VeChainThor Wallet  User Service Agreement


Dear User:

Thank you for choosing the VeChainThor Wallet (hereinafter referred to as the ‘Wallet’). In order to receive a better service from the Wallet, please read VeChainThor Wallet User Service Agreement (hereinafter referred to as this ‘Agreement’) in details. This Agreement is signed by and between VeChain Technology SEA PTE.LTD (hereinafter referred to as the ‘Company’) and the User. Both parties are bound by this Agreement. In this Agreement, ‘we’ and ‘us’ refer to the Company and ‘you’ refers to the User. Each of you and the Company shall hereinafter be referred to as a ‘Party’, and collectively, you and the Company shall hereinafter be referred to as the ‘Parties’.

Please be sure to read carefully and fully understand the contents of this Agreement, especially the terms of exemption or limitation of liability, governing law and dispute resolution. The terms of exemption or limitation of liability will be marked in bold and underlined, which you should fully understand and evaluate the risks of using the Wallet.

When you fill in the information, read and agree to this Agreement and complete the creation or import of wallet according to the information notice of the Wallet, it means that you have read, understood, accepted and abided by this Agreement and reached an agreement with us as the User of the Wallet. In the course of reading this Agreement, if you do not agree to this Agreement or any of its terms, you should immediately stop the registration or use the Wallet and related services. If you use the Wallet and related services, you are deemed to have fully understanding of this Agreement and promised to be bound by this Agreement as a party.



  1. You understand that this Agreement and relevant agreements apply to the Wallet and other decentralized applications on the Wallet which are developed and owned independently by the Company.
  2. The contents of this Agreement also include relevant agreements and rules relating to the application and related services of the Wallet that have been released and may be continuously released or updated. The aforesaid agreements and rules will become an integral part of this Agreement and they automatically become effective once they has been posted on the Walletwhich you should abide by them. If you do not accept the relevant agreements and rules for subsequent announcements or updates, please stop using the Wallet immediately. Your continuous use of the Wallet after any modification to this Agreement will be deemed as acceptance of this Agreement as modified.



  1.      VeChainThor Wallet: means the blockchain wallet developed by the Company based on the VeChainThor Blockchain system (and other blockchain systems that will be supported in the future), including other supporting tools developed to facilitate the use of blockchain systems by the User.
  2.      VeChainThor Blockchain: means the blockchain public chain platform designed and developed by VeChain Foundation Limited (‘Foundation’ or ‘VeChain Foundation’) to support large-scale enterprise applications. It has a comprehensive economic model, advanced technology concepts and a strong governance structure to ensure the commercialization of blockchain technology and to provide enterprises and individuals a simple and secure blockchain solution.
  3.      Digital Token: means types of digital tokens are now supported by the Wallet, including but not limited to VET and VTHO that developed by VeChain Foundation, and other digital tokens, located on the VeChain Blockchain, developed by third-party enterprises, such as OCE, PLA, TIC, SHA, DBET, etc. You should understand that We DO DOT make any guarantee or commitment to the economic value of above mentioned digital tokens.
  4.      User: means any natural person who accepts and agrees to all the terms and conditions of this Agreement and the related agreements and rules published or updated from time to time, and who registers and uses the Wallet and related services. You confirm that, before you begin the registration process and use the Wallet and related services, you must be 21 years of age (or more, depending on the legal age of majority in your jurisdiction) and should have the corresponding capacity required by the laws of the jurisdiction you are located at to your civil conduct. If you do not have the aforesaid civil capacity, you and your guardian should bear all the resulting consequences according to the law, and we have the right to seek compensation from you and your guardian.
  5.      Create or Import Walletmeans the creation or import of wallet in the Wallet after your acceptance of this Agreement.
  6.      Wallet Passwordmeans the password you fill in during the creation of the wallet in the Wallet. The Wallet Password will be used to encrypt and protect your Private Key. As a decentralized application (‘DApp’), the Wallet Password will not be stored on our server. If you lose or forget your Wallet Password, you need to use Mnemonic Words or Keystore to reset your Wallet Password.
  7.      Information Notice: means the messages displayed on the Wallet’s operation interface. We strongly suggest you following the Information Notice to operate the application.
  8.      Private Keyconsists of 256 random bits, which is the core of digital tokens the User owning and using.
  9.      Public Key: It is generated by the Private Key through unidirectional deduction based on cryptographic principles, and is used to generate a blockchain digital wallet address, which is a public address for receipt of VET, VTHO, etc.
  10. Mnemonic Words: It complies with the blockchain BIP39 industry standard and consists of 12 ordered words generated by a random algorithm. It is human readable format of Private Key, which is convenient for the User to backup and store.
  11. Keystore: means Private Key or Mnemonic Words in the format of a file which is encrypted and protected by the User’s Wallet Password. Keystore is stored only in your mobile device and will not be synchronized to our servers.
  12. Hot Wallet: means a wallet connected to the internet with storing a private key, which may make it easy for the User to transfer, collect tokens and check the transaction records, etc.
  13. Cold Wallet: means an offline wallet with storing a private key, which may make it easy for the User to manage their large amount of assets.
  14. Observation Wallet: means a wallet connected to the internet without storing a private key, which is designed to be used for assisting the Cold Wallet in managing virtual currency assets conveniently, flexibly and securely. The Observation Wallet can perform the following operations on the corresponding Cold Wallet: check wallet balance, transaction information, X-Node binding, VET swap, and collect VTHO rewards. For details on the authorization by Cold Wallet to the Observation Wallet, please refer to Authorized Observation Wallet Operation Guide.
  15. Smart Contract: means the VeChainThor-Blockchain-based program applied by the Wallet, which rules any trading behavior between the User of the Wallet, and clarifies the rights and obligations of both you and other Users in the relevant transaction. Once a certain event triggers a clause in a smart contract, code will be automatically executed.
  16. Collection: means the VIP181-compliant collection currently supported by the Wallet, including but not limited to VeChainThor Node, which are unique and non-interchangeable.
  17. Personal Information: means information recorded in electronic or any other form which may identify the User or reflect the User’s activity when used alone or in combination with other information, including but not limited to natural person’s name, date of birth, identification card number, personal biological identification information, living address, contact information, wallet address, mobile device information, mobile device operating system version information, IP address, operation and transaction records, etc. 
  18. Transaction: means the User’s conduct to transfer, receive tokens, collection directional sale, instant transfer and auction on the open market and other operations in the Wallet. The Wallet is only a tool for the Users to manage their digital tokens and does not provide any service of the exchange and trading platforms.



