Privacy Policy

1. Information Collection

We may collect the following information when you use our website or related services:

• Personally identifiable information (e.g., name, email, phone number, identity details);
• Project or business-related data (e.g., brand profile, business model, on-chain asset details);
• Technical and usage data (e.g., IP address, browser type, OS, device ID, browsing behavior);
• Non-direct identifiers via cookies and blockchain wallet addresses.

2. Use of Information

We use your information primarily to:

• Deliver, manage, and improve our products and services;
• Support project deployment and operational assistance;
• Comply with applicable legal and regulatory obligations;
• Notify you of updates or promotional content (with your consent);
• Ensure the security and compliance of the platform, user accounts, and on-chain assets.

3. Information Sharing and Disclosure

We may share your information under the following circumstances:

• With service providers, development partners, custodians, or compliance collaborators;
• To cooperate with legal or regulatory authorities where legally required;
• With your consent, for specific business collaborations or co-marketing;
• As part of a business merger, acquisition, or asset transfer involving XOOER.

4. Information Security

We implement industry-standard security measures, including:

• Data encryption and secure transmission (e.g., HTTPS, wallet signature verification);
• Access control, role-based permissions, and audit trails;
• Firewalls and anti-fraud systems;
• Incident monitoring and response protocols.

While we strive to protect your data, no internet transmission or blockchain system is completely secure.

5. Data Retention

We retain your data for a reasonable period to:

• Deliver services and archive project documentation;
• Comply with regulatory and audit requirements;
• Facilitate reactivation or data migration requests;
• Resolve disputes or enforce this policy and related agreements.

6. User Accounts and Wallet Addresses

When using our platform, you may connect a wallet or create an account. These identifiers are used to:

• Attribute on-chain activities to your identity;
• Authenticate access permissions;
• Distribute rewards, credits, or assets.

We will not access or transfer your wallet assets without your consent.

7. User Rights and Choices

You have the right to:

• Access, correct, or delete your personal data;
• Restrict or withdraw your consent to data usage;
• Opt out of marketing communications and notifications.

To exercise these rights, use your account settings or contact us via email.

8. Data Anonymization and On-chain Traceability

We may use anonymized or aggregated data for analysis or protocol-level interactions. Please note:

• Blockchain addresses and transaction histories are publicly traceable, though not directly tied to identities;
• We recommend safeguarding your keys and wallet address privacy.

9. Third-Party Websites and Services

XOOER.com may contain links to third-party platforms (e.g., DEXs, blockchain explorers, social media). These third parties operate independently and have their own privacy policies. We are not responsible for their data practices. You are encouraged to review their privacy notices before use.

10. Children's Privacy

Our website and services are not intended for children under the age of 13. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us for prompt deletion.

11. Cookies and Similar Technologies

We use cookies and local storage to:

• Remember your login status;
• Provide personalized content;
• Analyze site traffic and user behavior.

You can manage cookies through your browser settings, though doing so may limit certain site functionalities.

12. Analytics and Advertising

We may use third-party analytics (e.g., Google Analytics) and advertising providers to enhance user experience and marketing effectiveness. These services may collect non-personally identifiable data via cookies. To opt out, contact us or adjust your browser settings.

13. Social Media Features

Our site may include social features like “share” or “like” buttons provided by third-party platforms. These providers may collect data governed by their own privacy policies. We recommend reviewing these policies for further understanding.

14. International Transfers of Personal Data

To support on-chain asset deployment and cross-border operations, your data may be transferred outside your country. We ensure:

• Adequate levels of data protection by recipients;
• Data protection agreements with third parties;
• Compliance with applicable regulations such as GDPR and PIPL.

15. Data Subject Rights (EEA / GDPR)

If you are a resident of the European Economic Area (EEA) or subject to the GDPR, you have the right to:

• Access the personal data we hold about you;
• Rectify or delete inaccurate data;
• Withdraw consent or restrict processing;
• Request data portability;
• Lodge a complaint with a data protection authority.

16. California Privacy Rights (CCPA)

If you are a California resident, you have the following rights under the CCPA:

• Know what categories of personal information we collect and use;
• Request deletion of your personal information;
• Opt out of the sale of your personal information (we do not sell your data);
• Not be discriminated against for exercising your privacy rights.

17. Nevada Privacy Rights

If you are a Nevada resident, you may request that we not sell your personal information to third parties (even though we currently do not). You may make such requests via [email protected].

18. Do Not Track Signals

Our website currently does not respond to “Do Not Track” signals from browsers. However, we respect user preferences as expressed through privacy settings.

19. Contact Us

For any questions, requests, or complaints related to this Privacy Policy, please contact us at:

• Email: [email protected]
• Mailing address: Unit 1051, Building 19W, No.19 Science Park West Avenue, Hong Kong Science Park, Pak Shek Kok, N.T., Hong Kong

20. Effective Date and Updates

This Privacy Policy is effective as of June 1, 2025. We may update it from time to time and will notify you of significant changes via website notice or email. We encourage you to review this page periodically for the latest version.