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 Who are we?

 Your information will be saved by the A-Spadz Company.

"We", "us" and "ours" mentioned in this privacy statement mean Aspadz. If you are a representative of an organization or an organization (each one), "You" and "Your" in this Privacy Statement include the organization and the persons or related parts representing the organization (e. g.operators, officers, beneficial owners, principals, and beneficiaries), here in after referred to as "Data Subject".

For more information about Aspadz,please visit the www.aspadz .com。

Foreword

 We take your privacy seriously, and this privacy statement will inform you how we protect your personal information. We recommend that you read this Privacy Statement carefully as it contains the following important information:

 We collect your personal information, and how we handle it.

 Which part we may share your personal information with.

Your rights to personal information —— For example:obtain a copy of your personal information and ask us to change or delete the information.

We promise you

 We promise:

 Protect your personal information security and privacy.

 Do not sell your personal information.

 What personal information do we process?

"Personal Information" includes all information that can identify a natural person either directly (e. g., first name,surname) or indirectly (e. g., a passport number or combination of information).

We deal with the following personal information about the data subject:

Identity information, such as name, address, telephone number, email address, business contact information;

Personal characteristics, such as the date of birth, country of birth, and nationality;

Identification information issued by public institutions, such as passport, ID card, tax identification number, national insurance number, social security number, and work permit;

 Financial information, such as financial and credit record information, bank account information, debt collection and execution records;

Cookie Information, such as cookie and similar technologies in websites and email, will only be used to count and improve our websites, and will subsequently be deleted. We will also use this impersonal information to make it easier for you to use our website. (in addition, we may also use cookie to store the country of residence you have chosen during the session, so that you don't have to enter the information repeatedly).

We will also collect and process personal information to meet our legal and regulatory obligations, including:

Provide the sales documents related to the products and services to the data subject;

Record a communication record with the data subject (e. g., electronic communication, E-mail)

In addition, we may process relevant personal information to pursue legitimate interests, thus:

Assof some characteristics of the data subject based on automated processing (summary) (see also below);

Develop your business relationships with you;

Improve our internal business organization structure and operations, including risk management;

The use of such information for market research or advertising of Aspadz entities with the consent of the data subject and allowing the use of their personal information for marketing;

Assess our risks and make relevant business decisions on risk management;

Communicate personal information to other entities under Aspadz, especially to ensure efficient and coordinated services, and inform the data subject of the services provided by Aspadz;

Establishing, executing, and / or defending actual or potential legal claims, investigations, or similar proceedings;

 Record communications with data entities (e. g. telephone and electronic communications) to verify instructions, execute or defend our interests or rights, evaluate, analyze and improve the quality of our services, train our staff, and conduct risk management;

Audit and / or periodic reviews.

Source of personal information

 We collect or receive personal information as permitted by law:

 Personal information provided to us by the data subject, that is, personal information provided in opening accounts, discussing, consulting, inquiring, registering or using certain products and services on our website, opening subscription services and / or activities, participating in discussion areas or other social media functions of our website, and in the job registration process.

 Transmission through technical infrastructure can bring convenient personal information to our products and services.

Personal information from third parts and publicly available personal information (e. g., public registration information, public social media platforms).

 Automate personal decisions (including information aggregation) in specific situations

We may evaluate certain characteristics of the data subject based on the automated processing (aggregated) personal information, especially providing personalized products and recommendations for the data subject, or providing information about our or our affiliates and business partners' products and services. We also use technology to identify the risk level of a data subject or its account activity. Furthermore, we do not usually automate decisions on business relationships and / or data entities. For automated decisions on the above areas, we will comply with applicable laws and regulatory requirements.

Disclose personal information to third parts

We reserve the right to disclose or provide personal information to the extent permitted by law to:

Public / governmental authorities, courts, competent authorities (e. g. financial regulators), or financial market participants (e. g., third parts or central depository offices, brokers, exchanges, and registration departments);

 The Aspadz corporate entity or third-part processing agency that processes personal information on our behalf, and / or the agency responsible for our specific outsourcing work (outsourcing);

 Auditor or legal counsel.