  1.      Create or Import wallets. For the digital tokens supported by the Wallet, you can use the Wallet to create a new wallet or import a compatible wallet generated by other wallet application of the relevant blockchain system.
  2.      Transfer and Receive Tokens. You can use the transfer and receipt functions of the Wallet to manage your digital tokens, that is, using the Private Key for electronically signature and modifying the VechianThor Blockchain's ledger. Transfer of tokens refers to that the payer uses the blockchain address of Payee to perform the transfer operation. The actual transfer and receipt activities occur on the distributed ledger of the VeChainThor Blockchain (rather than on the Wallet).
  3.      Collection Transaction. You can use the Wallet to conduct your collections’ directional sale, node instant transfer, price-fixed auction, price-reduced auction, purchase on the open market, etc. The actual directional sale, node instant transfer, auction and purchase you have made happen on the VeChainThor Blockchain, other than the Wallet.
  4.      Browse DApp. The User can jump to DApp and use the services provided by the DApp (including the Company’s DApps and third-party-developed DApps) through the link showed on the Wallet.
  5.      Transaction Record. The VeChainThor Blockchain system will copy all or part of your transaction records. You should refer to the VeChainThor Blockchain system for the latest transaction records.
  6.      Suspension of Service. You understand that we cannot suspend or cancel transaction because transactions based on blockchain technologies are irrevocable.
  7.      Other services that the Company consider necessary.



  1.      You should abide by laws, regulations, regulatory documents and policy requirements to ensure the legality of sources of digital tokens in your wallet. You are forbidden to use the Wallet to engage in illegal activities or other activities that will damage the rights of the Company or any third party, such as sending any information that violates laws, regulations, public orderliness and rights of others, distributing pyramid schemes or message and speech causing bad influence to the Company and using or forging E-mail title without the Company’s permission.
  2.      You should understand we provide decentralized services that are different from banking financial institutions. You should abide by laws and regulations to properly use the Wallet and bear sole responsibility to take care of your own mobile device, memorize and back up your Mnemonic Words, Wallet Password, Private Key and Keystore. If you lose your mobile device, delete the Wallet, or your Wallet was stolen before you write down or backup your Wallet Password, Private Key, Mnemonic Words and Keystore, we are not able to help you restore the wallet or retrieve your Wallet Password, Private Key, Mnemonic Words and Keystore.
  3.      You should take full responsibility for any operations and consequences of using Wallet. For example, the Company cannot be able to cancel the transaction for your mishandling (such as typing in wrong wallet address or wrong transaction amounts). You shall be responsible for all risks, liabilities, losses, and costs arising from your loss of mobile devices, you actively or passively disclosing or forgetting of your Wallet Passwords, Private Keys, Mnemonic Words, Keystore, or any fraud and hacking attack.
  4.      You should understand that due to the decentralization feature of the blockchain, we do not provide the following services:

