Privacy Policy

Bitunix Privacy Policy

Bitunix is a digital asset trading platform that operates the website https://www.bitunix.com and related mobile applications (collectively, the “Platform”) and is dedicated to providing digital asset trading and related services.

This Privacy Policy forms an integral part of the Bitunix User Agreement and applies to your browsing, access to and use of Bitunix services.

This Privacy Policy (the “Privacy Policy”) is intended to help you understand how we collect, use, disclose, store and otherwise process your personal data, and to help you exercise your privacy rights under applicable law.

Bitunix will protect all personal data you submit to us when using our products and services. We may use or disclose your personal data in accordance with this Privacy Policy to provide you with better services.

We may amend this Privacy Policy from time to time and strongly recommend that you review it each time you browse or use Bitunix services to stay informed about our data processing practices, your privacy rights and the choices available to you.

If you have any questions about this Privacy Policy or any amendments to it, please contact us at [email protected].

1. Information We Collect

To provide you with our products and services, we may collect the following categories of personal data:

A. Account Registration Information

For example, your name, email address, telephone number, government-issued identification documents and selfie images for biometric templates (for example, for Know Your Customer (“KYC”) identity verification).

B. Device and Connection Information

Including device type, operating system, device identifiers, IP address, location data, browser information, network connection status and other technical identifying information relating to your access to the Platform.

C. Usage Behaviour Information

For example, browsing history, activity logs, clickstream data, browsing records within the Platform and usage patterns. This information will be used to improve our products and services, enhance the user experience, and detect or prevent fraud and other prohibited activities.

D. Transaction and Financial Information

Including transaction records, order records, deposits, withdrawals, payment card information (where applicable), cryptocurrency wallet information and other transaction-related information.

To the extent permitted by applicable laws and regulations, Bitunix may collect additional information from users applying for Advanced Verification, institutional accounts or other value-added services for purposes such as regulatory compliance, anti-money laundering obligations, sanctions screening, fraud prevention and suitability assessments.

Such information may include, without limitation, financial circumstances, source of funds, source of wealth, net worth, investment experience and investment knowledge.

E. Collection of CSP Error Reports

To enhance the security of the Platform, we collect reports relating to Content Security Policy (“CSP”).

These reports help us identify and fix potential security vulnerabilities.

The information we collect may include:

Page Address (document-uri): the URL of the webpage on which the CSP error occurred;

Blocked Resource (blocked-uri): the external resource (such as a script or image) blocked by a CSP rule;

Violated Directive (violated-directive): the specific CSP rule that caused the relevant resource to be blocked.

The above information is used solely for security analysis, fraud prevention and website optimisation.

All reports are encrypted in transit and sent to our internally deployed CSP collection service, which is accessible only to authorised information security personnel.

Unless otherwise provided in this Privacy Policy or required by applicable law, this information will not be shared with any third party.

F. AI Feature Data

We may offer or introduce AI features, such as AI Weekly Trading Reports, AI Candlestick Analysis and other tools for interpreting market information, analysing trades or providing assistance. The data processed by each feature depends on its purpose; features that use only public price or market data will not, as a result, provide your personal trading data to third parties. For optional AI features involving your personal data, the data necessary for that feature will be extracted, organised and processed only after you actively choose to use it and complete the relevant consent procedure.

Such data may include your selected trading instruments, analysis periods and parameters, relevant price and candlestick data, and, where genuinely required by the feature and with your consent, necessary metrics derived from trading data already held by the Platform, such as the number of trades, profit and loss, win rate, trading volume and position performance. We will also process the corresponding analysis results, necessary consent records and service operation logs to provide the feature, manage your choices, troubleshoot issues and protect service security. This list does not mean that every AI feature will process all such data.

When you use AI features, we will not disclose your name to third-party AI model, API or routing service providers. Requests sent to these providers contain only the data and analysis instructions necessary to provide the relevant feature. They do not include your UID, email address, telephone number, identification documents, account login credentials or other data that directly identifies you, nor do they include the mapping between the analysis data and your Platform account. Removing direct identifiers does not necessarily constitute irreversible anonymisation; any data that remains personal data continues to be protected by this Privacy Policy.

