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Leveraged Foreign Exchange Trading Service Privacy Policy

Lianlian StarFX Company Limited, together with its affiliates ("We" or " StarFX ") values your privacy. When you use our products and/or services, we may collect and use your information. To avoid ambiguity, the information you provide relating to other entities or individuals will also be deemed as your information. Through this Privacy Policy, we aim to explain to you how we collect, use, stores, share, and transfer such information when you use our products and/or services, and the ways we provide for the management and protection of such information. To avoid ambiguity, if you are an enterprise user, "you" as used in this Privacy Policy may include your legal representative, directors, and employees. This Privacy Policy has the same legal effect as the Leveraged Foreign Exchange Client Agreement.

It is important that the personal information we hold about you is always accurate and up-to-date. If you do not update or correct personal information, we may not be able to provide you with access to our platform and/or the services that we provide. Please let us know as soon as possible if personal information changes during your business relationship with us.

This Privacy Policy primarily describes:

I. What Personal Information We Collect

II. How We Collect Personal Information

III. How We Use Your Personal Information

IV. How We Process, Transmit, Provide, and Disclose Your Personal Information

V. How We Protect and Store Your Personal Information

VI. How You Manage Your Personal Information

VII. How Your Personal Information is Transferred Globally

VIII. How This Privacy Policy is Updated

IX. How to Contact Us

X. Dispute Resolution and Governing Law

This Privacy Policy is closely linked with the Leveraged Foreign Exchange Trading Service (“Service”) we provide; we expect that you carefully read and confirm that you have fully understood the contents of this Privacy Policy before using our products and/or services.

Your use or continued use of our products and/or services after we update this Privacy Policy means that you agree to the content of this Privacy Policy （including the updated version） and agree that we collect, use, save and share your information in accordance with this Privacy Policy.

I. What Personal Information We Collect

Personal information means any information that identifies you （whether directly or indirectly）, such as:

1) personal, including but not limited to: name, contact details, address, date of birth, identity card, passport details, and/or education details;

2) specimen signature(s);

3) financial details, including but not limited to: income, expenses, and/or credit history;

4) images and biometrics, including but not limited to: your thumbprints, voice and video recordings of you;

5) employment details, including but not limited to: occupation, directorships and other positions held, employment history, salary, and/or benefits;

6) tax and insurance information;

7) information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;

8) banking information, including but not limited to: account numbers and banking transactions;

9) information relating to your activities, habits, preferences and interests arising from your use of our products and services;

10) and/or other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their delivery to you.

Personal information can be collected from various sources and processed by us.

II. How We Collect Personal Information

We need to collect and use your Personal Information to provide you with our services, improve the quality of our services, ensure the security of your account and funds, and comply with applicable laws, regulations and regulatory provisions.

(a) We will collect your Personal Information for the following purposes:

1) Upon registration for and use of our Service, we are required to verify your identity and qualifications in compliance with applicable laws, regulations, regulatory provisions, as well as our internal compliance and risk control requirements, in order to provide facilities, products, or services (whether offered directly by us or through our platform). This includes, but is not limited to, executing investment, commercial, or other transactions and instructions, along with related processing, settlement, clearing, or reporting activities. Accordingly, you are required to provide the identity information specified in Section I.

2) In order to solve the problems, you encounter in the process of using our Services, we need to verify your identity before we begin to solve the problems for you. Therefore, you may be required to provide us with a photocopy of identity documents and a photograph of hand-held ID.

3) In order to ensure the security and stability of the services provided to you, and comply with applicable laws, regulations and regulatory provisions and our own compliance and risk control requirements, we need to collect information of the computer or device or applications you are using when you access our Services, such as your IP address and device identification (including brand, model, name, MAC address, identification code, identifiers of the device and environment and app information of other devices), your browser version information and geolocation information. If you don’t agree to our collection of the aforementioned information, it may affect your continued use of our services.

4) In order to provide you with better customer service, we will collect records of your use of our Service, your contact with us, including monitoring and recording of our telephone communication with you, your responses to questionnaires, your interactions with us (to the extent permitted by applicable law), and other information collected from other accounts that we have reason to believe under your control, whether in whole or in part. If you don’t agree to provide the aforementioned information, it will not affect our continued provision of services to you.

5) In order to send marketing-related notice to you, we may collect your comments and feedback of our services to form a characteristic label, and otherwise with your authorization and consent, send you text message or email notifications of marketing campaigns via your mobile number and/or email address. If you don’t agree to our collection and use of the aforementioned information, please contact us via the methods specified in Section X to request us not to send such notifications. At the same time, you can also choose to unsubscribe from such marketing notifications through the prompts on our short message of marketing or email notification; If you do not agree to the collection and use of the aforementioned information, it will not affect our continued provision of our service.

