1. Purpose and Scope of This Policy
1.1 Purpose of This Policy
This Privacy Policy explains how Smart Digital Assetd Inc. (hereinafter referred to as the “Company”) processes personal information in connection with the operation of its website and the provision of related services, as well as the rights available to users under applicable law. The Company processes personal information for specified purposes and limits such processing to what is necessary to fulfill those purposes.
1.2 Scope of Application
This Policy applies to websites operated by the Company that display or link to this Policy, as well as related services. Personal information processing activities may vary depending on the functions involved and shall be determined based on the functions actually used by users and the corresponding privacy notices. The display of a particular function on the website does not, by itself, indicate that personal information associated with that function has been collected.
1.3 Definitions
“User” refers to an individual who accesses the website or uses related services. “Personal Information” refers to information that directly or indirectly identifies an individual, or that otherwise qualifies as personal data under applicable law. “Processing” includes activities such as collecting, using, storing, disclosing, and deleting personal information.
1.4 Relationship to Other Documents
This Policy and the Terms of Service separately address the rules governing personal information processing and the conditions for using the services. Where a specific function requires additional notice or separate consent, the Company shall complete the applicable procedures before the relevant processing takes place. Browsing the website does not constitute blanket consent to all personal information processing activities, and nothing in this Policy limits the rights users are entitled to exercise under applicable law.
2. Categories and Sources of Personal Information
2.1 Information Provided Directly by Users
When users submit inquiries, complete forms, or use related functions through the website, the Company may process information voluntarily provided by users, including information requested in the applicable forms and content submitted by users. The Company shall clearly explain the purposes of collection, distinguish required information from optional information, and shall not require users to provide information unrelated to the matter at hand.
2.2 Information Generated Through Website Operations
Website operations may involve the processing of Internet Protocol (IP) addresses, browser types, device information, access times, page access records, and error logs. The Company processes such information only to the extent necessary for website operations, troubleshooting, and identifying unusual access activity. The Company shall provide applicable notices regarding such processing and shall not use operational records for other purposes that have not been disclosed or that lack a lawful basis.
2.3 Information Related to Specific Functions
When users access accounts or other functions that are actually available, the Company processes only the information necessary to complete the relevant activities and shall explain the categories, purposes, and necessity of such information on the applicable pages. Descriptions of functions or their display on the website do not, by themselves, constitute user consent to provide personal information or authorization for the Company to engage in additional processing activities.
2.4 Information Obtained From Other Sources
When obtaining personal information from third parties, the Company shall verify the source and applicable legal basis for processing, confirm the permitted scope of use, and fulfill any notification obligations required by law. Publicly available information may remain subject to personal information protection requirements and shall not be used without appropriate restrictions merely because it is publicly accessible.
3. Purposes and Legal Bases for Processing
3.1 Responding to Requests and Providing Services
The Company may use personal information to the extent necessary to respond to user inquiries, process matters submitted by users, or provide functions that users have actually requested. The information collected shall correspond to specific purposes, and a single inquiry shall not be treated as consent to receive ongoing marketing communications.
3.2 Website Maintenance and Incident Management
To troubleshoot technical issues, identify unusual access activity, and prevent misuse of the website, the Company may process necessary operational records in accordance with applicable law. Such processing shall be limited to authorized purposes and access permissions. Information required for website maintenance shall not automatically be repurposed for advertising or other unrelated activities.
3.3 Legal Obligations and Dispute Resolution
The Company may process personal information as required by applicable law to comply with legal obligations, respond to valid legal proceedings, or address specific disputes. The scope of processing and retention periods shall be proportionate to the actual requirements of the relevant matter.
3.4 Legal Bases and Changes in Processing Purposes
The Company shall identify the applicable legal basis for each processing activity, which may include lawfully obtained consent, necessity for the performance of a contract, compliance with legal obligations, or other grounds permitted by law. Where processing relies on legitimate interests, the Company shall assess the potential impact on users’ rights and interests as required by applicable law. If the purposes of processing change, the Company shall reassess the applicable legal basis and provide supplemental notice or obtain any required consent in accordance with the law.
4. Cookies and Similar Technologies
4.1 Purposes and Scope of Disclosure
If the website uses cookies, local storage, or similar technologies, the Company shall disclose their categories, purposes, duration, and providers in the relevant notices. Such technologies may be used to maintain sessions, remember user preferences, or understand website usage. The specific purposes shall be governed by the corresponding disclosures.
4.2 Essential and Optional Technologies
Technologies necessary for the basic operation of the website shall be managed separately from optional technologies used for analytics, personalization, or advertising. Essential technologies shall be limited to those required to provide basic functions requested by users. A technology shall not be classified as essential merely because it supports business operations. Appropriate choices shall be provided for optional technologies in accordance with applicable requirements.
4.3 User Choices and Management
Where prior consent is required by law, the Company shall activate the relevant technologies only after obtaining valid consent and shall provide applicable methods for refusing or withdrawing consent. Users may also manage related settings through their browsers. Restricting certain technologies may affect the corresponding functions but should not prevent access to unrelated basic functions.
4.4 Third-Party Technologies and Information Processing
If the website deploys third-party analytics tools, embedded content, or plugins, the Company shall identify the relevant providers, the purposes of information processing, and the applicable rules. The involvement of third parties does not relieve the Company of its responsibilities concerning its own deployment of such technologies or disclosure of information, nor does it authorize unrestricted collection of information by third parties.
5. Information Sharing, Service Providers, and Disclosure
5.1 Processing by Service Providers
When the Company engages website hosting providers, technical maintenance providers, or other service providers to process personal information on its behalf, it shall define the authorized purposes, categories of information, and duration of processing. Appropriate agreements shall establish requirements concerning confidentiality, protection, and deletion. Service providers shall not use personal information for unrelated purposes of their own beyond the scope of their authorization.
5.2 Disclosure to Independent Parties
Where personal information must be disclosed to another party that independently determines the purposes and methods of processing, the Company shall identify the recipient, purpose of disclosure, categories of information, and applicable legal basis, and shall provide notice or obtain any required consent in accordance with the law. The existence of a business relationship alone does not constitute sufficient grounds for sharing users’ personal information.
5.3 Disclosures Required by Law
The Company may respond to valid legal proceedings or lawful requests from competent authorities in accordance with applicable law. Before making a disclosure, the Company shall verify the legal basis and scope of the request and disclose only the information legally required. Where permitted and required by law, the Company shall provide the relevant notifications.
5.4 Processing in Connection With Corporate Transactions
In the event of a merger, acquisition, restructuring, or transfer of business involving personal information, the Company shall disclose relevant changes as required by law and require the receiving party to comply with applicable information protection obligations. If the purposes or methods of processing change, the Company shall complete any additional procedures required by law.
5.5 Sale of Personal Information and Advertising-Related Sharing
The Company shall not treat a user’s acceptance of this Policy as consent to the sale of personal information, advertising-related sharing, or targeted advertising. Before engaging in such activities, the Company shall disclose the relevant categories of information, recipients, and purposes as required by law, and provide applicable opt-out or restriction mechanisms. Where consent is legally required, the Company shall obtain valid consent in advance.
6. Data Retention, Deletion, and Anonymization
6.1 Data Retention Principles
The Company retains personal information only for as long as necessary to fulfill the purposes previously disclosed, except where continued retention is required or permitted by law. In determining appropriate retention periods, the Company shall consider the nature of the information, purposes of use, service relationships, dispute resolution requirements, and applicable legal obligations. Personal information shall not be retained indefinitely solely because it may be useful in the future.
6.2 Retention Arrangements by Information Category
Information submitted through inquiries shall be retained only for the period necessary to address the relevant requests and any necessary follow-up matters. Account information shall be retained based on the duration of the service relationship, necessary processing following account closure, and applicable legal requirements. Website access logs shall be retained only for the period necessary for operational maintenance, investigation of unusual activity, and compliance with applicable requirements. Once the relevant processing purposes have been fulfilled, the Company shall assess whether continued retention is necessary and delete or anonymize information that is no longer required.
6.3 Deletion and Anonymization
When the conditions for deletion are met, the Company shall delete the relevant personal information or anonymize it in a manner that prevents identification of individuals and does not permit the restoration of identifying associations. Merely removing names, replacing identifiers, or applying other de-identification techniques does not necessarily mean that the information has been anonymized.
6.4 Legally Required Retention and Backup Management
Where personal information must be retained due to legal obligations, valid disputes, or other lawful reasons, its use and accessibility shall be restricted. Once the grounds for retention no longer apply, the information shall be handled accordingly. Information contained in backups may be deleted according to reasonable backup update cycles. If previously deleted information reappears during a restoration process, the Company shall reapply the relevant deletion or restriction measures.
7. Information Security and Incident Response
7.1 Security Measures
The Company adopts appropriate technical and organizational measures based on the nature of the information, the scale of processing, and the potential impact of security incidents. These measures shall be evaluated and adjusted as necessary. No security measure can eliminate every information security risk. The Company does not guarantee that personal information will never be disclosed, lost, or accessed without authorization, and this acknowledgment does not limit or relieve the Company of its responsibilities under applicable law.
7.2 Access Controls and Personnel Management
Access to personal information shall be limited to personnel who require such access to perform their assigned responsibilities. Access permissions shall be granted and adjusted according to operational needs. The Company shall impose confidentiality requirements on relevant personnel and promptly adjust access arrangements when job responsibilities change or authorization ends, thereby reducing unnecessary exposure to personal information.
7.3 Incident Investigation and Remediation
Upon identifying a suspected incident involving the disclosure, loss, alteration, or unauthorized access of personal information, the Company shall promptly assess the nature of the incident, its potential impact, and the information involved. The Company shall implement appropriate measures to contain the impact, preserve necessary records, and undertake remedial actions.
7.4 Notification and Accountability
When an incident meets the notification requirements established by applicable law, the Company shall notify the relevant authorities and affected individuals within the legally prescribed timeframes. Such notifications shall describe the known impacts, measures taken, and applicable recommendations. The inherent uncertainties of the online environment do not relieve the Company of its legal responsibilities concerning information protection and incident response.
8. User Rights and Request Handling
8.1 Access, Correction, and Copies of Personal Information
Subject to applicable law, users may request confirmation of whether the Company processes their personal information, access relevant information and details regarding its processing, and request correction of inaccurate or incomplete information. Where provided by law, users may also request copies of their personal information or receive relevant information in an applicable format.
8.2 Deletion, Restriction, and Objection to Processing
Users may request the deletion of their personal information, restriction of certain processing activities, or object to processing based on specified legal grounds, subject to applicable law. Where legal retention obligations or other lawful exceptions apply, the Company shall explain the relevant grounds and limit any continued processing to what is necessary.
8.3 Withdrawal of Consent and Opt-Out Choices
Where processing is based on consent, users may withdraw that consent in accordance with applicable law. Withdrawal of consent does not affect the lawfulness of processing activities previously carried out on the basis of valid consent. Refusing or withdrawing authorization for nonessential processing shall not affect access to basic functions unrelated to that authorization.
8.4 Request Verification and Response Procedures
Users may submit requests through the personal information rights request channels published by the Company. The Company shall process requests within the applicable legal timeframes and conduct identity verification as necessary, taking into account the nature of the request and the information involved. The Company shall not collect information unrelated to the verification process. Where an extension is necessary, a fee is lawfully permitted, or a request cannot be fulfilled, the Company shall explain the applicable conditions, reasons, and available follow-up procedures.
8.5 Appeals and Non-Discrimination
Where a request is denied, the Company shall explain the reasons and available appeal procedures to the extent required by law. Users retain the right to submit complaints to the relevant supervisory authorities in accordance with applicable law. The Company shall not subject users to improper discriminatory treatment for exercising their lawful personal information rights.
