Privacy Policy

Personal data, as defined here, includes any information that:

• a)Directly or indirectly pertains to a living person.
• b)Allows for the identification of an individual, either directly or indirectly.
• c)Is accessible and processable.

As a visitor or user of our services, we collect necessary personal information to provide our services, comply with legal requirements, or as detailed herein. Providing personal data marked with asterisks (*) is mandatory for service provision.

We may obtain your data from partners, affiliates, and external sources, including social media connections. This may encompass demographic information and identity verification via KYC processes.

We might share your information with affiliates, service providers, government bodies, or other third parties under certain conditions — including with our affiliates or subsidiaries, service providers (e.g. AML, CRM, communication services), vendors, agents, relevant government ministries, regulators, partners, or any third party, including but not limited to when third parties perform part of our Services on our behalf (e.g. for data processing, analytics, delivery of Services, and verification), when complying with legal obligations, or to protect the rights, property, or safety of our company, clients or others.

Some third parties processing your personal data may be located in a different country from the point of collection of your personal data, including but not limited to the location of servers or cloud-based services.

In cases where your personal information must be shared with third parties in non-standard circumstances, xbnk will request your consent unless the disclosure of your personal information is:

• a)Requested by an Authority, law enforcement agency, or public agency;
• b)Without a doubt in your interests, and consent cannot be obtained in a timely way;
• c)Necessary to respond to an emergency that threatens the life, health, or safety of yourself or another individual; or
• d)Required, permitted, or authorized based on applicable laws and/or regulations.

Our websites and services may feature links to external sites or applications not operated by xbnk. When you follow these links, our Privacy Policy will no longer apply. We encourage you to review the privacy policies of these external platforms. xbnk does not bear responsibility for the privacy practices of third-party websites or applications.

We may transfer, store, and process your personal data in various locations, including facilities operated by third parties such as Google or Amazon Web Services or others. Despite the international nature of our data processing, we are committed to enforcing robust data and privacy protection standards.

Our commitment to your data’s security is unwavering. We adhere to the Personal Data (Privacy) Regulation and other relevant regulations to safeguard the confidentiality and integrity of your personal information. Despite rigorous electronic safeguards, we must acknowledge the possibility of unauthorized data disclosure. In such instances, our liability for any resulting harm to users or third parties is limited to the maximum extent permitted by law.

As a user of xbnk services, you have specific rights regarding your personal data:

• Data Access and Correction: You can request a copy of your personal data we hold (Data Access Request, “DAR”) or request corrections (Data Correction Request, “DCR”) by writing to us.
• Objecting to Data Use: You can object to our use of your personal information by contacting support@xbnk.com. Note that this may impact your ability to use our services.
• Response Time: We aim to respond to your requests within 40 calendar days.

In some circumstances, we may decline to comply with your request in the following circumstances:

• A government agency or regulator with jurisdiction over xbnk directs xbnk not to comply with a visitor or user’s request;
• The information may, in our discretion, affect the safety of any person or persons;
• The data may be relevant to a regulator or official investigators (criminal conduct or breach of applicable laws);
• The data correction request is not made in Chinese or English writing;
• It is unable to verify the identity and authority of the requestor;
• It is not satisfied that the personal data to which the DCR relates is inaccurate;
• It is not provided with sufficient information to ascertain that the data is inaccurate; or
• It is not satisfied that the correction provided in the DCR is accurate.

In case you decide to withdraw your consent for the use of your personal data by xbnk, you are advised to immediately discontinue using our services and inform us via email at legal@xbnk.app. Upon receiving your request, we will process it promptly. Be aware that withdrawing consent may have legal implications and could impact our ongoing relationship.

You have the right to request the erasure of your personal data in our control, commonly known as the “right to be forgotten.” However, we may not always be able to fully comply due to legal obligations or technical limitations. We commit to erasing personal data when it’s no longer needed for its original purpose, except where law or public interest prevents such erasure.

Any individual below the age of 18 (or applicable age required for you to legally access or use the Services) shall obtain permission from their parents or legal guardians before accessing or visiting our Site(s) and Services.

xbnk does not have any intention to collect any personal data about individuals below the age of 18. If you act as a parent or guardian, by providing us with the personal data of an individual below the age of 18, you hereby consent to the processing of his/her personal data as per applicable laws and agree to be personally bound by the terms of this Privacy Policy and take full responsibility for his/her actions.

xbnk retains your personal data for as long as your account remains active or as necessary for providing services, including for legal, accounting, or reporting requirements. This includes retention periods post-termination of our business relationship as mandated by applicable laws, such as anti-money laundering regulations. For further inquiries, contact us at support@xbnk.com. Upon account closure or when data is no longer needed, we may delete or destroy your information, except where retention is legally required or for other regulatory or audit purposes.

We may change this Privacy Policy from time to time. If we do, we will let you know by revising the date at the top of the policy. If the changes, in our sole discretion, are material, we may also notify you by sending an email to the address associated with your account or by otherwise providing notice through our Services. By continuing to use our Services after Privacy Policy changes go into effect, you agree to be bound by the revised policy.

If you wish to ask or notify us for:

• a)DAR or DCR;
• b)Queries related to this privacy policy;
• c)Remove your consent for us to use your personal data; or
• d)Erase personal data.

Please send us a notice to: support@xbnk.com

What Are Cookies?

Cookies are small amounts of data that are sent to your browser and stored on your computer’s hard drive to collect standard internet log information and visitor/user behavior information. When you visit our Sites or Channels, xbnk can automatically collect information from you through cookies or similar technologies. There may also be third-party cookies on our Websites and Channels.

How Do We Use Cookies?

We use cookies in a range of ways to make your experience on our Sites and Services more enjoyable, including but not limited to:

• To keep you signed in;
• To record your habits and preferences when browsing our Sites and Services;
• To record our performance and verify the effectiveness of online advertising through analytics tools with cookies;
• To manage and improve the design of the Site and Services.

We may collect your personal information, anonymized, to support us in our business. Such information may be shared, disclosed, leased, assigned, licensed, sold, and transferred.

How to Manage Your Cookies?

Most browsers automatically accept cookies. You can adjust your browser setting to prevent cookies or to notify you as soon as cookies are loaded. However, stopping all cookies might mean that you cannot access or use some of our Services or features.

What is Do Not Track (DNT)?

DNT is a concept promoted by regulatory agencies for the Internet industry to develop a mechanism allowing Internet users to control the tracking of their online activities across websites by using browser settings. However, please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests. Therefore, this Privacy Policy does not cover third-party policies related to cookies.

If you have any questions, concerns, or requests regarding this Privacy Policy or how xbnk handles your personal data, please contact us: