1. Who We Are

SPLENDID CELESTIAL RIVER LIMITED is a company incorporated in Hong Kong with its registered office and principal place of business at RM 12, 6/F THE CLOUD 111 TUNG CHAU ST TAI KOK TSUI HONG KONG, registration number 78034201 (hereinafter “SCRL”, “we”, “us”, or “our”). We understand the importance of protecting your privacy. This Privacy Policy explains what information we collect about you when you download, install, register for, access, or use our mobile application (hereinafter the “App”), how that information is used and shared. This policy also describes the choices you have in controlling the collection, correction, and/or deletion of your information.

This Privacy Policy applies only to information we collect through the App and through email, text, and other electronic communications related to the App. This Privacy Policy does not apply to information collected by other applications or websites (including third-party websites you may access through the App) or to information collected by any third party. Third parties typically have their own privacy policies, which we strongly recommend you read carefully before providing any information to them.

If you do not want your information collected or used as described in this Privacy Policy, you must cease using our services and uninstall the App from all your devices.

2. Information We Collect

When you use our App, certain information is collected automatically. This information may include, but is not limited to, usage details, metadata, and the real-time location information of your device. We do not typically collect or store information that directly identifies you (“Personally Identifiable Information” or “PII”) through the App. All collected data is held solely by service providers and partners, as detailed below. Nevertheless, the information we collect about you may still fall under the definition of “personal data” as defined by the General Data Protection Regulation (GDPR).

3. How We Use Your Information

We use the information collected through the App to operate, maintain, and provide you with the features of the App; to diagnose or fix technical problems; to help you efficiently access your information after you log in; to fulfill the purpose for which you provide it; to communicate with you about the App (e.g., to notify you of App updates); to protect our rights and your rights in connection with your use of the App; to enforce any agreements between you and us; and to comply with any court order, law, or legal process. We may also use non-personally identifiable information to optimize and improve our services; to provide customized, personalized content in the App; to display targeted advertisements; to fulfill any other purpose we disclosed when you provided the information, or to protect the rights, property, or safety of SCRL, our customers, or third parties.

We do not store any Personally Identifiable Information on our IT systems. For a clearer understanding of the data we collect about you, please refer to the data protection policies of the service providers mentioned below.

4. How We Share Your Information

SCRL may use and disclose aggregated or anonymized information that does not involve identifiable natural persons without restriction. For example, we may share anonymized usage data with third-party analytics providers to help them and us understand usage patterns related to the App, thereby enabling us to better evaluate and consider new features or enhance our services.

Notwithstanding anything to the contrary in this policy, SCRL expressly reserves the right to share the information we collect about you (including Personally Identifiable Information) with any third party in the event that we have a good-faith belief that such access, use, preservation, or disclosure of the information is reasonably necessary to satisfy any applicable law or regulation; to enforce our terms and conditions; to address fraud or technical issues; to protect us from any harm to our rights; or to protect our users from any harm to their rights.

5. Third-Party Logins

Our App allows you to log in and register through certain third-party services (such as Google). Notwithstanding anything to the contrary in this policy, if you choose to register or log in through a third-party service, SCRL reserves the right to collect personal information (including Personally Identifiable Information) that you have provided or may in the future provide to that third-party service. If you wish to change your account settings or manage account access for a third-party service, you must do so directly through the relevant third-party service. For Google, you can manage account access here: https://support.google.com/accounts/answer/3466521?hl=zh.

6. Third-Party Information Collection and Use for Online Behavioral Advertising

When you use the App on your Apple or Android mobile device, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include, but are not limited to, advertisers, ad networks, ad servers, and analytics companies.

SCRL provides the ad ID generated by your Apple or Android mobile device (which is a non-persistent, resettable device identifier) as well as real-time location data, usage data, or information about your use of the App and other services through your mobile device for use by third-party ad servers or ad networks (“Advertisers”). However, we do not provide your name or email address to Advertisers.

Advertisers may also use tracking technologies to collect information about you as you use the App. More specifically, Advertisers may collect information about your online activities over time and across different websites, apps, and other online services under a particular ad ID. Advertisers may use this information (including the information we provide to them) to serve interest-based (behavioral) advertising or other targeted content to your mobile device.