6) We will not collect or store track information or chip information, verification code, expiration date, password of your bank card.

(b) Exceptions:

In accordance with applicable laws, regulations and regulatory requirements, your consent is not required under the following circumstances:

1) Where it is necessary for the conclusion or performance of a contract to which the individual is a contracting party, or where it is necessary for carrying out human resources management under an employment policy legally established or a collective contract legally concluded;

2) Where it is necessary for performing a statutory responsibility or statutory obligation;

3) Where it is necessary for responding to a public health emergency, or for protecting the life, health or property safety of the natural person in the case of an emergency;

4) Where the personal information is processed within a reasonable scope to carry out any news reporting, supervision by public opinions or any other activity for public interest purposes;

5) Where the personal information, which has already been disclosed by the individual or otherwise legally disclosed, is processed within a reasonable scope and in accordance with applicable laws and regulations;

6) Any other circumstance as provided by law or administrative regulations.

(c) If you need to provide personal information in relation to other entities or individuals:

1) You shall obtain and maintain all rights and licenses for the materials, data and information that you use, provide to us or otherwise deals with in relation to our service;

2) You hereby confirm that every entity or individual whose information has been (or will be) provided to us has (or will at the relevant time have) been notified of and consented to the using, processing and disclosing of their information (including personal data for the individual) in accordance with this Privacy Policy and for the purposes as shown in this Privacy Policy;

3) You shall obtain the necessary consents from such entities or individuals for such personal data to enable StarFX (and each of the recipients) to validly and legally process or use any personal data.

4) If the personal information of other entities or individuals updates or changes, you shall promptly inform StarFX of the most recent information.

Ⅲ. How We Use Your Personal Information

In order to comply with applicable laws, regulations and regulatory requirements, as well as to provide you with services and improve the quality of services, or to protect your account and funds, we will use your information under the following circumstances:

(a) To fulfill the purposes described in “How We Collect Information” in this Privacy Policy;

(b) In order to ensure the stability and security of the service, protect your account and funds, and fulfill legal obligations such as anti-money laundering rules and other regulatory obligations, we will use your information for a variety of ways including identity

authentication, safety precautions, fraud/theft/suspicious transaction detection, prevention and prohibition of illegal activities, isolation or risk reduction, document record and preservation;

(c) Report to relevant authorities in accordance with applicable laws, regulations or regulatory requirements;

(d) To invite you to participate in customer and product research related to our services;

(e) We will use desensitization, de-identification and other methods to carry out comprehensive statistics, analysis and processing of your information in order to provide you with more accurate, personalized, smooth and convenient services, or to help us evaluate, improve or design services and operational activities.

IV. How We Process, Transmit, Provide, and Disclose Your Personal Information

(a) We will keep your Personal Information strictly confidential according to the provisions of this Privacy Policy.

1) Unless otherwise required by applicable laws, regulations and regulatory authorities, we will only share your information with third parties under the following circumstances:

● After your explicit consent or authorization in advance, we will share your information with our cooperative partners to the extent permitted by applicable laws and regulations within the scope of your authorization;

● Where necessary in accordance with applicable laws, regulations, legal procedures, mandatory administrative or judicial requirements;

● It is necessary to protect us, our affiliates or our cooperative third parties, you or other StarFX users or the public interest, property or safety from damage within the scope permitted by laws and regulations;

● Some services may be provided by or jointly provided by us and the third parties we cooperate with, so only by sharing your information can we achieve the core purposes of our services;

● If you opt to participate in the marketing and promotion activities jointly carried out by us and our cooperative partners, we may share the information generated in the course of the activity and necessary to complete the activity, so that the third party can provide you with services, rights or benefits in time. Besides, we will make specific further notices on the relevant activity rules page or in other ways according to the requirements of laws and regulations;

● To deal with your disputes or controversies with others at your request;

● To share information according to agreements or other legal documents you signed with us;

● To share information for academic research;

● To share information for public interest purposes.

2) In accordance with the foregoing provisions of this article, we may share your personal information with our affiliates. However, we will only share necessary personal information and are bound by the items specified in this Privacy Policy.

3) In terms of entities and individuals with whom we share personal information, we will assess the legality, legitimacy and necessity of such third parties collecting such information, require such parties to strictly observe applicable laws, regulations and regulatory requirements by signing agreements with them, and take necessary measures to protect your personal information.

4) Please note: If you transact directly on a third-party website or through a third-party application, any information you enter on that website or application will be shared with the owner of the third-party website or application. Since the website or application party may have its own privacy policy, you are advised to look over their privacy policy before providing personal information for them. We are not responsible for the content or information standardization of such third parties.

