according to the online agreement or contract you signed with the platform;

(9) It is necessary for maintaining the safe and stable operation of our products and / or services: finding and handling the faults of products or services and handling related problems;

(10) Other circumstances stipulated by laws and regulations.

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

2.1 share

2.1.1 we attach importance to the protection of your personal information. Your personal information is an important basis and component of the software and / or services we provide you. As for your personal information, we only collect and use it within the purpose and scope stated in this privacy policy or according to the requirements of laws and regulations. Generally, we will not share it with any company, organization or individual, Unless one or more of the following conditions exist:

(1) Your authorization has been obtained in advance;

(2) You proposed it yourself;

(3) Sharing necessary for the performance of legal obligations: we may share your personal information in accordance with the provisions of laws and regulations, the need for litigation and dispute resolution, or the requirements of administrative and judicial authorities according to law, and the need for the performance of other legal obligations.

(4) Necessary sharing with business partners:

2.1.2 You understand and know that in order to provide you with more complete and high-quality software and services, we will authorize business partners to provide you with some services. In this case, we may share some of your personal information with our partners to provide better customer service and user experience. Please note that we will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and only share the personal information necessary for providing services. We will conduct security assessment and processing on the output form, circulation and use of information data to protect data security. If we share your sensitive personal information or our affiliated companies change the purpose of using and processing your personal information, we will ask for your authorization again. At the same time, we will carry out strict supervision and management on our partners. Once we find that they have violated the rules in handling personal information, we will immediately stop cooperation and investigate their legal responsibilities.

2.1.3 at present, our partners include the following types, please refer toThird party information sharing list：

Serial number:	SDK / service name	Issuer	edition	Function and purpose
1	Aurora push	aurora	JPush Android SDK v4. seven point two JPush iOS SDK v4. six point six	Message push in app
2	Vonage	Nexmo	6.5.0	Send verification code SMS
3	mapBox Geocoding	mapBox	no version information	Obtain geographic location information according to longitude and latitude
4	bugly	tencent	Android 4.0.4 iOS 2.5.9	App exception reporting

2.1.4 cooperating third-party SDK service providers: when you use the functions provided by the third party in "NiFiTi", we may access the software development kit (SDK) provided by the third party to realize relevant functions. At this time, the third-party SDK service provider may collect your relevant personal information. The collection and processing of information by the aforementioned service provider comply with its own privacy terms, which is not related to "NiFiTi" and does not apply to this privacy policy. In order to ensure your information security to the greatest extent, we recommend that you check the privacy terms of any third-party SDK service before using it. In order to protect your legitimate rights and interests, if you find that there are risks in such SDK or other similar applications, it is recommended that you immediately terminate the relevant operations and contact us in a timely manner.

2.1.5 account security service: in order to ensure the security of your and other users' accounts and property, and protect your and our legitimate rights and interests from illegal infringement, the third-party security service provider may collect your necessary equipment information, network related information, operator information and log information to provide account security services;

2.2 transfer the possession of

Transfer refers to the transfer of control over your personal information to other companies, organizations or individuals. Unless we obtain your express consent, we will not transfer your personal information to any company, organization or individual. Except for the following circumstances:

(1) Your consent has been obtained in advance;

(2) You proposed it yourself;

(3) In case of merger, acquisition or bankruptcy liquidation of the company, the transfer of personal information may be involved. In this case, we will inform you about the situation and require new companies and organizations holding your personal information to continue to be bound by this privacy policy. Otherwise, we will require them to obtain your express consent again.

(4) Other circumstances stipulated by laws and regulations.

2.3 Public disclosure

Public disclosure refers to the act of releasing information to the society or unspecified people.

If there is a legitimate reason for public disclosure, we will inform you of the purpose and type of the publicly disclosed information before public disclosure (if your personal sensitive information is involved, we will also inform you of the content of the sensitive information involved), and make public disclosure after obtaining your authorization and consent.

As for your personal information publicly disclosed, we will carefully review its legitimacy, rationality and legality at the first time after receiving the application for public disclosure, and take the strictest personal information security protection measures and means to protect it during and after public disclosure.

In principle, we will not publicly disclose your personal information, except as otherwise provided by laws and regulations and under the following circumstances:

(1) The necessary desensitization information shall be displayed when the punishment announcement notice is made for the illegal account, infringement, fraud, etc;

(2) After obtaining your express consent.

