> For the complete documentation index, see [llms.txt](https://docs.propw.com/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.propw.com/help-center/getting-started/propw-privacy-policy.md).

# PropW Privacy Policy

PropW is a product service (the “Service”) offered by PROPW INNOVATIONS DMCC (“we,” “us,” “our,” or the “Company”) to proprietary trading users of PropW. For ease of reference in this policy, we collectively refer to ourselves as “we” or “our”.

We respect and protect the privacy of our users (hereinafter “you” or “user”). When you use our platform services, we will collect and use your personal information in accordance with this Privacy Policy (hereinafter the “Policy”).

We strongly recommend that you carefully read and fully understand the entirety of this Policy before using our services. By registering an account on our platform, accessing our platform, and/or using any of our services, you acknowledge that you have read, understood, and accepted this Policy and any future updates or revisions thereto. If you do not fully understand or accept this Policy, please do not register an account or use any of our services.

If you do not accept this Policy or any updated terms, please immediately discontinue your use of our services. Continued use of our services shall be deemed as your acceptance of this Policy and its revised versions.

1\. Information We Collect from You

Please be aware that we collect the following information solely to enable your use of our services, and we place great importance on protecting your privacy. When collecting your information, we strictly adhere to the principles of legality, fairness, and necessity. You acknowledge that you may choose whether or not to provide your personal data to us; however, if you do not provide the required personal information, we will be unable to continue providing our services to you.

When you register for or use our services, we may collect the following information from you:

1.1 Personal Information Collected During Registration or Reward Withdrawal

This includes your full name, nationality, gender, date of birth, ID/passport details, residential address, email address, phone number, bank account information, etc.

The specific purposes for collecting and processing the above personal data are:\
(1) User identity verification (KYC);\
(2) Verification of your eligibility to access to or use of the platform and its services;\
(3) Establishing and maintaining a good business relationship with you;\
(4) Understanding your needs and assessing your suitability for particular products and services;\
(5) Notifying you about transactions, financial information, advertisements, promotional messages, and other news;\
(6) Providing you with products or services;\
(7) Processing billing and collecting fees;\
(8) Obtaining user feedback on our services; and\
(9) Ensuring compliance with anti-money laundering (AML) and other applicable laws and regulations.

1.2 Automatically Collected Information

When you log in, register, or use our services, we may automatically receive and record information transmitted to us from your computer, mobile device, or other communication devices. This includes, but is not limited to, your mobile device information, IP address and location, operation logs, trading records, web browsing history, and related data.

The purposes of collecting such information include:\
(1) Analyzing your use of the platform and its services;\
(2) Developing and customizing services based on your preferences.

1.3 Additional Information for Specific Features

You acknowledge that when using certain specific features of the platform, we will provide you with a clear notice before collecting additional personal information. If you choose not to consent, you will be deemed to have waived the use of that particular feature.

1.4 Third-Party Services

When you are redirected to third-party service providers, those third parties will collect personal information directly from you. Our platform does not retain the personal information collected by such third-party service providers.

1.5 Collection Without Consent under Applicable Law

To the extent permitted by applicable laws and regulations, we may collect and use your personal information without your prior consent in the following circumstances:

(1) Related to national security or defense security;\
(2) Related to public safety, public health, or significant public interest;\
(3) Related to criminal investigation, prosecution, trial, or enforcement of judgments;\
(4) Where the personal information collected has been voluntarily disclosed by you to the public;\
(5) Where your personal information is collected from legally disclosed sources, such as lawful news reports or government information disclosures;\
(6) Where collection or use is necessary to maintain service security and compliance, for example to detect and remedy product or service faults; and\
(7) Other circumstances as stipulated by applicable laws and regulations.

2\. How We Use Your Personal Information

2.1 We use your information to provide you with our services when you register or use any of our services.

2.2 We will send you timely notifications of material matters, such as software updates, and changes to User Agreement and this Policy.

2.3 We collect your publicly available account address and device information to process feedback you submit to us.

2.4 We collect your personal information for internal audits, data analysis, and research to continuously improve our service quality.

2.5 In accordance with our User Agreement and other relevant Platform rules, we may use user information to manage and regulate user behavior.