(b) We may entrust our affiliates or other professional institutions to process information on our behalf. We will sign a written agreement with such parties, requiring the entrusted party to comply with confidentiality obligations strictly and take effective protection measures, and supervise the entrusted party's personal information processing and prohibit it from using the information for purposes without your authorization.

(c) We will not transfer your personal information to any entity or individual, except for the following:

1) Obtain your explicit written consent or authorization in advance;

2) Where necessary in accordance with applicable laws, regulations, legal procedures, mandatory administrative or judicial requirements;

3) To share information according to agreements or other legal documents you signed with us;

4) In the event of a merger, acquisition, asset transfer or similar transaction, we will require the receiving party to be bound by this Privacy Policy, or we will require such receiving party to obtain your explicit written consent or authorization.

(d) We will only disclose your personal information under the following circumstances and on the premise of taking security protection measures that meet the industry standards:

1) Disclose the personal information you have specified in the manner of disclosure you expressly agree to in accordance with your needs;

2) If it is necessary to provide your personal information in accordance with the requirements of applicable laws and regulations, mandatory administrative law enforcement or judicial requirements, we may disclose your personal information as required by legal documents, such as subpoenas or investigation letters. Public disclosure requests shall be carefully reviewed to ensure that they have a lawful basis and are limited to specific investigative purposes. To the extent permitted by applicable laws and regulations, the documents we disclose are protected by encryption keys.

(e) We may share, transfer and disclose your personal information without your consent under the following circumstances:

1) If it is related to the performance of obligations stipulated by laws, regulations and regulatory authorities;

2) If it is directly related to state security or national defense of the HK;

3) If it is directly related to public security, public health or important to public interests;

4) If it is directly related to criminal investigation, prosecution, trial and enforcement of sentences;

5) For the purpose of safeguarding your or other individuals’ significant legitimate rights and interests such as life and property but where it is difficult to obtain your own consent;

6) Personal information that you disclose to the public at your own discretion;

7) Personal information collected from legally publicly disclosed information.

V. How We Protect and Store Your Information

(a) We (including our affiliates) have taken reasonable safety protection measures in conformity with standard of the industry to prevent unauthorized access, disclosure, use, modification, damage or loss of your personal information. For example, the exchange of data (such as bank card information) between your browser and the server is protected by SSL (Secure Socket Layer) protocol encryption; We will use encryption technology to improve the security of personal information; We will use trusted protection mechanisms to prevent malicious attacks on personal information; We will deploy access control mechanisms to ensure that only authorized personnel can access personal information; And we will hold security and privacy protection training courses to enhance our employees’ awareness of the importance of protecting personal information.

(b) We have an industry-advanced data security management system centered on data life cycle, which improves the security of the entire system from multiple dimensions such as organization construction, system design, personnel management and product technology. At present, we (including our affiliates) have obtained PCI DSS (v3.2) international data security standards, UnionPay network access and security assessment certification, ISO27001 information security management system certification, graded protection level 3 certification and other relevant certifications.

(c) We will take reasonable and feasible measures to try our best to avoid collecting unnecessary personal information. We will only retain your personal information for the purposes described in this Privacy Policy and for the minimum period required by applicable laws, regulations and regulatory requirements, unless an extended retention period is required or permitted by applicable laws and regulations. We will strictly implement the principle of minimum and necessary data storage period, and if the relevant data no longer has the necessary storage and use and legal restrictions, we will promptly take measures such as data deletion or anonymization.

(d) The Internet is not a completely secure environment, and we strongly recommend that you do not send personal information using methods not recommended by StarFX.

When using our services for online transactions, you will inevitably disclose your personal information, such as contact information or contact address, to counterparties or potential counterparties. Please properly protect your login information of your accounts and other personal information, and only provide them for others when necessary. If you find that your information has been leaked, please contact our customer service immediately so that we can take measures according to your application. If such information is compromised, you may suffer a loss of privacy.

Please note that the information you voluntarily share or disclose when using our services may involve your or others’ personal information or even sensitive personal information, such as your choice to upload pictures containing personal information when evaluating. Please consider more carefully whether to share or disclose information when using our services.

(e) In the event of an unfortunate personal information security incident, we will inform you in accordance with laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to prevent and reduce risks on your own, remedial measures for you, etc. We will inform you of the relevant circumstances of the incident via email, letter, telephone notification, etc., and when it may be difficult to inform the personal information to you, we will issue an announcement in a reasonable and effective manner. At the same time, we may also report the disposal status of security incidents as required by regulatory authorities.

(f) When you terminate our Services, we will stop collecting and processing your information, unless otherwise required by laws, regulations or regulatory authorities.

Ⅵ. How You Manage Your Personal Information

(a) Access, copy, correct or complete your information.