Exceptions to authorization and consent for sharing, transfer and public disclosure of personal information

According to relevant laws and regulations, we may share, transfer and publicly disclose your personal information without your prior authorization and consent in the following circumstances:

1) In connection with our performance of our obligations under laws and regulations, including disclosure of your personal information to competent authorities in accordance with laws and regulations and mandatory requirements of judicial or administrative authorities; In this case, we will require the disclosure requester to issue effective legal documents corresponding to its request, and take security protection measures for the disclosed information that comply with laws and industry standards;

2) Directly related to national security and national defense security;

3) Directly related to public safety, public health and major public interests;

4) Directly related to criminal investigation, prosecution, trial and judgment execution and related matters;

5) For the purpose of protecting your or other personal life, property and related major legal rights and interests, but it is difficult to obtain my consent;

6) Your personal information disclosed to the public by yourself;

7) Personal information collected from legally disclosed information: legal news reports, government information disclosure and relevant channels.

8) Other circumstances stipulated by laws and regulations.

Please understand that according to the current legal provisions and regulatory requirements, sharing and transferring the personal information that has been de identified, and ensuring that the data receiver cannot recover and re identify the personal information subject, there is no need to notify you and obtain your consent.

3. What rights can you exercise to manage your personal information

We will try our best to take appropriate technical measures to ensure that you can access, update and correct your registration information or other personal information provided when using our services. When accessing, updating, correcting and deleting the above information, we may require you to perform a verification to ensure the security of your account.

3.1 Through the design of the interactive interface, we provide you with a channel to access, obtain, correct and delete relevant personal information by yourself. You can set it in the following ways:

Set and access [I - account and security] to modify the account login password;

Access, obtain and correct your personal data (including avatar and nickname) through [I - personal data];

Apply for account cancellation through [I - account and security - account cancellation]. After you cancel your account, unless otherwise specified by laws and regulations, we will delete or anonymize your personal information.

We will constantly optimize the channels and experiences for you to exercise your rights. If you have any questions or needs, you can contact us through the way agreed in this agreement.

3.2 You can change or withdraw the permission you authorized to us through the "setting -" NiFiTi "in the operating system of the device itself. We will collect personal information according to the settings you change or withdraw the permission. If you withdraw the authorization, we will no longer collect information related to these permissions. However, please note that this will lead to the unavailability of some or all functions. At the same time, your decision to change or withdraw your authorization will not affect our previous personal information processing based on your authorization.

3.3 For the sake of security and identity recognition, you may not be able to access, correct or delete some information directly through the "NiFiTi" interactive interface; If it is really necessary for you to access, modify or delete such information according to law, please send your questions to the designated contact mailbox by email according to the contact information provided in the introduction of this privacy policy. We will review the related issues as soon as possible and reply in a timely manner after verifying your user identity.

3.4 You can directly request us to delete (cancel) your personal information in case of the following circumstances, unless it has been anonymized or otherwise specified by laws and regulations:

(1) When our handling of personal information violates laws and regulations;

(2) When we collect and use your personal information without your consent;

(3) When our handling of personal information violates our agreement with you;

(4) When you cancel your "NiFiTi" account;

(5) When we terminate our services and operations.

4. How do we store and save your personal information

4.1 storage

4.1.1 We will store your information in a secure way, including local storage (for example, using app to cache data), database and server logs.

4.1.2 In general, we will only store your personal information within the time necessary to achieve the service purpose or under the conditions specified by laws and regulations.

4.1.3 Storage location: the user's personal information collected by us is stored on the software and / or the server in Hong Kong, China leased by the company. On the premise of complying with national laws, regulations and relevant provisions, and after obtaining your authorization and consent, we collect personal information and data from you according to this privacy policy, including your email, mobile phone number and transaction information, However, it does not include your other ID information, which may be transmitted to your country, region or the place where the software collects information and data and be accessed, stored and displayed overseas.

4.1.4 In this case, we will ensure that your personal information can receive the same protection in all regions as in the people's Republic of China. For example, we will implement security measures such as de identification before cross-border data transfer. In case of cross-border transmission of personal information, we will send you "NiFiTi" message notice or email separately to inform you of the purpose and recipient of personal information, and obtain your authorization and consent. We will strictly abide by Chinese laws and regulations to ensure that the data receiver has sufficient data protection capacity to protect your personal information.

4.1.5 Storage time: we promise to always store your personal information within a reasonable and necessary period in accordance with the provisions of the law. After the expiration of the above period, we will delete your personal information or anonymize your personal information.

4.1.6 If we stop operation, we will stop collecting your personal information in time, notify you of the stop operation in the form of push notice or announcement, and delete or anonymize your personal information.

4.2 protect

In order to protect the security of your personal information, we will strive to take various security measures (such as SSL) that meet industry standards to protect your personal information to minimize the risk of your personal information being damaged, embezzled, leaked, unauthorized access, use, disclosure and change. We will actively establish a data classification and classification system, data security management specifications, and data security development specifications to manage and regulate the storage and use of personal information and ensure that no personal information unrelated to the services we provide is collected.

