Banko Wallet Terms of Service
Last Updated: November 2nd, 2018.
Dear User,
Thank you for choosing Banko. This Banko Wallet Terms of Service (“Agreement”) is made between you (“User”) and Bitrock Pte. Ltd., and is legally binding between you and Company. In this Agreement (a) “we” and “us” refer to the Company and “our” shall be construed accordingly; and (b) “you” refers to User and “your” shall be construed accordingly. 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”.
Company hereby reminds you that you must carefully read the full content of this Agreement and other documents mentioned in this Agreement before using our mobile application “Banko Wallet” available on various mobile platforms including but not limited to Google Play and Apple App Store (“Banko” or “App”). In particular, you must carefully read the section of “Disclaimer and Limitation of Liability”. You must make sure that you fully understand the whole Agreement and evaluate the risks of using Banko Wallet on your own.

I. Confirmation and Acceptance of this Agreement

1. You understand that this Agreement and other relevant documents apply to Banko Wallet and the Decentralized Applications (“DApps”) which are developed and owned independently by Company on Banko Wallet (and excluding DApps developed by third parties).
2. After you download Banko Wallet and start to create or import wallet, you are deemed as having read and accepted this Agreement, which shall cause this Agreement to become effective and legally binding on both you and Company immediately.
3. Company may, at its sole discretion, modify or replace this Agreement at any time. The modified Agreement will automatically take effect once it is posted on Banko Wallet and you will not be notified separately. If you do not agree with the modifications, you shall cease to use Banko Wallet immediately. Use of Banko Wallet by you after any modification to this Agreement constitutes your acceptance of this Agreement as modified.



II. Definition

1. Banko Wallet: means the blockchain wallet developed by Company based on blockchain systems and other supporting tools which are developed for the convenience of the Users when using blockchain systems.
2. Excluded Person:
a) a person other than a natural person who possesses legal and mental capacity to enter into this Agreement; or
b) a User who is prohibited, restricted, unauthorized or ineligible in any form or manner whether in full or in part under this Agreement, laws, regulatory requirements, or rules in the jurisdiction applicable to such User, to use the Services (as defined below).
3. Identity: means the blockchain identity generated from a pair of your Public Key and Private Key.
4. Create or import wallet: means your use of Banko Wallet to create or import wallet after your acceptance of this Agreement.
5. Wallet Password: means the password determined by you when you create the wallet. The Wallet Password will be used to encrypt and protect your Private Key. Banko Wallet, as a decentralized application, will not store your Wallet Password on our servers, nor will your Wallet Password be stored in your own mobile devices. If you lose or forget your Wallet Password, you will have to reset the Wallet Password with your Private Key or Mnemonic Words.
6. Alert: means the messages displayed on Banko Wallet’s operation interface which provides suggestions for Users on subsequent operations.
7. Private Key: consists of 256 random bits. Private Key is the core for the User to hold and use the Tokens.
8. Public Key: is derived from the Private Key based on cryptography and is used to generate wallet addresses. A wallet address is a public address for receipt of Tokens.
9. Mnemonic Words: consists of 12 (or 15/18/21/24) words which are randomly generated, and it is based on BIP39, the industry standard of blockchain. It is a human readable format of words to back up your Private Key for recovery.
10. 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 the Company’ servers.
11. Tokens: means the tokens which are supported by Banko Wallet currently, including but not limited to BTC, ETH, DGD and so on.
12. Materials: means contents in the columns of “Discover” etc. on Banko Wallet. The Materials are third parties’ proprietary properties. User shall not reproduce or distribute the materials without their permission and authorization. Foregoing Materials are solely for your reference and shall not be considered as guidance or advice on your transactions provided by Company.
13. Message Center: means the inbox where the Users may receive messages or notices from the Company.
14. Profile Information: means information recorded in electronic or any other form which may identify a natural person when used alone or in combination with other information, including but not limited to name, date of birth, identification card number, personal biological identification information, address, telephone number, bank card number, e-mail address, wallet address, mobile device information, operation record, transaction record, but excluding Wallet Password, Private Key, Mnemonic Words and Keystore.
15. Smart Contract: means the type of Smart Contract operating on Ethereum blockchain and spreading, verifying and executing contracts via information methods, including but not limited to Smart Contract Kyber and/or Smart Contract 0x as hereinafter mentioned. Smart Contracts integrated on Banko Wallet do not provide cross-blockchain services.
16. WETH: means the tokenization of ETH. Because ETH does not satisfy its ERC20 standard, ETH is packaged via the means of tokenization to be used for direct transactions with other Tokens. The exchange rate between Tokens supported by Banko Wallet and WETH is decided by the third-party-developed Smart Contracts.
17. ETH means Ether, the cryptographic token associated with the Ethereum blockchain, which for the avoidance of doubt does not include “Ethereum Classic”.