1        Store your Wallet Password (the password you set when you create/import a wallet), Private Key, Mnemonic Words and Keystore;

2        Recover your Wallet Password, Private Key, Mnemonic Words and Keystore;

3        Freeze, restore or report the loss of your wallet;

4        Rollback transaction.

  1.      You should understand that the Wallet does not support all existing digital tokens, so you can only use our service to handle digital tokens that we support. You should bear all losses if you use the Wallet to handle any non-supported digital tokens.
  2.      You should understand that the Wallet is a tool for the User to manage his tokens and is not an exchange or trading platform. Although this Agreement refers to ‘transactions’ several times, it generally means that the User uses the Wallet to transfer and receive digital tokens, directionally sale, node instant transfer and auction collections, and other operating functions may be applied on the Wallet for future, which is substantially different from the ‘transactions’ on the exchange and trading platforms.



SECTION I. Create or Import Wallet

  1.      Create or Import Wallet: You may use the Wallet on your mobile device to create and/or import wallet, set your Wallet Password, use your wallet to transfer and receive digital tokens on the VeChainThor Blockchain.
  2.      True Information: You are responsible for the authenticity, validity and security of your personal information, including but not limited to your name, ID number, mobile phone number, credit card number, etc.
  3.      We may develop different versions of the Wallet for different terminal devices. You should obtain, download, and install the applicable version. If you obtain the application or other application with the same name as the Wallet from any unauthorized third party, we cannot guarantee the normal operation of the application or security of such application. All losses are fully borne by the User.
  4.      In order to enhance the User’s experience and our service, the Wallet will update or modify the application occasionally (including but not limited to application modifications, upgrade, function enhancement, new service development of and application replacement, etc.). After the application is updated, we will notify the User by Information Notice, announcements, and private messages. A previous version of the Wallet may stop to operate after a new version is released, please check and download the latest version at any time.



  1. You should take the sole responsibility to keep your mobile device, Wallet Password, Private Key, Mnemonic Words, Keystore, etc. by yourself. We are not responsible for keeping the foregoing information.
  2.      Follow the Information Notice. You understand and agree to follow the Information Notice prompted by the Wallet. Otherwise, you shall take sole responsibility for all risk, liability, loss and cost which result from your failure to comply with the  Information Notice.
  3.      You acknowledge and understand that the Wallet undertakes no responsibility to conduct due diligence on the services or transactions provided by third-party-developed DApps. You should make rational investment decisions and assume corresponding investment risks.
  4.      Transfer

1     You understand that Blockchain operations are irrevocable. When you use the Wallet to transfer digital tokens or trade collections, you shall be responsible for the consequence of your mishandling (including but not limited to the wrong address or transfer amount inputted by you and the problem of the node server selected by you).

2     You understand that the following situations may result in ‘transaction failure’ or ‘mining overtime’ when using the Wallet:

1)        Insufficient balance in the Wallet;

2)        Insufficient Gas for transaction;

3)        Blockchain’s failure to execute the code of smart contracts;

4)        Technical failure of the network or equipment;

5)        Abandoned transactions result from blockchain network congestion, failure or other reasons;

  1.      Notifications. The relevant notifications shall be released via public media channels of VeChain Foundation, including but not limited to official Twitter account, WeChat official account, Weibo, etc.
  2.      Service Fees and Taxes

1        You need to pay gas fee when you transfer digital tokens through the Wallet, and the amount of which is on your sole discretion. 30% of the gas fee is charged pro rata by the bookkeeping node in the VeChainThor Blockchain, and the remaining part is automatically destroyed;

2        You understand that under certain circumstances, including but not limited to the instability of relevant blockchain network, your transfer operation may fail, but you may still be charged gas fee by certain blockchain system.



