Privacy Policy

We value your privacy and data security.

0. Introduction and Policy Statement

0.1 Purpose and Background

This Privacy Policy is established to explain how BWSC Group (the “Group”) collects, processes, uses, and protects personal data in connection with its blockchain mainnet information services, decentralized wallet software (under development), ecosystem portals, and other technology-related services.

The Group is committed to respecting user privacy and implementing transparent and predictable data protection practices in accordance with generally accepted international data protection and information security standards.

0.2 Legal Nature and Effect

This Privacy Policy constitutes a material policy governing personal data protection between users and the Group.

By accessing or using any part of the Services, users acknowledge that they have read, understood, and agreed to this Policy in its entirety. If a user does not agree with any part of this Policy, the user should discontinue use of the Services immediately.

1. Scope of Application

1.1 Applicable Services

This Policy applies to the following services and activities operated, provided, or introduced by the Group:

• Official websites and technical documentation.

• Information display of blockchain mainnets, networks, or protocols.

• Decentralized wallet software and related functions (under development).

• Ecosystem portals, node or developer applications.

• User-initiated contact, inquiries, or interactions.

1.2 Exclusions

This Policy does not apply to websites, applications, DApps, smart contracts, or services independently developed, operated, or provided by third parties, even if accessed via the Group’s interface.

The Group is not responsible for the privacy practices of third-party services. Users should review the privacy policies of such third parties.

2. Definitions and Interpretation

2.1 Personal Data

Refers to any data that can directly or indirectly identify a specific natural person, including but not limited to names, ID numbers, contact details, etc. However, in the context of blockchain technology, standalone wallet addresses, transaction hashes (Tx Hash), or on-chain data are generally not considered personal data unless linked to a specific natural person’s real identity.

2.2 User

Refers to any natural person or legal entity that visits, browses, downloads, installs, or uses the Services.

3. Nature of Services and Technical Architecture

3.1 Decentralized Technology Characteristics

The Services provided or introduced by the Group are designed based on decentralized blockchain technology, operating through distributed network nodes rather than a single central controller. Users understand that blockchain technology is characterized by transparency, immutability, and decentralization.

4. Non-Custodial Core Statement

4.1 No Asset Custody

All wallet-related services provided or introduced by the Group are decentralized, non-custodial technical tools. BWSC Group does not hold, custody, manage, or control users’ digital assets, crypto assets, or other on-chain assets in any form. Users have complete and sole control over their assets.

4.2 No Access to Private Keys or Mnemonics

The Group does not collect, store, back up, transmit, or access users’ Private Keys, Mnemonic Phrases (Seed Phrases), Keystores, or any sensitive information that can directly or indirectly control blockchain assets. Such information is stored solely on the user’s local device, and the user assumes full responsibility for its safekeeping.

5. Categories and Classification of Personal Data

5.1 User-Provided Information

During the use of the Services, users may voluntarily provide specific information to BWSC Group through forms, applications, inquiries, or other interactions. Such information may include but is not limited to:

• Name or nickname.

• Email address or other contact details.

• Company, organization, or affiliation.

• Information voluntarily disclosed by the user in communications.

5.2 Automatically Collected Technical Data

When users visit the Group’s website or use related software services, the system may automatically record certain technical data to maintain service stability and security. Such data typically does not directly identify individuals and may include:

• Device information (e.g., model, OS version, language settings).

• Network connection information (e.g., approximate IP location, connection type).

• Service usage records (e.g., access time, pages viewed, error reports).

5.3 Public On-Chain Data

Users understand and agree that any operations performed on the blockchain network (e.g., transfers, smart contract interactions) will generate public and immutable on-chain data (e.g., wallet addresses, transaction amounts, timestamps). Such data is generated and recorded by the underlying blockchain protocol mechanisms and is not personal data collected or controlled by the Group.

6. Purpose of Data Collection and Use

6.1 Service Provision and Operation

• To provide, maintain, and optimize various functions of the Services.

• To process user applications, registrations, or subscription requests.

• To respond to user inquiries, suggestions, or complaints.

6.2 Security and Risk Management

• To detect, prevent, and address security threats, fraud, or malicious attacks.

• To perform system debugging, troubleshooting, and performance monitoring.

6.3 Communication and Notification

• To send important service announcements, system maintenance notifications, or policy updates.

• To send relevant event information or newsletters, subject to user consent.

7. Data Sharing, Disclosure, and Cross-Border Transfer

7.1 No Sale of Data Commitment

The Group commits never to sell, rent, or exchange users’ personal data to any third party for marketing or commercial purposes.

7.2 Necessary Third-Party Collaborators

The Group may engage screened third-party service providers (e.g., cloud hosting providers, security vendors, data analytics tool providers) to assist in the operation of the Services. Such third parties may access relevant data only to the extent necessary to perform their entrusted duties and are bound by strict confidentiality obligations and data security regulations.

7.3 Legal Requirements and Compliance

The Group may disclose relevant data to the extent necessary if required by law, court order, lawful government request, or to protect the rights, property, or safety of the Group, users, or the public.

7.4 Cross-Border Transfer Statement

The Group operates globally, and user data may be transferred to, stored in, or processed in countries where the Group or its service providers are located. Users consent to such cross-border transfers, and the Group will take reasonable measures to ensure data is adequately protected during transmission.

8. Data Retention and Deletion

8.1 Retention Period

The Group retains user data only for the period necessary to fulfill the collection purposes or as required by applicable laws.

8.2 Deletion Mechanism

Once the retention period expires or the collection purpose ceases to exist, the Group will delete, destroy, or anonymize relevant data in accordance with internal procedures. However, public data on the blockchain cannot be deleted or modified due to technical characteristics and is excluded from this provision.

9. Cookies, SDKs, and Analytics Tools

9.1 Use of Cookies

To enhance the functionality and user experience of the Services, BWSC Group may use Cookies or similar technologies on the website or related services. Cookies are small data files stored on user devices by browsers to record basic settings, usage status, or other technical information.

9.2 User Control

Users can choose to refuse or limit Cookie access through browser settings. However, disabling Cookies may cause some functions of the Services to operate improperly.

10. Information Security Measures

10.1 Security Protection

The Group employs industry-standard information security technologies and management measures (e.g., SSL/TLS encryption, firewalls, access control management) to protect user data security and prevent unauthorized access, leakage, tampering, or destruction.

10.2 Risk Warning

While the Group strives to protect data security, internet transmission cannot be guaranteed to be 100% secure. Users assume the risk of data transmission and must safeguard their devices, private keys, and related credentials.

11. Protection of Minors

11.1 Service Restrictions

The Services are not targeted at minors. The Group does not knowingly collect personal data from minors. If such collection is discovered, it will be deleted immediately.

12. Amendments to Privacy Policy

12.1 Right to Amend

The Group reserves the right to amend this Privacy Policy at any time to respond to legal changes, technological developments, or business adjustments. Revised policies will be published on the Group’s official website or related service interfaces with the update date.

12.2 Effect of Consent

Continued use of the Services after policy updates constitutes acknowledgement, understanding, and agreement to the revised content.

13. Contact Us

13.1 Contact Channels

If users have any questions, suggestions, or wish to exercise relevant rights regarding this Privacy Policy, please contact us via the contact channels published on the Group’s official website.

Last Updated: January 25, 2025