If you have registered an account on our platform or other platforms we provide (if applicable), you can log in to your account to access and copy your identity information (such as email address, contact number, login password, etc.) in the " Settings" column.

If your information is incorrect or incomplete, you can modify it (such as contact number, login password, etc.) according to the page prompts in the "Settings" column, or request us to correct or complete it by contacting us via the methods specified in Section X. The specific method for updating information will be determined based on the support provided at that time. However, for security and identity recognition purposes or mandatory provisions of laws and regulations, you may not be able to modify some of the initial registration information provided at the time of registration.

(b) Delete your information. You may request us to delete the personal information you have provided under the following circumstances:

1) Where the purpose of processing has been achieved or is unable to be achieved, or the personal information is no longer necessary for achieving the purpose of processing;

2) Where the StarFX ceases the provision of the product or service involved, or the retention period has expired;

3) Where consent is withdrawn by you;

4) Where the processing of personal information by the StarFX is in violation of any law, administrative regulations or agreement;

5) Any other circumstance as provided by law or administrative regulations.

We will also notify recipients who can access your personal information from us as much as possible and require them to delete it in time (unless otherwise provided by laws and regulations, or these recipients have independently obtained your authorization).

You can contact us via the methods specified in Section X to request us to delete the relevant personal information. We may not be able to immediately delete the personal information from the backup system, we will cease the processing of the personal information, except for the storage and any necessary measure taken for security protection until the backup version can be erased or anonymized.

(c) Change/withdraw your consent.

If you need to change or withdraw your consent, you can contact us via the methods specified in Section X. A withdrawal of consent by you shall not affect the validity of any activity of processing of your personal information already carried out before the withdrawal based on your consent.

(d) Respond to your requests.

If you make a claim to exercise your rights based on applicable personal information protection laws, or if you believe that we have violated any laws and regulations or agreements with you on the process of your personal information, you can contact us via the methods specified in Section X. For security purposes, you may be required to provide a written request or otherwise prove your identity. We might ask you to verify your identity before handling your request. We will reply within fifteen working days. For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. We may deny requests that are unreasonably repetitive, technically difficult, bring risks to the legitimate rights and interests of others, or are very unrealistic.

We will not be able to respond to your request under the following circumstances:

1) If it is directly related to the national defense security and security of the HK and other relevant countries, regions and fields;

2) If it is directly related to public security, public health or important to public interests;

3) If it is directly related to criminal investigation, prosecution, trial and enforcement of sentences;

4) If there is sufficient evidence indicating that you have subjective malice or abuse your rights;

5) If responding to your request will cause significant damage to the legitimate rights and interests of you or other parties;

6) If the request involves any trade secret, it is forbidden.

(e) Cancel your Account.

You may cancel your account via the methods specified in Section X or contacting your service manager. After the termination of your account, the information in your account will be cleared and you will not be able to access any Services. We will no longer process personal information of such account, but the information will still be stored (1) as required by applicable laws and regulations, and we shall assist and cooperate with the performance of their duties in accordance with the law by competent authorities during the retention period; or (2) under your specific consent.

VII. How This Privacy Policy is Updated

We may update this Privacy Policy at any time and post it onto our official website at lianlianstar.com. For material changes, we will also provide more prominent notice. The material changes referred to in this Privacy Policy include, but are not limited to:

1) Material changes in the purpose, scope and rules for processing your personal information;

2) Material changes in our ownership and structure, such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;

3) Material changes in the receiving party of sharing, transfer or disclosure of personal information;

4) Material changes in the way and procedure for you to exercise your personal information rights;

5) Changes in our contact information;

6) The risk level of Personal Information Protection Impact Assessment Report is high.

IX. How to Contact Us

(a) If you would like to make any inquiries, complaints, access or correction requests or request for us to limit the processing of your personal information, please contact us at:

Privacy team

Contact Number: +852 2881 8498

Email: cs@lianlianstar.com

(b) In general, we will reply within fifteen working days. If you are not satisfied with our response, especially if our personal information processing behavior harms your legitimate rights and interests, you can also complain or report to regulatory authorities.

X. Dispute Resolution and Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of Hong Kong. Any dispute, controversy, difference or indemnity arising out of or in connection with this Privacy Policy, including the existence, validity, interpretation or settlement of this Privacy Policy, shall be governed by and construed in accordance with the laws of Hong Kong. Any dispute arising out of or relating to the interpretation, performance, breach or termination of this Agreement shall be submitted to arbitration by the Hong Kong International Arbitration Centre (“HKIAC”) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The seat of arbitration shall be Hong Kong, the number of arbitrators shall be one (1). The arbitration proceedings shall be conducted in the English language.