  1.     You understand and acknowledge that digital tokens are not the official currency of any country. The digital token market is brand new, unconfirmed, and may not grow. At present, digital currency is relatively rarely used in retail and commercial markets, and is mainly used by investors. The digital token market has no restrictions on price fluctuations. Therefore, the price fluctuation of digital tokens is much greater than that of other financial assets. To participate in digital tokens investment, we recommend you to rationally choose to hold or dispose of any type of digital tokens based on your financial situation and risk appetite.
  2.     In the course of trading, you should take sole responsibility to make sure that your counterparty is a person with full capacity for civil acts and decide whether to transact with your counterparty, and you should bear all risks arising out from the transaction.
  3.     You shall check the official channels of relevant blockchain system or other blockchain query tools when you receive an Information Notice, during the process of transaction, such as ‘transaction failure’, ‘mining overtime’, ‘Node abnormal’ or ‘failure to obtain Node information’, in order to avoid repetitive transfer. If you fail to follow this instruction, you shall bear the losses and expenses occurred due to such repetitive transfer.
  4.     You understand that when you create or import a wallet in the wallet, your Keystore, Private Key, Mnemonic Words and other information are only stored on the current mobile device rather than stored in the Wallet or on our server. You may change another mobile device to use the Wallet after you follow the instruction in the Wallet to back up your wallet.
  5.     We suggest that you back up your Wallet Password, Private Key, Mnemonic Words and Keystore in a secure way when you create or import wallet. We draw your attention, please do not use the following electronic methods such as screenshots, e-mail, note-taking apps, text messages, WeChat, QQ or other electronic backup methods to back up any of the above information. We recommend you back up the above information such as Mnemonic Words and Keystore by writing them down on paper and you can also save electronic data to the password manager.
  6.     We suggest that you use the Wallet in a secured network environment to ensure that your mobile device is not actively or passively jailbroken or rooted to avoid potential security risks.
  7.     Please be alert to frauds when you use the Wallet. If you notice any suspicious activity, we encourage you to inform us by submitting your feedback in the Wallet at the first time.



  1.      You understand and accept that our Wallet application and related services are provided in accordance with our current state of technology and conditions. The following reasons may result in temporary suspension of services:

1   Technical reasons such as maintenance, upgrading, failure of equipment and the VechainThor Blockchain system;

2   Force majeure events including but not limited to earthquake, tsunami, flood, power outrage, war or terrorist attack;

3   Viruses, Trojan horse, malicious program attacks, network congestion, system instability or equipment failure, communications failure, power failure, bank reasons, third-party service defects, or government behaviors;

4   Material unfavorable change of applicable laws or policies;

5   Other circumstances which the Company cannot control or reasonably predict.



It means that you trust our way to process your information when you accept to use our service.  We understand that this is a big responsibility and we work hard to protect your information and put you in control.

VeChainThor Wallet Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information. We suggest that you carefully read and understand all content of VeChainThor Wallet Privacy Policy before using the Wallet


  1.      You understand and agree that we expressly disclaim any form of guarantee for the following circumstances, and the User shall bear all risks and responsibilities:

(1)          We do not guarantee the orderliness, stability and long-term survival of the digital token market. You should be cautious in the trading of digital tokens (and any other assets) and fully understand all the actual or potential risks that may exist in each digital token and its issuing company. All losses caused by the real-time fluctuations of price of digital tokens, and the suspension, prohibition or any other restriction of digital token transactions due to the formulation or revision of relevant national laws, regulations and regulatory documents, shall be borne by the User.

(2)          Unless expressly agreed by us in writing, we will not guarantee the authenticity, accuracy, completeness, reliability, validity, timeliness and legality of any content, information and data obtained by the User from the Wallet in any way, including but not limited to the User’s physical or non-physical asset information, physical or non-physical assets transfer request information, project promotion information, advertisement information, etc. We shall not bear any responsibility for any transaction or acquisition of any product or service (including but not limited to the transfer of physical or non-physical assets) made by the User based on such content, information or data in the Wallet. The User shall bear all risks and losses caused by the use of the content, information and data in the Wallet.

(3)          As a third-party blockchain network service platform, the Wallet does not guarantee that the information and services on the Wallet platform can fully meet the needs of the User. We do not bear any legal responsibility for incidents such as fraud or deceit that may be encountered by the User when accepting services of the Wallet.

(4)          Based on the particularity of the blockchain and digital tokens, although we do our best to improve the quality of service of the product, we do not guarantee that the Wallet service will not be interrupted.  We do not guarantee the timeliness and security of the Wallet services, including but not limited to whether the transaction information can be transmitted accurately, timely and smoothly.