III. Banko Wallet Services (collectively, the “Services”)

1. Create or import wallet. You may use Banko Wallet to create a new wallet or import wallets generated by other wallet application. You may only import wallets with Tokens which are supported by Banko Wallet.
2. Company may develop different versions of Banko Wallet for different terminal devices. You shall download and install applicable version. If you download and install Banko Wallet or other application with the same name as “Banko Wallet” from any unauthorized third party, Company cannot guarantee the normal operation or security of such application. Any loss caused by using such application shall be borne solely by you.
3. A previous version of Banko Wallet may stop to operate after a new version is released. Company cannot guarantee the security, continuous operation or customer services for the previous version. Users shall download and use the latest version.
4. Banko Wallet Alerts. You understand and agree to comply with the Alert(s) published by the Company on Banko Wallet. You shall be responsible for any risks, liabilities, losses and expenses which result from your failure to comply with any Alert(s).
5. Identification verification: Specific Users will be asked to complete identification verification before using Banko Wallet to comply with related laws and regulations, according to the notification of Banko Wallet. Specific Users may be asked to provide Personal Information including but not limited to name, identification card number, cell phone number, bank card information, etc., without which the Specific Users will not be able to use certain services and the Specific Users alone shall be responsible for the loss caused by their delay in completing the verification.
6. Transfer of Tokens
i. You understand that you may be subject to daily limits on the amount and times of transfers according to your location, regulatory requirements, transferring purposes, risk control by Banko Wallet, or identification verification.
ii. You understand that blockchain operations are “irrevocable”. When you use Banko Wallet to transfer Tokens, you shall be solely responsible for the consequences of your mishandling of the transfer (including but not limited to wrong address, problems of the node servers selected by you).
iii. You understand that the following reasons may result in a “transfer failed” or “mining overtime” prompt:
insufficient balance in wallet;
insufficient gas for transaction;
blockchain’s failure to execute the code of smart contracts;
the transfer amount exceeding the transfer limits imposed by authorities, Banko Wallet or laws or regulations;
technical failure of the network or equipment;
abandoned transactions result from blockchain network congestion or failure;
the wallet address of yours or your counterparty’s is identified as special addresses, such as high-risk address.
iv.You understand that Banko Wallet is only a tool for transfer of Tokens. Company shall be deemed to have fulfilled its obligations once you have completed the transfer and shall not be held liable for any dispute in relation thereto.
7. Compliance. You understand that you shall abide by applicable laws, regulations and policies when you use Banko Wallet or the DApps or the Smart Contracts on Banko Wallet.
8. Notifications. Banko Wallet may send notifications to you by web announcements, e-mails, text messages, phone calls, Notification Centre information, popup tips or client-end notices (e.g., information about your transfer or suggestions on certain operations) which you shall be aware of timely. 9. Service fees and taxes.
i.the Company does not charge you any service fees or handling fees for the time being. The Company may reach an agreement with you or announce rules regarding service fees in the future;
ii. You need to pay “gas” or network fees when you transfer Tokens, the amount of which would be on your sole discretion and would be collected by the relevant blockchain network;
iii. You understand that your transfer of Tokens may fail under certain circumstances, including but not limited to insufficient “gas” or network fees paid by you for the transfer of Tokens during the time of your transfer, or the relevant blockchain network being unstable, and in such event, you may still be charged gas by the relevant blockchain network, notwithstanding the failed transfer attempted;
iv. You shall bear all the applicable taxes and other expenses occurred due to your transactions on Banko Wallet.
10. Other services that Company would like to provide.



