User Privacy Policy

We only collect the following service-related personal information as necessary to provide financial services and fulfill regulatory obligations:

• Identity Verification Information: Includes your name, date of birth, ID card number/passport number, nationality, address, phone number, email address, and biometric information (facial recognition data, fingerprint information). This is used to complete real‑name verification, open an account, and comply with U.S. anti‑money laundering (AML) and know‑your‑customer (KYC) regulatory requirements.
• Transaction and Financial Information: Includes your bank account information, securities account information, transaction records, position records, asset status, risk tolerance assessment results, and tax identification number. This is used to execute trading instructions, complete clearing and settlement, conduct risk management, and fulfill tax reporting obligations.
• Device and Usage Information: Includes your device model, operating system version, IP address, login location, browsing history, operation trajectories, and app crash logs. This is used to ensure system security, optimize service experience, and prevent fraud and cyberattacks.
• Other Information Required by Law: In accordance with the requirements of U.S. regulatory agencies such as the SEC, the Department of the Treasury, and the IRS, we may need to collect additional information to fulfill statutory disclosure obligations.

We do not collect personal information unrelated to the services we provide, nor do we force you to authorize the collection of unnecessary information. If you refuse to provide necessary information, you may be unable to use some or all of our financial services.

We strictly use your personal information in accordance with laws and regulations and the terms of this policy. The scope of use includes:

• Providing you with basic financial services such as account management, trade execution, market data inquiries, and customer consultation.
• Carrying out compliance work including risk control, anti‑money laundering, anti‑fraud, and insider trading investigations to meet financial regulatory requirements.
• Optimizing platform functionality and personalizing recommendations of financial products and services that match your risk tolerance (you may disable the personalization feature at any time).
• Sending you necessary notifications such as service announcements, trade confirmations, and regulatory‑required disclosures.
• Providing relevant information in response to legitimate requests from judicial authorities or regulatory agencies to fulfill statutory obligations.

We will not use your personal information for purposes other than those described above without your authorization. If we need to use your information for other purposes, we will separately obtain your explicit consent.

We strictly protect the privacy of your personal information and will only share your information with third parties under the following circumstances:

• Sharing with Service Providers: We only share information with third‑party partners that provide essential services to us, including exchanges, clearing institutions, payment institutions, data providers, cloud service providers, and compliance audit institutions. We require such third parties to process personal information strictly in accordance with our instructions and not to use it for any other purpose.
• Disclosure Required by Regulation or Judiciary: In accordance with U.S. federal or state laws, court orders, government directives, or legitimate requests from regulatory bodies such as the SEC, we may be required to disclose your personal information to relevant authorities.
• Business Transition Scenarios: If the Platform undergoes a merger, acquisition, asset transfer, or other business transition, your personal information may be transferred as part of the business assets. We will notify you before any such transfer and ensure that the information recipient remains bound by this Privacy Policy.

We do not sell or rent your personal information to any third party for commercial marketing purposes, nor do we disclose your personal information to third parties without your authorization, unless otherwise provided by law.

Storage Location and Duration: Your personal information will be stored on servers within the United States that meet financial regulatory requirements. The storage duration is the minimum retention period required by law (generally at least five years after account closure; certain regulatory requirements may mandate longer retention). After the retention period expires, we will anonymize or destroy your information.

Security Protection Measures: We use security measures that comply with financial industry standards, including encryption technology, firewalls, access controls, and data backups, to protect your personal information from unauthorized access, disclosure, alteration, or destruction. We regularly conduct information security tests and employee privacy training to ensure the effectiveness of these protection measures.

Security Incident Handling: In the event of a personal information breach or other security incident, we will notify you and relevant regulatory authorities in a timely manner as required by law and take emergency remedial measures to mitigate risks. However, if the breach is caused by uncontrollable factors such as force majeure or third‑party hacking attacks, we will fulfill our legal notification obligations but shall not bear any related liability for compensation.

In accordance with relevant U.S. laws, you have the following privacy rights:

• Right to Access and Rectify Information: You may access your personal information at any time in the platform account center. If you find any errors, you may request corrections by yourself or by contacting customer service.
• Right to Erasure (Right to be Forgotten): To the extent permitted by law, you may request the deletion of your personal information. However, we have the right to retain necessary information until the statutory retention period expires in accordance with regulatory requirements.
• Right to Withdraw Consent: You may withdraw your authorization for us to collect and use your personal information at any time. However, withdrawing consent will prevent you from continuing to use the platform services.
• Right to Data Portability: You may request a copy of your personal information. We will provide it to you in the format prescribed by law.
• Right to Object to Personalized Recommendations: You may disable the personalized product recommendation feature at any time in the platform settings. Disabling this feature will not affect your ability to use basic financial services.
• Right to Lodge Complaints: If you believe we have violated this Privacy Policy or applicable laws, you may file a complaint with us or the relevant regulatory authorities.

You may submit a request to exercise your rights through the platform’s online customer service or customer service hotline. We will respond to your request within 15 business days. To protect your account security, we will verify your identity before processing your request.

Protection of Minors: Our services are not directed to individuals under 18 years of age. If we discover that we have collected personal information from a minor without parental consent, we will promptly delete such information.

California Residents’ Rights: If you are a California resident, in addition to the rights described above, you also have additional rights under the California Consumer Privacy Act (CCPA/CPRA), including the right to non‑discrimination and the right to request data disclosure. For details, please contact us for a separate California User Privacy Notice.

Notice to Users Outside the United States: If you are a user outside the United States, you consent to the transfer of your personal information to the United States for storage and processing. We will ensure that the data transfer complies with the cross‑border data transfer requirements of your jurisdiction.

(These terms apply only to users whose habitual residence is within the territory of the People’s Republic of China – Mainland China)

• Data Export Control: We confirm that, with respect to the personal information of Mainland Chinese users, we will store such information preferentially on servers within Mainland China. If cross‑border transfer (including to our headquarters in the United States) is truly necessary, we will strictly complete the data export security assessment, personal information protection certification, or sign a standard contract as required by the Personal Information Protection Law of the People's Republic of China, and will separately obtain your explicit consent. Without your consent, we will not transfer your personal information outside Mainland China.
• Protection of Information Rights: In addition to the rights set forth in the general privacy policy, you may, in accordance with the laws of Mainland China, consult us regarding the handling of your personal information. We will respond within 15 business days. If you believe that our information handling activities have harmed your legitimate rights and interests, you may file a complaint with the relevant Mainland Chinese regulatory authorities or file a lawsuit with a competent Mainland Chinese people’s court.
• Minimum Necessary Collection Principle: For Mainland Chinese users, we collect only the minimum scope of information necessary to provide our services. We will not refuse you access to basic financial services because you decline to provide non‑essential information. We strictly refrain from collecting sensitive personal information such as biometric data, religious beliefs, or medical health information unless we have obtained your separate explicit consent and such collection is necessary for providing the service.

• Suitability Management Obligation: We will strictly assess your risk tolerance in accordance with Mainland Chinese regulatory requirements. Based on the assessment results, we will recommend financial products of corresponding risk levels and will not sell you products that exceed your risk tolerance. The risk assessment result is valid for one year; after expiration, you must complete a reassessment before you can continue to purchase financial products.
• Fee Transparency Commitment: We will publicly display the fee schedule and billing methods for all services in a prominent location on the platform, including transaction fees, remittance fees, account management fees, etc. No fees will be charged without explicit disclosure. If you have any objection to a fee, you may contact customer service at any time to request a detailed breakdown.
• Convenience of Dispute Resolution: For disputes arising between Mainland Chinese users and the Platform, you may choose to file a lawsuit either in the court where the Platform is registered or in the competent people’s court at your domicile, ensuring your right to resolve disputes near your place of residence.
• Prohibition of Tying and Forced Authorization: We will not force‑bundle other products or services when providing our services, will not require you to agree to all non‑essential authorization terms at once, and will not pre‑check consent boxes for non‑essential service options.

(These terms apply only to users who hold shares of U.S. public companies and exercise shareholder rights through this Platform)

• Voting Rights Service: In accordance with U.S. SEC rules and the requirements of public companies, we will promptly push to you the shareholder meeting notices, voting proposal explanations, voting guidelines, and other information for the public company whose shares you hold, and assist you in exercising your shareholder voting rights online. Your voting instructions will be submitted strictly in accordance with your will and will not be altered or delayed without authorization.
• Dividend and Rights Payout: For cash dividends, stock dividends, rights offerings, and other shareholder benefits distributed by public companies, we will transfer them to your account within three business days after receiving the relevant funds/rights, without unauthorized interception or delay. Applicable taxes will be withheld and paid in accordance with U.S. tax laws and the tax requirements of your jurisdiction, and we will provide you with access to tax payment certificates.
• Information Disclosure Notifications: We will promptly push to you annual reports, quarterly reports, material event announcements, and other information released by the public companies whose shares you hold, helping you stay informed about the companies’ developments. You may also view the original text of relevant announcements on the platform at any time.
• Assistance with Shareholder Litigation: If the public company whose shares you hold engages in illegal or non‑compliant conduct that harms shareholder rights, we may, at your request, provide you with necessary materials such as proof of shareholding and transaction records to assist you in exercising your rights as a shareholder.

• Information Confidentiality Obligation: We will keep strictly confidential your sensitive shareholder information, including your shareholding details and voting intentions. We will not disclose your shareholding or voting intentions to any third party unless required by law or necessary for the public company or clearing institution to perform their duties.
• Service Fee Description: Basic shareholder services such as exercising voting rights and receiving dividends are provided to you free of separate charge. If optional value‑added shareholder services are added in the future, we will separately specify the fee schedule and collect fees only after obtaining your explicit consent.
• Limitation of Liability: We only provide technical support for the exercise of shareholder rights. The content of proposals, business decisions, and the truthfulness of disclosures made by public companies are the sole responsibility of those companies. We do not guarantee the conduct of any public company and assume no responsibility for the results of your exercise of shareholder rights.
• U.S. Equity Compliance Record Retention: We will retain records relating to shareholder services for at least six years as required by the SEC, and will accept SEC regulatory inspections to ensure that the entire process of shareholder services is traceable.