(5)          We do not guarantee any physical or non-physical asset trading services or trading processes acquired by the User in the Wallet. You understand and acknowledge that the operations on the blockchain are ‘irreversible’ and that related transactions are also ‘irreversible’. You and your counterparties of the transaction shall bear the corresponding risks and losses. If you or your counterparties of the transaction does not comply with this Agreement or any other rules, instructions, operation instructions in the Wallet, we reserve the right to refuse to provide services to you and your counterparties. And we are exempt from any legal liability including damages.

  1.      The Company only take the responsibility for the obligations stipulated in this Agreement.
  2.      You understand and agree that the Company should not be held liable for the failure of providing services under the circumstances regulated in Clause VII.1 of this Agreement. Despite the previous clause, the Company will take reasonable actions to promote services back to normal.
  3.      You shall understand and agree that we should not be held liable for any of the following circumstances:

1   Loss of digital tokens due to loss of mobile devices, deletion of the Wallet without back-up, or loss of wallet by theft, or oblivion of Wallet Passwords, Private Key, Mnemonic Words and Keystore by the User;

2   Loss of digital tokens due to the User’s disclosure of Wallet Password, Private Key, Mnemonic Words, Keystore to others, the User’s borrowing, transfer or authorization of their own mobile device or the Wallet to others, or User’s inappropriate download of the Wallet through unofficial channels, or insecure using means;

3   Loss of digital tokens due to the User’s mishandling (including but not limited to transferring a wrong address, choosing the wrong node servers by the User)

4   Loss of digital tokens due to mishandling by the User who lacks knowledge in relation to blockchain technology;

5   Deviation of the User’s transaction records copied to VeChainThor Blockchain due to time lags, instability of the blockchain system and other reasons.;

6   The risks and consequences of the User' operations on third-party-developed DApps.

  1.      You understand that the Wallet is only a tool used for managing digital tokens and displaying transaction information, and the Company does not provide legal, tax or investment advice which you should seek from professionals in law, taxation, and investment.



The Wallet is an application developed and owned by the Company. The intellectual property rights of any contents displayed in the Wallet (including this Agreement, announcements, articles, videos, audio, pictures, files, information, materials, trademarks or logos) are owned by the Company or third-party licensors. The User should use the Wallet application and its contents only for the purpose of holding and managing digital tokens, and should not copy, modify, transmit or use any of the aforementioned materials or contents for commercial purposes.



  1.      The effectiveness, interpretation, amendment, supplement and dispute resolution of this Agreement shall apply to the laws of the Republic of Singapore and can be referred to commercial practices and/or industrial practices if there are no such relevant provisions under the laws of the Republic of Singapore.
  2.      Any dispute arising out of this Agreement or performance of this Agreement, or in connection with this Agreement, including any problem to its existence, validity or termination, the Parties shall endeavor to settle through friendly communication and negotiation. Where any party is unwilling to settle in good faith, or failure to reach an amicable settlement within 30 days from the first day when such dispute occurred, then either party shall have the right to submit the dispute to the International Chamber of Commerce (‘ICC’) and appoint one or more arbitrators in accordance with the current valid ‘Rules of Conciliation and Arbitration’ to settle. The language for arbitration is English. Unless otherwise as agreed by the parties under this Agreement, the place for arbitration is in the Republic of Singapore and the arbitration award is finally and legally binding to the parties.



  1.      This Agreement includes VeChainThor Wallet User Service Agreement, VeChainThor Wallet Privacy Policy, X Node Binding Service Agreement, VET Token Swap Service Agreement, Node Upgrade, VTHO Rewards Service Agreement, Address Authentication Authorization Service Agreement, Designated Transfer and public Auction of Collectibles Service Agreement and various agreements and rules posted and updated by the Company from time to time.
  2.      All provisions of this Agreement are severable, and if any provision or part thereof of this Agreement is deemed invalid or otherwise unenforceable, the remaining provisions of this Agreement shall remain valid, enforceable and binding.
  3.      Any translated version of this Agreement is only provided for the convenience of the User, and is not intended to modify the Chinese version of this Agreement. If there is any discrepancy between the Chinese version and the non-Chinese version of this Agreement, the Chinese version shall prevail.
  4.      If you come across any problem during the use of the Wallet, you can contact us by submitting feedback on the Wallet.
  5.      The Agreement shall become effective on  April, 3 2019.