9. Cross-Border Processing, Minors, and Third-Party Services
9.1 Cross-Border Processing Activities
If personal information is transferred outside the jurisdiction in which it was collected or accessed by personnel located in another jurisdiction due to website hosting, technical support, or other actual operational arrangements, the Company shall disclose the relevant circumstances, processing purposes, and categories of information in accordance with applicable law. This Policy does not replace any specific disclosures that may be legally required.
9.2 Conditions for Cross-Border Protection
Cross-border processing shall comply with the requirements of applicable law. Depending on the circumstances, the Company shall implement the appropriate legal mechanisms for international transfers and corresponding protective measures. Where separate consent, assessments, or other procedures are required by law, the Company shall complete those requirements before processing begins. Accessing the website does not constitute blanket authorization for all cross-border processing activities.
9.3 Personal Information of Minors
Functions subject to age restrictions shall clearly state the applicable requirements before use. Where parental or legal guardian consent or additional protective procedures are required, the Company shall comply with those obligations. If the Company discovers that it has collected personal information from a minor without satisfying the applicable legal conditions, it shall promptly investigate and take appropriate measures, including deletion, restriction of processing, or other necessary actions.
9.4 External Links and Independent Services
External links and third-party services available through the website may be governed by separate privacy policies. Users may review the relevant disclosures before accessing such services. The Company remains responsible for its own activities involving the deployment of third-party tools, disclosure of information, and related processing to the extent required by law. Third-party involvement does not relieve the Company of its applicable obligations.
10. Policy Updates and Supplemental Rules
10.1 Reasons for Updates and Version Information
The Company may revise this Policy in response to changes in its actual services, personal information processing activities, or applicable requirements. The effective date and date of the most recent update shall be identified upon publication. Updates to this Policy do not constitute automatic authorization for new processing activities and do not alter the Company’s legal responsibilities for processing activities conducted before the updates.
10.2 Notice of Material Changes
Where material changes affect the categories of personal information collected, purposes of processing, scope of recipients, or user rights, the Company shall provide appropriate notice in accordance with applicable law. Where advance notice is required, the Company shall provide an explanation before implementing the changes. Updates made without adequate visibility shall not replace legally required notifications.
10.3 Processing Following Policy Changes
Revisions to this Policy do not, by themselves, constitute user consent to additional processing activities. Where changes require new consent or other legally mandated procedures, the Company shall complete the necessary steps before initiating the relevant activities. Continued browsing of the website shall not automatically be treated as acceptance of all changes.
10.4 Jurisdiction-Specific Supplemental Rules and Reservation of Rights
Personal information protection requirements may vary across jurisdictions. The Company shall provide supplemental disclosures based on the laws actually applicable to its activities. If any provision of this Policy conflicts with mandatory legal requirements, the applicable requirements shall prevail. Nothing in this Policy shall be interpreted as excluding or waiving any rights that users are legally entitled to exercise and that cannot be waived.
11. Contact Us
11.1 Company Information
The Company responsible for this Privacy Policy and its contact information are as follows:
Company Name: Smart Digital Assetd Inc.
Company Address: 45 Broadway, New York, NY 10006, USA
Contact Email: [email protected]
11.2 Privacy Inquiries and Rights Requests
If you have questions regarding this Privacy Policy or the Company’s handling of personal information, or if you wish to request access to, correction of, or deletion of your personal information, withdraw consent, or exercise other applicable rights, you may submit a request through the email address provided above. Please include a description of the relevant matter and the specific action requested.
11.3 Identity Verification and Request Processing
The Company shall conduct necessary verification based on the nature of the request and the information involved. You will not be required to provide information unrelated to your request. Please do not submit account passwords, verification codes, or other unnecessary sensitive information. The Company shall process requests within the timeframes prescribed by applicable law. Where an extension is necessary or a request cannot be fulfilled, the Company shall explain the reasons and available follow-up procedures. Contacting the Company does not affect your right to file complaints, pursue appeals, or seek other remedies available under applicable law.