The App uses the following services:

• Google’s Firebase: https://firebase.google.com/support/privacy;

• Google Analytics: https://policies.google.com/technologies/partner;

• Yandex’s Appmetrica: https://yandex.ru/legal/metrica_agreement/.

We do not control the tracking technologies of third parties or how they may be used. This Privacy Policy does not apply to the Advertisers mentioned above. If you have any questions about an advertisement or other targeted content, you should review the relevant Advertiser’s privacy policy. For information about how to opt out of receiving targeted advertising, please see the “Your Choices About Your Information” section below.

7. How We Protect Your Information

SCRL uses commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your data. However, no transmission of information over the Internet or mobile platforms can ever be completely secure. While we do our best to protect your personal information, we cannot guarantee the absolute security of personal information transmitted through the App and will not be liable for any security issues. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures.

8. Your Choices About Your Information

We are committed to providing you with choices regarding the information you provide to us. This section describes the mechanisms we provide that may allow you to control certain uses and disclosures of your information.

Ad ID: The ad ID is a non-persistent, resettable device identifier used for online behavioral advertising purposes, which is generated and managed by Apple or Google depending on whether you are on an iOS or Android device. You can object to the transmission of the above information at any time by adjusting your mobile device settings to disable Apple’s ad tracking (via IFDA) or to opt out of interest-based ads (via Google Ad ID). The specific procedures vary by device, so you will need to consult your device’s operating system user manual for specific instructions. Additionally, you can reset the ad ID at any time (and as many times as you want), which will cause the Google or Apple system to rebuild your device’s ad profile, preventing Advertisers from associating your pre-reset activities with your device.

Other Tracking Technologies: Depending on your device, you may be able to disable or refuse App cookies and/or other tracking technologies by adjusting your settings. If you disable or refuse cookies or block other tracking technologies, some parts of the App may be inaccessible or not function properly. SCRL does not access your device’s “Do Not Track” settings and will not respond to such settings. However, third-party Advertisers, ad networks, and ad servers that display ads in our App may access and respond to your device’s or browser’s “Do Not Track” signal. To learn how a third-party Advertiser responds to your device’s or browser’s “Do Not Track” signal, you must consult their respective privacy policy.

Third-Party Targeted Advertising: We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide options to allow you to choose not to have your information collected or used in this way. Typically, you can find out how to opt out of targeted advertising from a specific Advertiser by clicking on the AdChoices icon or link (or a similar icon or link) displayed in or near an ad. You can also opt out of targeted advertising from certain ad networks in the following ways.

If an Advertiser is a member of one of the following:

• Google’s Admob: https://policies.google.com/technologies/partner;

• Facebook: https://www.facebook.com/about/privacy/update.

You can stop all collection of information by the App by uninstalling it. You can use the standard uninstall process provided by your mobile device or through the App marketplace or network.

9. How to Delete Your Information

In accordance with Meta platform rules, we are required to provide a user data deletion callback URL or a data deletion instruction URL.

If you wish to delete your activities related to the App, please follow these steps:

1. Go to “Settings & Privacy” on your Meta account, then click “Settings”.

2. Go to “Apps and Websites,” where you will see all your App activities.

3. Select the checkbox for our App.

4. Click the “Remove” button.

Congratulations, you have successfully removed your activities.

To delete your data from the App’s database, you must send an email to office@CryptoStart.app with your specific account information.

10. How to Correct Your Information

If you believe that the information we hold about you is incorrect or inaccurate, you can request to correct, delete, or modify such information by sending an email to office@cryptostart.app with your specific account information and a detailed description of your request.

11. Changes to Our Privacy Policy

We reserve the right to modify this Privacy Policy at our sole discretion at any time. If any modifications are made to our Privacy Policy, we will provide the updated Privacy Policy within the App. Any modifications to the Privacy Policy are effective immediately upon posting, and your continued use of our services automatically signifies your consent to and acceptance of these modifications. The date the Privacy Policy was last revised is identified at the top of the page. It is your responsibility to periodically review this Privacy Policy to confirm if there have been any changes.

12. Contact Us

If you have any questions or concerns about our Privacy Policy, you can contact us at office@cryptostart.app.