Users who use Banko Wallet acknowledges and accepts that:

1. In order to keep the decentralization feature of blockchain and to protect the security of your digital Tokens, Company offers decentralized service which is largely different from the banking and financial institutions. Users acknowledge and accept that the Company SHALL NOT have any responsibility to :
a) store Users’ Wallet Password (the password Users set when creating or importing wallets), Private Key, Mnemonic Words or Keystore;
b) recover Users’ Wallet Password, Private Key, Mnemonic Words or Keystore;
c) freeze the wallet;
d) report the loss of wallet;
e) recover the wallet; or
f) rollback transactions.
2. You shall bear sole responsibility to take care of your mobile devices, back up the Banko Wallet App, and back up the Wallet Password, Mnemonic Words, Private Key and Keystore. In the event that: your mobile device is lost, your Banko Wallet App or your wallet is deleted and not backed up, your wallet is stolen or you forget your Wallet Password, Private Key, Mnemonic Words or Keystore, the Company will not be able to recover the wallet or recover Wallet Password, Private Key, Mnemonic Words or Keystore. The Company may not be able to cancel transactions for the mishandling of Users (such as typing in wrong addresses for transactions, wrong amounts to be exchanged) and the Company shall not be responsible in any way in respect of the same.
3. Banko Wallet does not support all existing tokens. Do not use Banko Wallet to handle any non-supported tokens.
4.The DApps integrated into Banko Wallet include those developed independently by Company and those developed by third parties. Banko Wallet only provides blockchain search and browser functions for those third-party-developed DApps, and thus Banko Wallet does not offer any guarantee for functions or service qualities of those third-party-developed DApps. Users shall, at their sole discretion, decide whether there would be any risks to accept the services provided by or to conduct transactions on the third-party-developed DApps.
5. If Users access any websites and any third-party-developed DApps not integrated on Banko Wallet by entering URL under the developer mode, Users shall understand the security risks of the websites and the third-party-developed DApps linked by such URL, and assume all risks and consequences independently.



IV. Risks

1. You understand and acknowledge that the blockchain technology is a field of innovation where the laws and regulations are not fully established. You may be faced with material risks including instability of technology or failure for fiat-token exchange. You also understand that Tokens have much higher volatility comparing to other financial assets. You shall hold or dispose of the Tokens in a reasonable way and corresponding to your financial status and risk preferences. You also acknowledge that the market information is captured from exchanges by Banko Wallet and may not represent the latest or the best quotation of each Token.
2. If you or your counterparty fails to comply with this Agreement or fails to follow the instructions, tips or rules on the website or on the page of the transaction or payment, the Company does not guarantee successful transfer of the Tokens and the Company shall not be held liable for any of the consequences of such failure. If you or your counterparty has already received the payment in Banko Wallet or third-party wallet, you understand that transactions on blockchain are irreversible and irrevocable. You and your counterparty shall assume the liabilities and consequences of your transactions.
3. When you transfer your tokens directly to another wallet address, it is your sole responsibility to make sure that your counterparty is a person with full capacity for civil acts and decide whether you shall transact with him/her.
4. You shall check the official blockchain system or other blockchain tools when you receive an Alert such as “transaction failed” or “mining overtime” 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.
5. You understand that after you create or import wallet on Banko Wallet, your Keystore, Private Key and Mnemonic Words are only stored on your mobile device and will not be stored in Banko Wallet or on the servers of Company. You may change another mobile device to use Banko Wallet after you follow the instructions on Banko Wallet to back up your wallet. If you lose your mobile device before you could write down or backup your Wallet Password, Private Key, Mnemonic Words or Keystore, you may lose your Tokens and Company will not be able to recover them. If your Wallet Password, Private Key, Mnemonic Words or Keystore is disclosed or the device which stores or holds your Wallet Password, Private Key, Mnemonic Words or Keystore is hacked or attacked, you may lose your Tokens and Company will not be able to recover them. Any and all losses arising in connection with the foregoing shall be borne solely by you.
6. We suggest you backup your Wallet Password, Private Key, Mnemonic Words and Keystore when you create or import wallet by writing them down on papers or backup them in password management apps. Please do not use electronic methods such as screenshots, e-mails, note-taking apps in cell phones, text messages, WeChat or QQ to backup any of the foregoing information.
7. In order to avoid potential security risks, we suggest you use Banko Wallet in a secured network environment. Please do not use a jailbreak or rooted mobile device.
8. Please be alert to frauds when you use Banko Wallet. If you find any suspicious activity, we encourage you to inform us immediately.
V. Change, Suspension, Termination of Company Service

1. You acknowledge and accept that Company may, at its sole discretion, provide only a part of the Services for the time being, suspend certain Services or provide new Services in the future. When we change our Services, your continuous use of Banko Wallet is deemed as your acceptance of this Agreement and revisions of this Agreement.
2. In order to avoid (to the extent possible) any mishandling of Banko Wallet or any risk to the security of your Tokens, you shall not use Banko Wallet if you do not possess the basic knowledge of blockchain. For Users who do not possess basic knowledge of blockchain, Company may refuse to provide all or part of the Services on Banko Wallet to such Users.
3. You understand that Company may suspend the Services under the following circumstances (or may completely terminate the Services in connection with any of the following circumstances):
a) maintenance, upgrading, failure of equipment and blockchain system and the interruption of communications etc., which lead to the suspension of the operation of Banko Wallet;
b) force majeure events including but not limited to typhoon, earthquake, tsunami, flood, power outage, war, or terrorist attacks, or computer viruses, trojan horse, hacker attacks, system instability or government behaviors and other reasons, which result in the Company’s inability to provide Services or if in Company’s reasonable opinion, continuous provision of Services would result in significant risks;
c) material adverse change of applicable laws or policies; or
d) any other event(s) which Company cannot control or reasonably predict.
4. Company reserves the right to unilaterally suspend or terminate all or part of the Services or any function of Banko Wallet under the following circumstances:
a) death of Users;
b) if you steal others’ wallets information or mobile devices;
c) if you provide false Personal Information on Banko Wallet;
d) if you refuse to allow mandatory update of Banko Wallet;
e) if you use Banko Wallet to commit illegal or criminal activities;
f) if you hinder the normal use of Banko Wallet by other Users;
g) if you pretend to be staff or management personnel of Company;
h) if you threaten the normal operation of Company computer system by attack, invasion, alternation or any other means;
i) if you use Banko Wallet to send spam; or
j) if you spread rumours which endanger the goodwill of Company and Banko Wallet;
k) if you conduct any illegal activities, breach this Agreement etc. or other circumstances under which Company reasonably considers necessary to suspend Services.
5. You are entitled to export your wallets within a reasonable amount of time if Company changes, suspends or terminates its Services.



VI.Your Representations and Warranties

1. You shall comply with all applicable laws and regulations of the country or area you reside in. You shall not use Banko Wallet for any unlawful purposes or by any unlawful means.
2. You shall not use Banko Wallet to commit any illegal or unlawful activities, including but not limited to:
a) activities endangering national security of the country or area you reside in, disclosing state secrets, overturning the government or undermining national unity;
b) any illegal conducts, such as money laundering, illegal fund raising etc.;
c) accessing Company services, collecting or processing the content provided by Company, intervening or attempting to intervene any Users, by the employment of any automated programs, software, network engines, web crawlers, web analytics tools, data mining tools or similar tools etc.;
d) providing gambling information or inducing others to engage in gambling;
e) invading into others’ Banko Wallet to steal Tokens;
f) engaging in any inaccurate or false transactions with the counterparty;
g) committing any activities which harms or attempts to harm Banko Wallet service system and data;
h) other activities which Company has reason to believe are inappropriate.
3. You understand and accept that you shall be responsible for any violation of law (including but not limited to the customs and/or tax regulations) or for breach of this Agreement by you and shall indemnify Company against the losses, the third-party claims or administrative penalties against Company incurred by such violation or breach, including reasonable attorney’s fees.
4. You confirm that you will pay the service fees charged by Company in time (if applicable). Company reserves the right to suspend the services when the User fails to pay service fees (if applicable).



VII. Disclaimer and Limitation of Liability

1.Company only undertakes obligations expressly set forth in this Agreement.
2.YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, Banko Wallet IS PROVIDED ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS. Company shall not be held liable for malfunction of Banko Wallet which results from any of the following reasons:
a) system maintenance or upgrading of Banko Wallet;
b) force majeure, such as typhoon, earthquake, flood, lightning or terrorist attack etc.;
c) malfunction of your mobile device hardware and software, and failure of telecommunication lines and power supply lines;
d) your improper, unauthorized or unrecognized use of the Services;
e) computer viruses, trojan horse, malicious program attacks, network congestion, system instability, system or equipment failure, telecommunication failure, power failure, banking issues, government acts etc.;
f) any other reasons not imputed to Company.
3. Company shall not be held liable due to any of the following circumstances:
a) you losing your mobile devices, deleting Banko Wallet applications and wallets without back-up, forgetting Wallet Passwords, Private Keys, Mnemonic Words, Keystores without back-up, which result in the loss of such User’s Tokens;
b) you disclosing your Wallet Passwords, Private Keys, Mnemonic Words, Keystores, or lending or transfering your Banko Wallet wallets to others, or authorizing others to use your mobile devices or Banko Wallet, or downloading Banko Wallet applications through unofficial channels, or using Banko Wallet applications by other insecure means, which result in the loss of your Tokens;
c) you mishandling Banko Wallet (including but not limited to wrong address, failure of the node servers selected by you) , which result in the loss of Tokens;
d) you being unfamiliar with the lack of knowledge in relation to blockchain technology and your mishandling of Banko Wallet resulting in loss of your Tokens;
e) Banko Wallet being unable to copy accurate transaction records due to system delay or blockchain instability etc.;
4. Each User shall undertake the risks and consequences arising or in connection with the following :
a) such User’s transactions on the third-party-developed DApps or Smart Contracts;
b) the use of developer mode by Users; and
5. You understand that Banko Wallet is only a management tool for Tokens which is incapable to control the quality, security and legitimacy of products and services provided by the third-party-developed DApps or Smart Contracts, or the authenticity and accuracy of their information and their capabilities to fulfill the obligations under the agreements with you. You, at your sole discretion, decide whether to transact on the third-party-developed DApps or Smart Contracts. You understand that such transactions and corresponding contractual relationship are between you and your counterparty, instead of the Company. We kindly remind you to carefully review the authenticity, legitimacy, and effectiveness of related information provided by the third-party-developed DApps and Smart Contracts before you decide to use the DApps or the Smart Contracts. In addition, you shall also assume all the risks arising from the transactions between you and any third party exchanges.
6. You acknowledge that Banko Wallet may provide services to you and your counterparty simultaneously or may have affiliation or other interest relationship with foregoing parties, and you agree to waive any actual or potential conflicts of interests and will not claim against Company on such base or burden Company with more responsibilities or duty of care.
7. Company does not warrant that:
a) services provided by Company would satisfy all your needs;
b) all techniques, products, services, information or other materials from Company would meet your expectations;
c) all the transaction information in digital Tokens markets captured from the third party exchanges are prompt, accurate, complete, and reliable;
d) your counterparties on Banko Wallet will perform their obligations in the transaction agreements with you timely.
8. In any case, the total liability for Company under this Agreement shall not exceed the greater of:
a) the market value of 0.1 ETH; or
b) 100 U.S. Dollars.
9. You are aware that Banko Wallet is only a tool for Users to manage their Tokens and to display transaction information. Company does not provide legal, tax or investment advice. You shall seek advice from professional legal, tax, and investment advisors. In addition, Company shall not be liable for any investment loss, data loss etc. during your use of our service.
10.You understand that we may change our entry standards, limit the range and ways to provide services for specific Users etc. at any time in accordance with applicable laws and regulations.



VIII. Miscellaneous

1. No Assignment. Subject to this Agreement, only you and no other person shall have the right to any claim against us in connection with use of the Services. You shall not assign, trade or transfer, or attempt to assign, trade or transfer, your right to any such claim. Any such assignment or transfer shall be void and shall not impose any obligation or liability on or against us to the assignee or transferee.
2. Intellectual Property Rights
Banko Wallet is an application developed and owned by Company. The intellectual property rights of any contents displayed in Banko Wallet (including this Agreement, announcements, articles, videos, audios, images, archives, information, materials, trademarks or logos) are owned by Company or the third party licensors. Users can only use the Banko Wallet applications and its contents for the purpose of holding and managing their Tokens. In particular, without prior written consent from the Company or the third party licensors, no one shall use, modify, decompile, reproduce, publicly disseminate, alter, distribute, issue or publicly publish the abovementioned applications and contents. This Agreement shall not entitle you to any intellectual property rights, including the rights in relation to the use, for any purpose, of any information, image, user interface, logos, trademarks, trade names, internet domain names or copyright in connection with us or the Services.
3.No Waiver
Any failure by us to enforce this Agreement or to assert any right(s), claim(s) or causes of action against you under this Agreement shall not be construed as a waiver of our right to assert any right(s), claim(s) or causes of action against you.
4.Entire Agreement
This Agreement includes this Banko Wallet Terms of Service, Banko Wallet Privacy Policy, and other rules (including contents in the “Support” column) posted by Company from time to time.
Save for Banko Wallet Terms of Service, Banko Wallet Privacy Policy which are incorporated in this Agreement, this Agreement contains the entire agreement and the understanding between us and supersedes all prior agreements, understandings or arrangements (both oral and written) in relation to the use of Banko Wallet and the services in connection thereto.
5. Taxes
5.1 The use of Services shall be exclusive of all taxes that are applicable to, arising from, or in connection to your use of the Services in any jurisdiction (“Payable Tax”).
5.2 You shall be responsible for determining any Payable Tax and declaring, withholding, collecting, reporting and remitting the correct amount of Payable Tax to the appropriate tax authorities. You shall be solely liable for all penalties, claims, fines, punishments, or other liabilities arising from the non-fulfilment or non-performance to any extent of any of your obligations in relation to the Payable Tax.
5.3 We shall not be responsible for determining any Payable Tax and declaring, withholding, collecting, reporting and remitting the correct amount of Payable Tax to the appropriate tax authorities.
6. Severance and Partial Invalidity
6.1 If any of part of this Agreement is rendered void, illegal or unenforceable by any legislation to which it is subject, it shall be rendered void, illegal or unenforceable to that extent and no further and, for the avoidance of doubt, the rest of this Agreement shall continue to be valid and in full force and effect.
 6.2 The illegality, invalidity or unenforceability of any provision of this Agreement under the law of any jurisdiction shall not affect its legality, validity or enforceability under the law of any other jurisdiction nor the legality, validity or enforceability of any other provision.


IX. Others

1. You shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of the Services. 2. During your use of the Services, if you come across any problems, you can contact us through the submission of your feedbacks on Banko Wallet. 3.This Agreement is accessible for all Users on Banko Wallet. We encourage you to read this Agreement each time you log onto Banko Wallet. 4.This Agreement shall become effective on November 2nd, 2018. As for any issues not covered in this Agreement, you shall comply with the announcements and relevant rules as updated by Company from time to time.

Bitrock Pte. Ltd.

Banko Wallet Privacy Policy
Last Updated: November 2nd, 2018.
Dear Users,
Bitrock Pte.Ltd. (“Company”, “we”, “us”, or “our”) respects and protects the privacy of Users(“you”, “your” or “Users”).The Company will collect, use, disclose and process your Personal Information, in accordance with this Privacy Policy(“Policy”) when you:

(a) access or use our website and mobile applications(“Applications”) and services; and/or
(b) provide us with your Personal Information, regardless or the medium through which such Personal Information is provided.

The Company recommends that you shall carefully read and understand the whole contents of this Policy before your use of the Applications. Definitions of key words in this Policy are consistent with those in the Banko Wallet Terms of Service of the Company. If there is any discrepancy between the definitions of any defined term used in this Policy and the Banko Wallet Terms of Service, the definition of any defined term used in this Policy shall prevail. By providing us with your Personal Information, you consent to our collection, use, disclosure (including transfer) and processing of your Personal Information in accordance with this Policy. Please DO NOT provide any Personal Information to us if you do not accept this Policy. The Company reserves the right to update this Policy online from time to time, without notice to you, and the revised Policy will come in effect and supersede the older versions once posted on our Applications. The revised Policy wl apply to Personal Information provided to us previously. In parti ular, if you do not accept the revised Policy, plse immediately stop your use of the Applications. Your continuous use of our Applications will be regarded as your acceptance of the revised policy.

1. Information We Collect

1.1 We collect your Personal Information, including but not limited to your mobile device information, operation records, transaction records and wallet addresses.
1.2 In order to satisfy your needs or requests for specific services, we may also collect Personal Information including but not limited to your name, bank card number, telephone number, email address etc.
1.3 You confirm that your Wallet Password, Private Key, Mnemonic Words, Keystore on the Applications are not stored or synchronized on the Company’ servers. The Company does not offer the service to recover your Wallet Password, Private Key, Mnemonic Words or Keystore.
1.4 We may also request for you to provide us with additional Personal Information in order for us to enable your use of any specific functions of the Applications. Your refusal to provide us with the requested Personal Information will be considered as your choice to not use a particular specific function of the Applications.
1.5 To the extent permitted by applicable laws and regulations, the Company may collect and use the Personal Information in the following circumstances witht your prior consent or authorization:
1.5.1 information related to national security and national defense;
1.5.2 information related to public security, public health, si gnificant public interests;
1.5.3 information related to criminal investigation, prosecution, trial and enforcement;
1.5.4 Personal Information in the public domain;
1.5.5 Personal Information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
1.5.6 Personal Information necessary to maintain the security and compliance of services, such as to detect or to solve the malfunction of products and services; and/or
1.5.7 other circumstances permitted by laws and regulations.
1.6 We collect information in the following ways:
1.6.1 when you provide us with your Personal Information for whatever reasons;
1.6.2 when you authorize us to obtain your Personal Information from a third party;
1.6.3 when you register for a user account on our Applications;
1.6.4 when you contact us or interact with our employees through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;
1.6.5 when you transact with us, contact us or request that we contact you;
1.6.6 when you request to be included in an email or our mailing list; and/or
1.6.7 when we copy all or part of your transaction records on the blockchain. However, you should refer to the blockchain system for your latest transaction records.
1.7 Our Applications may contain certain technologies that collect Personal Information in the manner described in this Policy (see paragraph 5 below) or the applicable terms and conditions.
1.8 Your provision of Personal Information to us is voluntary and you may witdraw yur consent for us to use your Personal Information at any time. However, if you choose not to provide us with the Personal Information we require, it may not be possible for you to use the Applications or for us to contact you, or provide products or services which you need from us.
1.9 In certain circumstances, you may also provide us with the Personal Information of persons other than yourself. If you do o, youwarrant that you have informed him/her of the purposes for which we are collecting his/her Personal Information and that he/she has consented to your disclosure of his/her Personal Information to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such Personal Information in accordance with the terms of this Policy.
1.10 You are responsible for ensuring that all Personal Information that you provide to us is true, accurate and complete. You are responsible for forming us of any changes to your Personal Information.



2. How We Use Your Information

2.1 We collect, use or disclose your Personal Information for one or more of the following purposes:
2.1.1 to provide you with products and/or services that you request for;
2.1.2 to manage your relationship with us;
2.1.3 to facilitate your use of our Applications;
2.1.4 to associate you with your wallet by the unique serial number of your mobile device;
2.1.5 to push important notifications to you, such as software update, update of Terms of Service and this Policy;
2.1.6 to assist with your enquiries, feedback, complaints and requests by using the Wallet Address and the mobile device information provided by you;
2.1.7 to notify you of our products, services, programmes and events;
2.1.8 to resolve any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct;
2.1.9 to conduct our internal audit, data analysis and research;
2.1.10 to conduct user behavior tracking by tracking the Users’ use of the Applications;
2.1.11 to comply with our obligations in accordance with laws, regulations and to cooperate with regulatory authorities;
2.1.12 to comply with international sanctions and applicable regulation for securities and to counter money-laundering or financing of terrorism;
2.1.13 to enforce obligations owed to us, and contractual terms and conditions; and/or
2.1.14 any other reasonable purposes related to the aforesaid.
2.2 If you have consented, we may use your Personal Information, from time to time, for additional purposes such as to inform you of the latest activities, special offers and promotions offered by our strategic business partners, associates and affiliates.



3 How You Control Your Own Information

You are entitled to control your Personal Information provided to Banko Wallet.
3.1 You may import your other wallets into Banko Wallet through synchronization of wallets and you may export your wallets from Banko Wallet to other Tokens management wallets. Banko Wallet will display the information of imported wallets to you.
3.2 You may add or delete Tokens, transfer and collect Tokens using the “Assets” column.
3.3 You understand that you may handle the following operations in the “Profile” column on Banko Wallet:
3.3.1 in the “Settings” column, you may choose not to open “Touch ID”, which means you may refuse to use the Touch ID verification service provided by Apple Inc.;
3.3.2 in the “Feedback” column, you may submit any questions or suggestions for Banko Wallet at any time. We are glad to communicate with you to improve our services.
3.4 You acknowledge that since blockchain is an open source system, your transaction records are automatically public and transparent in the whole blockchain.
3.5 You are entitled to ask us to update, revise, and delete your Personal Information
3.6 In many circumstances, we need to use your Personal Information in order for us to provide you with products or services that you require. If you do not provide us with the required Personal Information, or if you withdraw your consent to our use and/or disclosure of your Personal Information for these purposes, it may not be possible for us to continue to serve you or provide you with the products and services that you require.



4 Information We may Share or Transfer

4.1 We will keep your Personal Information for so long as we need the Personal Information for our business and legal purposes.
4.2 We do not sell, trade or otherwise transfer your Personal Information to third parties without your consent.
4.3 If you have consented to our disclosure of your Personal Information to our strategic business partners and associates, we may disclose your Personal Information to them. They will use your Personal Information only for the purposes you have consented to.
4.4 You agree that we may disclose or share your Personal Information with third parties such as:
4.4.1 service providers and data processors working on our behalf and providing services to us such as conducting know-your-clients checks, accounting, data processing or management services, website hosting, maintenance and operation services, e-mail message services, analysis services, handling of payment transactions, marketing etc; and
4.4.2 our consultants and professional advisors (such as accountants, lawyers, auditors).
4.5 The Company will not share with or transfer your Personal Information to any third party without your prior consent, except for the following circumstances:
4.6.1 the collected Personal Information is publicized by yourself;
4.6.2 the Personal Information is collected from public information which was legally disclosed, such as news (lawfully reported), government information disclosure and other channels;
4.6.3 in order to abide by applicable laws, regulations, legal procedures, and administrative or judiciary autho r itie s or t o enforce our Policy or protect our or others’ rights, property or safety;
4.6.4 in the case of mergers and acquisitions, transfer of Personal Information is involved, the Company may require the receivers of Personal Information to be continuously bound by this Policy.



5 How We Protect Your Information

5.1 If the Company ceases operation, the Company will stop the collection of your Personal Information, and take steps to delete or anonymize your Personal Information held by us within a reasonable period.
5.2 To protect your Personal Information, the Company may adopt data security techniques, improve interal copliance levels, provide security training for our staff, and set security authority for access to relevant data to protect your Personal Information.
5.3 We will send you messages about information security in the “Notifications” column and update articles concerning the use of wallets and information protection in the “Support” column on our Applications for your reference.



6 Protection for the Minors The following special provisions apply to minors who are under the age of 18 years old:

6.1 The minors shall not use Banko Wallet without the guidance from their parents or guardians.
6.2 The parents and guardians of the minors shall provide guidance to the minors on using Banko Wallet after they read this Policy, Banko Wallet Terms of Service and other relevant rules.
6.3 Banko Wallet will ensure the confidentiality and security of the minors’ Personal Information in accordance with the applicable laws and regulations.



7 Disclaimer

7.1 After you access the websites, applications or Smart Contracts operated by third parties, you acknowledge that this Policy no longer applies to the collection, use, disclosure and transfer of your Personal Information by these third parties. The Company is unable to guarantee that these third party websites, applications and/or Smart Contracts will implement reasonable security measures to protect your Personal Information.
7.2 You are solely responsible for your use of these third party websites, applications and/or Smart Contracts and agree that you will not hold the Company liable for any damages incurred or injuries inflicted as a result of the collection, use, disclosure and transfer of your Personal Information by these third party websites, applications and/or Smart Contracts .
7.3 YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY WILL ADOPT MEASURES AS REASONABLE AS POSSIBLE TO PROTECT YOUR PERSONAL INFORMATION UNDER CURRENT TECHNIQUES ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS, TO AVOID THE DISCLOSURE, TAMPERING OR DAMAGE OF INFORMATION. SINCE THE COMPANY TRANSFERS DATA WIRELESSLY, THE COMPANY MAKES NO GUARANTEE ON THE PRIVACY AND SECURITY OF WIRELESS INTERNET DATA TRANSFERRING.



9 Miscellaneous

9.1 You shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of the services provided by the Company.
9.2 The validity, interpretation, alternation, enforcement, dispute resolution of this Policy and its revised versions shall be governed and construed in accordance with the laws of Singapore. Where there is no applicable law, this Policy shall be interpreted by applicable commercial and/or industrial practices. If any dispute or claim in connection with this Policy arises between you and the Company, the parties shall first attempt to resolve the dispute or claim through amicable negotiations in good faith. If the parties cannot reach an agreement, either party may sue the other party at the competent court in Singapore.
9.3 You may access this Policy and other terms (e.g. Banko Wallet Terms of Service) through our Applications. We encourage you to check the Banko Wallet Terms of Service and Policy of the Company each time you log onto our Applications.
9.4 This Policy shall become effective on November 2nd, 2018. As for any issues not covered in this Policy, you shall comply with the announcements and relevant rules as updated by the Company from time to time.

Bitrock Pte. Ltd.