For any issues not mentioned in this Agreement, you should comply with the announcements and the relevant rules posed by the Company from time to time. If you have any further questions, advices or suggestions, please contact us through the following way:


We will review issues as soon as possible and respond within thirty days of verifying your identity.




VeChain Technology SEA PTE.LTD


April , 3, 2019





VeChainThor Wallet Privacy Policy (hereinafter referred to as this "Privacy Policy") is only applicable to functions of VeChainThor Wallet (hereinafter referred to as the “wallet”), which is run by VeChain Technology SEA PTE.LTD (hereinafter referred to as "we") (registered address, office address: 7 Straits View, #12-00Marina One East Tower,Singapore,, Company Code: 201626984R), including but not limited to creating wallets, importing wallets, VET transfer services, asset management, receiving VeThor rewards, collectibles transactions, etc.

We attach great importance to the protection of your personal information and fully understand its significance to you as well. We may collect and use your personal information when you use the wallet and our related services, and simultaneously we will spare no effort to protect your personal information. We are highly committed to maintaining your trust in us and to abide by the following principles while protecting your personal information: principle of rights and responsibilities, principle of clear purpose, principle of consistence, principle of minimum use, principle of security, principle of participation, principle of openness and transparency. At the same time, we promise that we will take appropriate security measures to protect your personal information in accordance with the tested and mature standards.

We suggest that you carefully read and understand all content of this Privacy Policy before using the wallet. This Privacy Policy may contain following contents for you:

  1. Information we collect
  2. How we store information
  3. How we use information
  4. External provision of information
  5. How you manage personal information
  6. How we protect information
  7. Disclaimer
  8. Underage protection
  9. How we update this Privacy Policy

Update date: [ * ]

This Privacy Policy comes into effect since publication.

If you have any question, advice or proposal, please contact us by following:



1.   Information we collect

You understand and agree that in order to protect your normal use of our services, when you fill in the information, read and agree to this Privacy Policy and complete the creation or import of a wallet address in according with the information notice, we will collect your personal information strictly abiding by the principles of publicity, legality, properness and necessity.

Please be aware that the address of the wallet you create or import, and all transaction records associated with that address will be stored on VeChainThor Blockchain, and you and we have no control over the disclosure, modification and deletion of your transaction records.

(1)       We will collect and use the information as you provide or is generated by user itself during the use of the services, which comply with the purposes described below:

a)         In order to provide you with the wallet service, we need to collect your following indispensable basic information before such provision, which is necessary to providing you with our service:

i.                Wallet information: When you use our wallet service, we will automatically collect the version information of the wallet you use

ii.                Device information: We will collect information about the device you use during our service, including device ID, mobile device operating system version information, mobile device platform type (iOS or Android), system language, source information (such as Google Play, Xiaomi App store, Baidu App store and Apple App Store), etc.

Information we collect from the same wallet address despite various login devices may be associated by us so that we can provide you with a consistent wallet service on those devices.

b)         In order to improve our service, we will use data analysis software to collect your following behavioral analysis information based on your authorization:

Log information of wallet operation: We will collect details upon how you use the wallet, including but not limited to the frequency and duration of your visit, wallet browsing history, operation history, etc. As to user behavior analysis data collected described as above, data analysis software will randomly generate an anonymous Distinct ID for you. Once you reinstall your wallet or use another device to log in to the same wallet address, a new Distinct ID will be reassigned to you. Collected behavior data will not be shared with any third party.

i.                When you contact us, we may save your contact information to reach you or help you solve the problem, or to record the solution and results of the problem you report.

(2)       After you link any other third-party-developed DApp through the wallet, such DApp may collect your personal information when providing services. If you refuse the third party to collect your personal information during or before the service, it may cause you unable to use such DApp in the wallet. We do not hold any personal information collected by any such third party DApp.

2.   How we store information

We will continue to store and keep personal information collected from you for a necessarily certain time either for data collection or our legal and commercial purposes or the requirements of the relevant laws. Besides, we usually keep your personal information permanently to ensure that any contract disputes can be resolved.

We will store the personal information collected and generated by our customers permanently in the territory of the People’s Republic of China. We will ensure that your personal information will be protected in accordance with this Privacy Policy to meet the equivalent requirements of the laws and regulations of the Republic of Singapore.