2.6 In accordance with legal and regulatory requirements and to cooperate with regulatory authorities.

3\. How You Control Your Information

You have the following rights regarding control over your personal information:

3.1 You acknowledge that you may submit requests to us by email to <support@propw.com> to exercise rights including changing, deleting, restricting use of, or withdrawing consent to the use of your personal information. Specifically, you may exercise the following rights:

(1) Right of access: you have the right to access your personal information.\
(2) Right to rectification: if your information is inaccurate or incomplete, you have the right to request correction.\
(3) Right to erasure: you have the right to request deletion or removal of your information unless there are compelling legitimate grounds for continued processing.\
(4) Right to restriction of processing: you have the right to block or prohibit further use of your information.\
(5) Right to data portability: you have the right to obtain and reuse your personal data across different services for your own purposes.\
(6) Right to object: you have the right to object to certain types of processing.\
(7) Right to lodge a complaint: you have the right to file a complaint regarding how we process your personal data.\
(8) Right to withdraw consent: You have the right towithdraw your previously given consent for processing your personal data.\
\
Please note that you may choose whether to exercise any of the foregoing rights. However, if you validly exercise rights to restrict processing, object to processing, request deletion or withdraw your consent, we may be unable to continue providing the related Platform services to you.

3.1 You acknowledge that where we collect information for specific purposes we will notify you in advance and you have the right to refuse. If you choose to refuse to provide the requested information, you understand and accept that you thereby forfeit the ability to use the related Platform services.

3.2 You acknowledge that neither you nor we have control over the public visibility of your blockchain transaction records due to the open and transparent nature of blockchain systems and your transaction records may be transparent and publicly accessible across the blockchain network.

3.3 You acknowledge that after you are redirected to a third-party service provider via our platform, our User Agreement and Privacy Policy no longer apply. We recommend that you carefully review the third party’s privacy policy and terms of service before using their services.

3.4 We will continue using your personal information until you stop using our services or contact us to update, modify, stop using or delete your information; please note that if you request such actions, we may no longer be able to provide our services to you.

4\. We May Share or Transfer Your Information

4.1 User personal information collected and generated by us will be stored on servers. If cross-border transfer of your personal information is necessary, we will obtain your prior authorization and comply with all applicable laws and regulations regarding international data transfers, while fulfilling our confidentiality obligations.

4.2 Without your prior consent, we will not share or transfer your personal information to any third party, except in the following circumstances:\
(1) Where we have obtained your explicit prior consent or authorization;\
(2) Where the personal information collected has been voluntarily disclosed by you to the public;\
(3) Where the personal information was collected from lawfully disclosed public sources (e.g., news reports, government disclosures);\
(4) Where information is shared with our affiliates, limited to necessary information and bound by the purposes stated in this Policy;\
(5) Where, in our reasonable judgement, it is necessary to share your personal information with certain important third parties (e.g., partner banks, their appointed service providers, telecom companies, and other service providers) to facilitate service delivery, enhance our KYC procedures to prevent fraud, and comply with AML, counter-terrorism financing nd related policies. If you object to such sharing, please contact us; however, we may then be unable to provide our services to you;\
(6) Where disclosure is required by applicable laws, legal proceedings, or at the request of administrative or judicial authorities;\
(7) In the event of a merger or acquisition involving the transfer of personal information, in which case we will require the recipient of the personal information to remain bound by this Policy.

4.3 You expressly acknowledge and agree that we will engage CoinW platform to perform your identity verification (KYC). To complete this process, you hereby explicitly authorize us to provide CoinW with the necessary personal information for KYC purposes. CoinW will process such information solely for identity verification in compliance with applicable data protection laws and pursuant to the engagement arrangement between us and CoinW, and will securely store and protect your information in accordance with its data security obligations.

5\. How We Protect Your Information

5.1 If the Platform ceases operations, we will promptly cease collection of personal information, publish a notice on the platform, and delete or anonymize your personal data within a reasonable timeframe.

5.2 To protect your personal information, we implement technical security measures, enhance internal compliance, provide regular information-security staff training, and enforce strict access controls. We endeavour to employ a variety of security technologies and management systems to minimise the risk of disclosure, damage, misuse, unauthorised access, unauthorised disclosure and alteration of your information. Where appropriate, we will apply additional reasonable measures — for example, using de-identified data for statistical analysis in technical development environments, and de-identifying information contained in external research reports. De-identified data will be stored separately from any information that could be used to re-identify individuals, to ensure that subsequent processing of de-identified data does not re-identify persons.

5.3 We have established a dedicated data protection team responsible for conducting Privacy Impact Assessments (PIAs) for data collection, use, sharing, and processing. Internal policies ensure that staff access to user data follows the principle of minimum necessary, and all access is monitored. Regular training on privacy laws, security protocols, and awareness is provided.

5.4 We will send security-related messages via the platform’s “Message Center” and periodically update guidance on account and information protection in the “Help Center.”

Important Notice: Your account password, private keys, and mnemonic phrases are not stored on or synchronized with our servers. We do not provide any service to retrieve these credentials. Please safeguard them carefully. If you disclose such information, you may suffer losses and adverse consequences. If you suspect or confirm their compromise, contact us immediately so we can take prompt action to prevent or mitigate potential losses.

6\. Protection of Minors’ Information

We have the following special provisions regarding minors under 18 years old:

6.1 Our services are exclusively intended for individuals aged 18 years or older. We do not knowingly collect personal information from minors.

6.2 If we discover or reasonably believe that a minor has registered or used our platform without obtaining the consent of a guardian, we will promptly take reasonable measures to delete or anonymize their data and suspend service provision.

6.3 We comply with national laws to protect the confidentiality and security of minors’ personal information. If you are a guardian and believe we have inadvertently collected a minor’s data, please contact us immediately.

7\. Disclaimer

7.1 Please notice that when you access third-party services through our platform, their privacy policies apply. Such third parties’ collection and use of your information are beyond our control and not governed by this Policy. We cannot guarantee that third parties will adopt information-protection measures equivalent to ours.

7.2 You should exercise caution when selecting and using third-party services and take appropriate steps to protect your personal information. We assume no liability for the privacy practices of third parties.

7.3 Within the constraints of current technological capabilities, the Platform will adopt reasonable security measures to protect your personal information against disclosure, tampering or damage. Because the Platform transmits data wirelessly, we cannot guarantee the privacy or security of data transmitted over wireless networks.

8\. Your Rights Regarding Personal Information Protection

8.1 You may exercise the following rights:\
(1) Request access or inspection;\
(2) Request a copy;\
(3) Request supplementation or correction;\
(4) Request cessation of collection, processing, or use;\
(5) Request deletion.

8.2 Upon receiving your request for access, inspection or a copy, we shall determine whether to grant such request within fifteen (15) days from the date of your request, except where granting the request would:\
(1) Endanger national security, diplomatic or military secrets, national economic interests, or other major national interests;\
(2) Impede performance of statutory duties of public authorities;\
(3) Harm the significant interests of the data controller or a third party.

8.3 If necessary, the fifteen (15)-day period may be extended by up to another fifteen (15) days, with written (electronic or physical) notice of the reason for extension. We may charge a reasonable administrative fee for processing requests to access, inspect or copy personal information.

8.4 Where you request supplementation or correction of your personal information, the Platform shall determine whether to comply within thirty (30) days from receipt of your request, except where the accuracy of the personal information is in dispute. If necessary, the thirty (30)-day period may be extended once by no more than thirty (30) days; we will notify you in writing (electronic or paper) of the reason for the extension.

8.5 To exercise any rights under this Section 8, please contact our customer service or email <support@propw.com>.<br>

9\. Miscellaneous

9.1 You are solely responsible for understanding and complying with all laws, regulations, and rules applicable in your jurisdiction regarding your use of our services.

9.2 If you have questions about personal information usage, please contact us via in-app feedback or other official channels.

9.3 You may review this Policy, the User Agreement, and other service rules on our website. We encourage you to check these documents each time you visit our platform.

9.4 We may update this Policy from time to time. Revised versions will take effect immediately upon publication on our platform.

9.5 Matters not covered herein shall be governed by our official announcements and supplementary rules, which may be updated periodically.

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