Except for the above recipients, we promised not to transmit personal information to any third part, except for disclosure to the data subject and cooperate with the instructions of any court, government or regulatory authority (including tax authorities).

Disclosure abroad

 In our business relationship, we may disclose, transmit, and / or store personal information abroad ("cross-border transmission"):

signing or performance of contracts directly or indirectly related to our business relationships, such as contracts with you or a third part for your benefit; (ii) the necessary communications for the protection of important public interests;  (iii) special circumstances foreseeable by applicable law (e. g. disclosure of certain transactions conducted on the Exchange to the International Trade Registry).

Cross-border transmission may involve the transmission of information to jurisdictions: (i) Ensuring adequate data protection of the rights and freedom of the data subject in the processing of information; (ii) Benefiting from adequacy decisions at the level of data protection (e. g. by the European Commission or the Swiss Federal Data Protection and Information Commissioner); (iii) Neither benefiting from or providing adequate data protection. In the latter case, we will ensure that appropriate safeguards are provided, such as the use of data protection standards set by the European Commission.

 Transfer of data over the Internet

 Please note that data transmitted across countries over the Internet is not be affected to any control during transmission, even if the sender and receiver are located in the same country.

 We cannot guarantee the security of the data during the Internet transmission process, and we will assume no responsibility for it. We cannot guarantee the security of any information you send us by email. If you send us any confidential information by email, at your own risk. When contacting us, if possible, please send the data with security, not through the Internet.

Even if the transmitted information is encrypted, the sender and the receiver can still be identified. Third parts may inadvertently or otherwise infer a business relationship between you and Aspadz. Therefore, we recommend avoiding the transmission of any strictly confidential information through the open network.

 Rights of the data subject

 You are entitled to know whether we are processing personal information related to you. If you request, we will disclose you the personal information in our database, including the source of the information, the purpose and legal basis of processing the personal information (when appropriate), the category of the personal information processed, the information collectors and the information recipient involved.

 You may at any time revoke your permission to process your personal information, and / or at any time in the future decide not to use your information for advertising or marketing. You can also exercise more rights, such as the right to correct them. In addition, you have the right to request any inaccuracies in your personal information to disable or delete your information. The exercise of these rights depends on the legal basis on which we hold specific data.

 If we do not reach your expectations in handling our personal information, or if you want to complain about our practices in data protection, please let us know. We will immediately check your questions and make improvements if necessary.

 If the above happens, please ask us in writing and attach a clear copy of a valid official id card (such as passport, ID card) so that we can determine your identity. We will confirm immediately upon receipt, check your question and respond promptly.

We will continue to process personal information even if the data subject opposes: (i) mandatory legal requirements; (ii) necessary for the performance of the contract by the data subject; (iii) necessary for the performance of the public interest, or (iv) necessary for the purposes of our legitimate interests, including establishing, enforcing, or defending legal claims.

Retention period

 Considering our responsibility to respond to requests, resolve problems, provide improved new services, and act in accordance with applicable laws and regulations, A-Spadz will only store your personal information if necessary.

This in particular indicates that we have the right to keep your personal information for a reasonable period of time after we last contacted you. If personal information is no longer required, we have responsibility to remove such information in a safe manner except where (i) store personal information longer under any applicable law or regulation, or (ii) for the establishment, execution, and / or defense of actual or potential legal claims, investigations, or similar procedures, including legal retention, we may force such information.

Contact Way

If we do not reach your expectations in handling our personal information, or if you want to complain about our practices in data protection, please let us know. We will immediately to check your questions and make improvements if necessary. In any case, please clearly request us in writing,our contact information listed below:

Data Protection Commissioner

A-Spadz

Address: 14205 SE 36TH ST STE 100, BELLEVUE, WA, 98006-1553, UNITED STATES

Tel.: + 01 5612929457

Email address: contact@aspadz.com

Privacy statement change

We may change this privacy statement from time to time. You will be notified in an appropriate manner. Please review this statement regularly to ensure that you are aware of the latest version of the Privacy Statement every time you visit the A-Spadz website.

Note: The translated version is for reference only. If there is any inconsistency between the Chinese and English versions, the version shall prevail the Chinese version.