If an AI feature allows you to enter questions, text or files, we will explain the scope, purposes and recipients of the data to be processed before the feature is enabled. Please do not enter your own or anyone else’s name, identification information, contact details or account credentials. We will not transmit content containing such direct identifiers directly to third-party AI services and will take the necessary measures to remove or mask them before transmission. New features or data uses will not be automatically authorised merely because you previously consented to another AI feature.

You understand and agree that this Privacy Policy does not apply to:

A. Search keywords you enter when using the Platform’s search function.

B. Public content that you voluntarily create or publish on the Platform, including, without limitation, forum posts, blogs, social media pages or other publicly accessible content.

C. Information relating to your violation of applicable laws, regulations, the Bitunix User Agreement, Platform rules or other applicable policies, including any enforcement actions, restrictions or other measures taken as a result of such violations.

2. How We Use Your Information

We use your personal data for various business purposes, including, without limitation:

A. Providing you with information about products, services and promotions offered by Bitunix or selected third parties that we believe may interest you, subject to obtaining your express consent where required by applicable law.

B. Processing applications, transactions and financial information relating to your purchase or use of products or services through the Platform.

C. Enhancing the security of the Platform and your account by detecting, preventing and investigating malicious, fraudulent, deceptive, illegal or other prohibited activities.

D. Continuously improving our products and services through research, testing, analysis, product development and service optimisation.

E. Sending you administrative or account-related notices concerning Bitunix services by email, telephone, SMS or in-app/push notifications, including security alerts, identity verification messages, service announcements, legal notices and transaction-related communications.

F. Presenting services suited to your needs based on your assets and trading patterns, including, without limitation, trading, wealth management, staking, custody services and other digital asset-related products.

G. You expressly understand and agree that the foregoing presentation is intended solely to enhance your user experience and does not, under any circumstances, constitute investment advice, financial advice or any other form of professional advice provided to you by Bitunix.

H. Complying with applicable local and international laws, regulations, regulatory requirements, judicial requirements and legally binding government orders.

I. We will collect, use and retain your personal data only to the extent reasonably necessary for the purposes set out in this Privacy Policy.

J. Where it is necessary to share your personal data with third-party business partners to provide products or services to you, we will require those partners to take appropriate measures to protect your personal data in accordance with this Privacy Policy and applicable law.

K. Use of AI Features and Your Choices

We use the data necessary to provide the relevant feature to organise market information, interpret prices and charts, analyse trading performance or generate related content. Optional AI analysis involving your personal data requires your separate consent and is not a condition for using basic trading services. The specific scope and purposes of the data will be set out in the feature-specific notice.

For personalised AI features that you must actively enable, we will not additionally collect, extract, organise or analyse your personal data for the feature, or send data to third-party AI services for that purpose, before you enable it and complete the relevant consent procedure. If you do not consent, the feature will not be activated, and you may continue to use other Platform services that do not depend on it.

Taking AI Weekly Trading Reports as an example, if you have not actively entered the feature, we will not automatically generate a weekly report in the background, additionally collect, extract or analyse data for that purpose, or transmit data to third-party AI services. After entering the feature, you must still complete the consent procedure first; if you do not consent, the system will exit and return to the previous page. Prior consent to use the feature does not mean that we may automatically generate new weekly reports when you have not actively entered it.

These arrangements do not affect our separate collection and processing of data under this Privacy Policy in the ordinary course of providing account, trading, security and compliance services, nor do they mean that the Platform has never held your trading records. AI features that analyse only public market data are distinct from analyses using your personal trading data; listing such features in this Policy does not authorise access to your personal data.

We will not use personal data, non-public trading metrics, analysis instructions or generated content processed by AI features to train or fine-tune general-purpose AI models of Bitunix or any third party, nor will we use such data for independent third-party advertising or marketing on the basis of your consent to AI features. The general provision on service improvement in Section 2.D does not authorise such model training.

AI-generated content may contain inaccuracies, omissions or erroneous inferences. The information and analysis provided do not constitute investment advice, trading instructions or guarantees of returns. Your consent to use AI analysis features does not authorise us or any third party to place orders or operate your account on your behalf, nor does it constitute consent to decisions that produce legal or similarly significant effects based solely on AI analysis results.

3. Sharing and Disclosure of Personal Data

Bitunix respects and protects your personal data.

Unless otherwise provided in this Privacy Policy, consented to by you, or required or permitted by applicable law, Bitunix will not sell your personal data to any third party or allow any third party to use your personal data for its own independent marketing purposes.

To provide our products and services, fulfil legal and regulatory obligations, or protect the legitimate rights and interests of Bitunix, our users and other third parties, we may share or disclose your personal data to the following categories of recipients where necessary:

A. Bitunix Group Companies and Affiliates

We may share your personal data with our parent companies, subsidiaries, affiliates and other members of the Bitunix group for the following purposes:

· Providing and managing Bitunix services;

· Unified customer account management;

· Risk management;

· Anti-money laundering (AML);

· Counter-terrorist financing (CTF);

· Sanctions screening;

· Fraud prevention;

· Customer support;

· Information security;

· Regulatory compliance; and

· Ensuring the continued operation of the Platform.

B. Third-Party Service Providers

We may disclose your personal data to third-party service providers that provide services on behalf of Bitunix, including, without limitation:

· Identity verification (KYC) service providers;

· Payment institutions;

· Banking partners;

· Cloud computing and hosting service providers;

· Data storage service providers;

· Cybersecurity service providers;

· Fraud prevention service providers;

· Customer support platform providers;

· Technical support service providers;

· Data analytics service providers; and

· Other professional service providers that assist us in operating the Platform or providing Bitunix services.

These service providers may process your personal data only in accordance with our instructions and must implement appropriate technical and organisational measures to protect your personal data.

For AI features, these service providers also include providers of AI models, model APIs, request routing and related cloud services. Only after you complete the consent procedure for the relevant feature will we provide necessary data to the providers actually involved in processing that request. We will restrict data use, access and retention through contractual arrangements and appropriate technical settings. Service providers must not use data processed by AI features for their own model training or independent marketing purposes, nor may they use such data to attempt to identify you or establish a mapping to your Platform account.

C. Business Partners

Where Bitunix jointly launches products, services, promotions or other business collaborations with third parties, we may share necessary personal data with business partners to the extent reasonably necessary to achieve the relevant business purposes.

Any such sharing must comply with applicable laws and regulations and be subject to appropriate safeguards.

D. Regulators, Law Enforcement and Government Authorities

Where required by applicable laws, regulations, legal proceedings, court orders, regulatory investigations, government requests or other legally binding processes, we may disclose your personal data to competent regulators, law enforcement agencies, courts, government authorities or other authorised public bodies.

E. Protection of Legitimate Rights and Interests

Where we reasonably believe disclosure is necessary, we may disclose your personal data to:

· Prevent, investigate or address suspected illegal activities, fraud, money laundering, terrorist financing or other criminal conduct;

· Investigate violations of the Bitunix User Agreement, Platform rules or other applicable policies;

· Protect the rights, property, safety or legitimate interests of Bitunix, our users or other third parties; or

· Prevent significant harm or maintain the security and integrity of the Platform.

F. Professional Advisers

Where reasonably necessary, we may disclose your personal data to our lawyers, auditors, accountants, insurers or other professional advisers to obtain legal, financial, insurance, audit or other professional services.

G. Corporate Transactions

If Bitunix undergoes a merger, acquisition, financing, restructuring, asset sale, bankruptcy, liquidation or other similar corporate transaction, your personal data may be transferred or disclosed as part of that transaction to the extent permitted by applicable law.

Where practicable, we will require the relevant recipients to continue protecting your personal data in accordance with this Privacy Policy and applicable law.

4. Third-Party Services

To ensure the security, stability and compliance of the Platform, Bitunix may use third-party service providers.

These service providers may collect and process certain device identifying information, location data and user behaviour data in accordance with their respective privacy policies and applicable law.

We engage only service providers that we reasonably believe comply with applicable laws, regulations and relevant industry standards, and require them to implement appropriate technical and organisational measures to protect your personal data.

The third-party service providers currently used by Bitunix include, without limitation, the following:

Third-Party Services for AI Features

The AI model services currently integrated include Google AI Studio (Gemini API) and Google Vertex AI, with one of these services used according to the service configuration for each request. If a request is routed through OpenRouter, OpenRouter will also act as an API and routing service provider, processing the data necessary to transmit that request and return the results, subject to the above purpose restrictions. These are backend API services and are distinct from the mobile application SDKs listed above.

We use only service arrangements that do not use AI feature inputs and outputs for model training. The relevant Google AI Studio services may retain requests and responses for a limited period for security, abuse detection and compliance with legal obligations; this feature does not authorise their use of such content for model training. For Google Vertex AI, we use service configurations that meet zero data retention requirements to process the relevant AI requests. This arrangement applies to prompt and response content and does not mean that legally required records or necessary service operation data that do not contain such content do not exist. If a required service or configuration cannot meet these restrictions, we will not send the relevant AI feature data through that service.

For information on data processing by these services, please refer to the Google Gemini API Terms of Service (https://ai.google.dev/terms](https://ai.google.dev/terms), Google Cloud’s explanation of zero data retention (https://cloud.google.com/compliance/data-privacy) and the OpenRouter Privacy Policy (https://openrouter.ai/privacy](https://openrouter.ai/privacy). These links help you understand the providers’ service arrangements; they do not replace Bitunix’s responsibilities under this Privacy Policy or expand the authorisation you give to Bitunix.

If the addition of AI products, a change of providers or adjustments to processing methods materially change the data categories, purposes, recipients or retention arrangements, we will update this Policy or the feature-specific notice before the changes take effect and before the relevant data is transmitted, and obtain your consent again where required by applicable law. We will not expand existing authorisations for AI features solely on the basis of a general provision for updating the provider list.

Bitunix may update the above list of third-party service providers from time to time in response to changes in products, services or compliance requirements.

5. Data Storage and Transfer

You acknowledge that your personal data and transaction data may be stored and processed in various jurisdictions in which Bitunix, its affiliates or its service providers operate.

We will implement reasonable physical, technical and organisational safeguards to protect your personal data in accordance with applicable laws and regulations.

Your personal data will generally be retained for as long as necessary to:

· Provide Bitunix services;

· Achieve the purposes described in this Privacy Policy;

· Comply with applicable legal and regulatory obligations;

· Resolve disputes;

· Establish, exercise or defend legal claims;

· Conduct audits;

· Maintain the security and integrity of the Platform; or achieve other legitimate business purposes.

You further acknowledge that, where permitted by applicable law, your personal data may be transferred in connection with a merger, acquisition, financing, corporate restructuring, bankruptcy, liquidation, asset sale or transfer of services to other service providers.

Bitunix will take reasonable measures to ensure that any such transfer complies with applicable law and that your personal data continues to receive an appropriate level of protection.

Retention and Cross-Border Processing for AI Features

Bitunix retains relevant inputs, analysis results, necessary metrics and records only for as long as necessary to provide AI features and access to analysis results, handle your requests, maintain security or fulfil legal obligations. Retention periods are determined by the purposes of processing, service needs and applicable law. Once the purposes have been fulfilled and no other lawful basis for retention exists, we will delete the relevant data or irreversibly anonymise it. Third-party retention of prompts and responses is subject to the restrictions in Section 4 and will not be extended indefinitely by the general retention purposes listed in this Section.

AI requests and responses may be processed outside your location by the above service providers and their authorised subcontractors. Before transfer, we will implement the cross-border safeguards required by applicable law, including applicable data processing agreements and standard contractual clauses, and comply with applicable notice or consent requirements. Your consent to use AI features does not replace our cross-border data protection obligations.

6. Use of Cookies

A. We use browser technology known as “Cookies”, which assigns a unique identifier (a small data file) to your computer, tablet, mobile phone or other device.

B. Information collected through Cookies enables us to record your preferences, improve your experience on the Platform, identify your device, provide relevant features and content, analyse Platform performance and help resolve access or technical issues.

C. You may block, reject or delete Cookies through your browser settings or browser extensions. However, choosing to do so may affect the availability or functionality of some Bitunix services.

D. Information collected through Cookies will be processed in accordance with this Privacy Policy.

7. Data Protection

A. We implement reasonable physical, technical and organisational security measures to protect the confidentiality, integrity and security of your personal data, including non-public personal data.

B. We have established appropriate access controls and administrative measures to ensure that only personnel authorised for legitimate business needs may access your personal data.

C. If you choose to access third-party websites or services through links provided on the Platform, you are responsible for reviewing the applicable privacy policies and terms and conditions of those third parties.

D. Although Bitunix has implemented reasonable security measures, no method of electronic transmission, storage or processing can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of any personal data you provide to us.

E. If you discover unauthorised access to your account or believe that your personal data, username, password or other authentication information has been compromised or stolen, you should notify Bitunix immediately at [email protected] so that we can take appropriate protective measures.

8. Disclaimer

To the fullest extent permitted by applicable law, Bitunix shall not be liable for:

A. Disclosure of your personal data due to unintentional or inadvertent circumstances, despite Bitunix having implemented reasonable security measures.

B. Disclosure of your personal data resulting from your disclosure of your Bitunix account credentials, password, authentication information or other security information to any third party.

C. Any loss arising from any third party’s theft, loss or unauthorised use of your account information, incidents affecting the security of your account, criminal conduct, malicious acts or other acts affecting the Platform, except where liability cannot be excluded under applicable law.

D. Any claims, proceedings, liabilities or damages arising from the collection, disclosure, processing or use of your personal data by any external or other third-party website that is not owned, operated or controlled by Bitunix.

9. External Websites

The Bitunix Platform may from time to time contain references or links to third-party websites, applications or services (“External Websites”).

Bitunix does not own, control or operate any External Websites and assumes no responsibility for their content, products, services or privacy practices.

External Websites have their own separate user agreements, privacy policies and other applicable policies.

We recommend that you review the applicable privacy policy and terms and conditions of an External Website before providing any personal data to it.

If you choose to use an External Website, you acknowledge that any collection, processing or use of your personal data by that External Website is governed solely by its own privacy policy and applicable terms.

10. Your Legal Rights

Depending on the laws applicable in your jurisdiction, you may have certain privacy rights in relation to your personal data.

You may contact us at [email protected] to exercise any applicable rights.

A. Right of Access

You may request confirmation as to whether Bitunix is processing your personal data and, if so, request access to the personal data we hold about you.

As Bitunix processes a large volume of data, we may ask you to specify the information or relevant processing activities you wish to access before responding to your request.

B. Right to Rectification

You may request that Bitunix correct or update any inaccurate, incomplete or outdated personal data.

C. Right to Erasure

Subject to applicable law, you may request that Bitunix delete your personal data in certain circumstances.

However, Bitunix may refuse such a request where retention is necessary to comply with legal obligations or regulatory requirements, resolve disputes, comply with law enforcement requests, establish or defend legal claims, or pursue other legitimate business purposes.

D. Right to Restriction of Processing

Where permitted by applicable law, you may request that Bitunix temporarily restrict the processing of certain categories of personal data so that we can verify their accuracy, assess the grounds for your objection or determine whether continued processing is appropriate.

E. Right to Data Portability

Where applicable law grants you this right, you may request that we provide certain personal data to you, or transfer it to another organisation, in a structured, commonly used and machine-readable format.

F. Right to Object

Where Bitunix processes your personal data on the basis of legitimate interests (or the legitimate interests of a third party), you may object to such processing where permitted by applicable law.

However, we may continue to process your personal data if Bitunix has compelling legitimate grounds for doing so, or if the processing is necessary for the establishment, exercise or defence of legal claims.

Where applicable, you also have the right to object to our use of your personal data for direct marketing purposes.

Where any of the above rights applies, it may still be subject to limitations, exemptions or exceptions under applicable law.

For example, if responding to your request would:

· Disclose another person’s personal data;

· Prejudice the rights of other persons or legal entities, including Bitunix;

· Prevent Bitunix from fulfilling applicable legal or regulatory obligations; or

· Adversely affect the prevention, detection or investigation of fraud, money laundering or other illegal activities;

Bitunix may refuse the request.

Where permitted by applicable law, if Bitunix refuses your request or restricts your rights, we will explain the relevant legal basis in our response.

11. Contact Us

If you have any questions about this Privacy Policy, your personal data or your privacy rights, or wish to exercise any rights granted to you under applicable law, please contact our customer support team:

Email: [email protected]

Disclaimer

This article is not intended to provide:

(i) investment advice or investment recommendations;

(ii) an offer, invitation, or solicitation to buy, sell, or hold digital assets;

(iii) financial, accounting, legal, or tax advice.

Digital assets, including stablecoins and NFTs, carry significant risk and price volatility. Evaluate whether trading or holding digital assets is appropriate for your financial situation. Seek guidance from your legal, tax, or investment adviser regarding your specific circumstances.

Bitunix assumes no responsibility for any investment outcomes. You are solely responsible for understanding and complying with all applicable local laws and regulations.