Since we provide products or services through resources and servers around the world, that is, upon your authorization, your personal information may be transferred to or receive visit from a foreign jurisdiction as to the country in which you use the product or service. Such jurisdiction may have different data protection laws, or there may be no laws that should be expected to provide adequate protection for your personal information. Under these circumstances, we will ensure that your personal information will be adequately protected in accordance with this Privacy Policy. For cross-border transmission, we will obtain your authorization in advance.

If you are a user of our wallet service from the European Union, the United States, or any other regions outside of the Republic of Singapore that apply laws or regulations that collect, use and disclose personal data in a way different from the laws of the Republic of Singapore, please be aware that not only do you agree that our wallet service shall be governed by the laws of the Republic of Singapore, but also you accept the transfer of your personal information to the territory of the People's Republic of China.

When our products or service cease to operate, we will notify you by notice and delete or anonymize your personal information within a reasonable period.

3.   How we use information

We may use your personal information that we have collected when you use our service for the following purposes:

(1)       To provide basic wallet service to you;

(2)       To improve your experience with the wallet;

(3)       To help us with design of new service and enhance existing one;

(4)       To help us know more about how you use the wallet so that we can satisfy your personalized needs, such as resolving any question, feedback, complaint and requirement you submitted to us by using your wallet’s public address and device information that you provided to us;

(5)       To authenticate application or upgrade the management application;

(6)       Other uses. If we use your personal information for other purposes not mentioned in this Privacy Policy or use your personal information for different purpose other than the ones we tell you, we will always ask for your consent in advance.

You agree that, during your use of the wallet products or our service, we are entitled to generating patterns, trends, knowledge, metadata and other insights (collectively, “Derivative Data”) by (i) anonymizing users’ data; (ii) aggregating users’ data with other data; and/or (iii) based on anonymous learnings, logs and data regarding use of the wallet and/or services.

Derivative Data shall only consist of anonymized data that does not identify the user or any other personally identifiable information. Anonymized data means that any information that can identify the user or any other natural person is removed and the remaining data is data from which one cannot identify an individual, whether by us or by any other person. You agree that Derivative Data shall belong to us and we may use Derivative Data for any business purpose (including but not limited to development, provision, operation, maintenance, and improvement of our products and service).

4.   External provision of information

At present, we do not share or transfer your personal information to any third party. If there is any situation that we need to share or transfer your personal information, we will obtain your authorization or consent in advance, or we will anonymize your personal information in a non-recoverable way to make it impossible to identify specific individuals.

We do not publicly disclose your personal information. If public disclose is required, we will inform you of the purpose of this public disclosure, the type of information disclosed and the sensitive information that may be involved and obtain your explicit consent.

You understand that we will not share, transfer, publicly disclose your personal information to any third party without your prior consent except for the following circumstances:

(1)       Information related to national security and national defense security;

(2)       Information related to public security, public health, significant public interests;

(3)       Information related to criminal investigation, prosecution, trial and enforcement;

(4)       When it is difficult to obtain your consent for the maintenance of your or others’ major legal rights such as your life or property;

(5)       Personal information actively disclosed to the public by yourself;

(6)       Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

(7)       Personal information necessary to maintain the security and compliance of the wallet, such as to detect or to solve the malfunction of the wallet, and/or;

(8)       Other circumstances stipulated by laws and regulations.

5.   How you manage personal information

In accordance with the relevant laws of the Republic of Singapore, we ensure that you are entitled to controlling your personal information provided to the wallet by following methods:

(1)       You understand that you can perform the following actions under the “Me” section

a)         Under the "Settings" section, you can choose to turn off the "Fingerprint Login" option, that is, you can choose not to use the Touch ID/Face ID verification service provided by the mobile phone;

b)         Under the “Settings” section, you can choose to turn off the “Behavior Data Collection” option, that is, you can choose not to allow data analysis software to collect your behavior data;

c)          Under the “Settings” section, you can choose “Delete Behavior Data” option to submit your request to delete data, then we will delete your behavior data collected by us through data analysis software within 5 working days.

(2)       You understand that when we collect any personal information from you for a specific purpose, we will give you a notification in advance and you have the right to refuse. However, you need to understand that if you refuse to provide basic information specified in article 1- (1) - a) of this Privacy Policy to us, you are either deemed to refuse service provided by the wallet.

(3)       You understand that neither you nor we have the control right over whether transaction records being publicly disclosed or not. Your transaction records are public and transparent on the Blockchain due to the nature of publicity of Blockchain system.