Your account has security protection function. Please keep your account and password information properly. "NiFiTi" will ensure that your information is not lost, abused or altered by backing up to other servers, encrypting user passwords and relevant security measures. Despite the foregoing security measures, please note that there are no "perfect security measures" on the information network. In order to prevent the occurrence of safety accidents, we have formulated appropriate early warning mechanisms and emergency plans in accordance with the provisions of laws and regulations. If a security incident does occur, we will promptly inform you of the relevant information by mail, letter, telephone, push notification and other relevant methods. If it is difficult to inform the personal information subjects one by one, we will take reasonable and effective measures to publish the announcement. At the same time, we will actively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities and closely cooperate with the work of government agencies.

When our products or services stop operating, we will stop collecting personal information in a timely manner. We will notify you of the above changes in the form of push notifications, announcements and related forms, And delete your personal information or conduct anonymous processing within a reasonable period of time (the so-called "anonymous processing" refers to the process of technical processing of personal information so that the subject of personal information cannot be identified and the processed information cannot be recovered. The information obtained from the anonymous processing of personal information does not belong to personal information.)

Your active self-protection is also important to ensure the security of your personal information. The Internet is not an absolutely safe environment, and it is impossible to determine whether email, instant messaging, social software and other communication methods with other users are encrypted. We strongly recommend that you do not send your personal information in "NiFiTi" in this way, and please set a complex password when using such tools.

In case of personal information leakage, damage, loss and other security incidents, we will launch an emergency plan to prevent the expansion of security incidents. After a security incident occurs, we will promptly inform you of the basic situation of the security incident, the handling measures and remedial measures we will take or have taken, and our response suggestions to you in the form of push notifications and emails. If it is difficult to realize notification one by one, we will issue warnings through announcements and other means.

5. How do we use cookies and similar technologies

If you do not refuse to accept cookies, "NiFiTi" will set or use cookies on your computer and related mobile devices so that you can log in or use the "NiFiTi" platform services or functions that depend on cookies.

You have the right to choose to accept or reject cookies. You can refuse to accept cookies by modifying the browser settings or setting in the mobile device. However, if you choose to refuse to accept cookies, you may not be able to log in or use the "NiFiTi" platform services or functions that depend on cookies.

This privacy policy applies to the information obtained through "NiFiTi" cookies.

6. How do we handle children's personal information

"Children" in this privacy policy refers to minors under the age of 14.

Children are not allowed to create their own "NiFiTi" account. "NiFiTi" software and services are only available to adult users over 18 years old. If you are under 18 years old, please do not register your account and conduct NFT transactions.

If we find that we have collected children's personal information without our knowledge, we will try to delete the relevant data as soon as possible. If you think that we may have collected the information of your children under 14 years old or minor guardians without your consent, please contact us according to the contact information provided in the introduction of this privacy policy. We will delete the information after verifying the account information.

7. How is this Privacy Policy updated

We reserve the right to update or amend this privacy policy from time to time. If this privacy policy is updated, we will notify you through the "NiFiTi" client push notification and relevant reasonable methods, so that you can timely understand any changes made in this Privacy Policy and explain the effective date to you. Please read the changed privacy protection guidelines carefully. If you continue to use "NiFiTi", you agree that we will process your personal information according to the updated privacy protection guidelines.

These updates and amendments will form a part of this Privacy Policy and have the same effect as this privacy policy. Without your explicit consent, we will not reduce your rights under the currently effective privacy policy.

If such updates result in substantial reduction or significant change of your rights under this privacy policy, we will notify you in a prominent position or send you a push message or other ways before this privacy policy takes effect. If you continue to use our services, it means that you fully read, understand and agree to be bound by the revised privacy policy.

8. How do you contact us

If you have any complaints, suggestions and questions about the protection of personal information, or you have any questions about this privacy policy, you can contact us through the following ways. We will review the related issues as soon as possible and reply within 15 working days after verifying your user identity ("NiFiTi" official email): support@nifiti.xyz。

It should be noted that we may not reply to questions unrelated to this policy or your personal information rights.

9. Dispute resolution

The interpretation and dispute resolution of this Privacy Policy shall be governed by the laws of Hong Kong of the people's Republic of China. Any dispute arising from this Privacy Policy and our handling of your personal information can be brought to the local court of Hong Kong, China. If you think that our personal information processing behavior has damaged your legitimate rights and interests, you can also report to the relevant government departments.

The title of this privacy policy is only for convenience and reading, and does not affect the meaning or interpretation of any provisions in the text.