(4)       You understand that when you open a third-party DApp through a link posted on the wallet, this Privacy Policy will no longer apply. For the safety of your personal information, we recommend that you read and understand its privacy rules and the user service agreements before using the third-party DApp.

(5)       While you use your wallet, we will provide you with tools and privacy settings to access, correct, delete or modify the personal data you provide to us in connection with your wallet. You can download the personal information we collect by following the instructions stipulated in article 5-(6) below. You can also request to correct, delete or modify your personal data, and download your address transaction information by following the instructions below.

(6)       You are entitled to asking us to provide, update, revise or delete your personal information collected by the wallet or revoke your authorization. These processes can be done by sending us the following information to

a)         Your wallet address;

b)         The contents of the information that you request us to provide, update, revise, or delete;

c)          Your contact information.

(7)       You understand that we can collect your information without your consent in accordance with article 4 of this Privacy Policy.

(8)       The information you provide will continue to be authorized to us during your use of the wallet service

6.   How we protect information

If we close the operation of the wallet, we will stop any further collection of your personal information without delay. Meanwhile, we will announce the termination of the operation on the wallet and delete or anonymize your personal information within a reasonable period.

In order to protect your personal information, we will implement data security technology measures to improve internal compliance, add internal information security training for employees, and protect your personal information in a secure method by setting access control in addition with other security means.

In the event of security incidents such as the disclosure of personal information, we will promptly inform you of the following matters in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the solutions we have taken or will take, and suggestions regarding self-prevention and risk reduction, remedial measures for you, etc. We will promptly inform you the incident by email, letter, phone, message notification, etc. When it is difficult to inform individual information subjects one by one, we will issue announcements in a reasonable and effective manner.

We will proactively report the result of personal information security incidents in accordance with the requirements of the regulatory authorities.

7.   Disclaimer

Please note that when you access a third-party DApp through the wallet, your personal information may be collected or used in accordance with the privacy policy issued by such third party. The collection, use and other operation of your personal information by the third-party DApp is beyond our control, to which this Privacy Policy will not apply.

You should prudently select and use third-party DApps and properly protect your personal information. We shall bear no responsibility for the privacy protection of other third-party DApps.

You understand and agree that we will take reasonable security measures to protect your personal information under current technical situation as far as possible to avoid the disclosure, tampering or damage of information. However, since the wallet transfers data wirelessly, we cannot guarantee the security of personal information even if we do everything we could to strengthen security measures. If you use the wallet to transmit data over a wireless network, its privacy and security may suffer problem due to factors beyond our control, and such problem shall not be deemed as our fault. In the event of any of the above problems, we will make every reasonable effort to reduce the loss for you. If any loss has been caused to you, we shall only be held liable for the reasonable part of loss that is rendered by our fault.

8.   Underage protection

We highly value the protection of underage’s personal information. Although the definition of underage varies between jurisdictions, we treat anyone the age of least 21 years of age (or older, depending on the legal age of majority in your jurisdiction) as underage. We do not offer wallet service to underage despite our inability to distinguish between their ages of users. If you are a guardian of an underage, please contact us at anytime you have questions about him/her using the wallet.

9.   How we update this Privacy Policy

This Privacy Policy may be revised from time to time.

We will not reduce your rights under this Privacy Policy without your explicit consent. We will post announcements related to any change to this Privacy Policy through the wallet.

For major changes, we will also provide more remarkable notices (including we will provide you with a page reminder to explain the specific changes to this Privacy Policy).

Major changes referred to in this Privacy Policy include but not limited to:

(1)       Major changes have taken place in how we offer service. Such as the purpose of processing user information, the type of personal information processed, the way in which personal information is used, etc.;

(2)       We have undergone major changes in the ownership structure and organizational structure. Such as changes in the owners caused by business adjustments, bankruptcy mergers, etc.;

(3)       The main objects of personal information sharing, transfer or public disclosure have changed;

(4)       Major changes in your rights to participate in the processing of personal information and how it is exercised;

(5)       When there are changes in departments responsible for dealing with user information security, contact information and complaint channels;

(6)       The information security impact assessment report indicates that there is a high risk.

We will also archive the old version of this Privacy Policy for your review.

For matters not covered by this Privacy Policy, you are subject to the announcements and related rules that we update from time to time. If you have any questions, comments or suggestions, please contact us by:


We will review the issue as soon as possible and respond within 30 days after verifying your user status.



VeChain Technology SEA PTE.LTD

April , 3, 2019