Hi AiPay Privacy Policy

HELLO DID YAZILIM SANAYİ VE TİCARET ANONİM ŞİRKETİ ("we," "our," or "us") respects and protects the privacy of users ("you" or "User"). When you use Hi AiPay ("ts Product" or "the Service"), we will collect and use your personal information in accordance with ts Privacy Policy ("ts Policy") and will maintain strict confidentiality regarding the personal information you provide.

We recommend that you carefully read and understand the entire content of ts Policy before using ts Product. Important information, including disclaimers, is ghlighted in bold. The definitions of key terms in ts Policy are consistent with our Hi AiPay Service Agreement.

We may update ts Policy online at any time. The updated policy, once published, will replace the previous version. If you do not accept the revised terms, please stop using Hi AiPay immediately. Your continued use of Hi AiPay will be deemed acceptance of the modified policy. The modified policy takes effect automatically upon publication on Hi AiPay. You acknowledge that ts Policy and other relevant regulations apply to Hi AiPay and the DApps independently owned by us on Hi AiPay.

1. Information We Collect

Please be aware that we collect your information to fulfill the purpose of meeting your service needs witn Hi AiPay, and we place great importance on protecting your privacy. When collecting your information, we strictly adhere to the principles of "legality, legitimacy, and necessity." You acknowledge that if you do not provide the relevant information required for our services, your service experience in Hi AiPay may be affected.

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

(1) Related to national security and national defense security;

(2) Related to public security, public health, and significant public interests;

(3) Related to criminal investigation, prosecution, trial, and execution of judgments, etc.;

(4) The personal information is disclosed by you to the public on your own initiative;

(5) Collecting your personal information from legally publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels;

(6) Necessary for maintaining the security and compliance of the services, such as discovering and handling product and service failures;

(7) Other circumstances stipulated by laws and regulations.

We collect information in the following ways:

1. Information You Actively Provide. For example, you provide an email address when reporting issues, or provide additional information to us when using specific services.

2. Information We Obtain During Your Use. Ts includes your mobile device information and your operation records on Hi AiPay, among other information.

3. How We Use Your Information

- We confirm the correspondence between you and your wallet through the unique serial number of your mobile device.

- We will send you important notices promptly, such as software updates, changes to the Service Agreement, and terms of ts Policy.

- We provide you with the "Fingerprint Login" option in the "System Settings" of Hi AiPay, allowing you to manage your digital tokens more conveniently and securely.

- We process the feedback you submit to us by collecting your public wallet address and provided mobile device information.

- We collect your personal information for internal auditing, data analysis, and research to continuously improve our service level.

- In accordance with the Hi AiPay Service Agreement and our other relevant regulations, we will manage and process user behavior using user information as necessary.

- To meet the requirements stipulated by laws and regulations and for cooperation with regulatory authorities.

4. How You Control Your Information

You have the following autonomous control rights over your personal information witn Hi AiPay:

1. You can import your other wallets into Hi AiPay by synchronizing wallets, or import your Hi AiPay wallet into other digital token management wallets.

2. Hi AiPay will display the information of the imported wallet. You acknowledge that you can manage your digital token types, conduct transfers, receive funds, and other activities through the "Assets" section.

You acknowledge that in the "Me" section of Hi AiPay, you can freely choose to perform the following operations:

1. In "Address Book," you can view, add, or delete your "Contacts" at any time;

2. In "System Settings," you can choose not to enable the "App Lock" option, meaning you can choose to enter Hi AiPay directly without using the verification service;

You acknowledge that when we collect information from you for specific purposes, we will notify you in advance, and you have the right to refuse. However, you also acknowledge that if you choose to refuse to provide relevant information, it may mean you cannot use the corresponding services of Hi AiPay.

You acknowledge that neither you nor we have control over whether your transaction records on the blockchain are public, because based on the open-source nature of the blockchain transaction system, your transaction records are transparent and public throughout the blockchain system.

You acknowledge that when you use Hi AiPay's features to redirect to trd-party DApps, our Hi AiPay Service Agreement and Hi AiPay Privacy Policy will no longer apply. Regarding your control over your personal information on trd-party DApps, we recommend that you read and understand their privacy rules and relevant user service agreements in detail before using trd-party DApps.

You have the right to request us to update, correct, or delete your relevant information. Simultaneously, you acknowledge that we may collect your information without obtaining your consent pursuant to circumstances such as those outlined in Article 1(6) of ts Policy and as stipulated by laws and regulations.

4. How We May Share or Transfer Your Information

We will store your personal information for business and legal purposes.

Without your prior consent, we will not sell, trade, or transfer your personal information to any trd party.

Except for the following situations:

1. It is necessary to share your information with trd parties in order to provide the services you have requested;

2. The personal information is disclosed by you to the public on your own initiative;

3. The personal information is collected from legally publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels;

4. Provision is required according to applicable laws, regulations, legal procedures, mandatory requirements of administrative or judicial authorities, or is reasonably necessary to execute ts Policy to protect the personal and property safety or legitimate rights and interests of us, our affiliates, other users, or employees;

5. In connection with mergers, divisions, acquisitions, asset transfers, or similar transactions, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by ts Policy; otherwise, we will require that company or organization to seek your authorization and consent again.

5. How We Protect Your Information

1. If we cease operations, we will promptly stop collecting your personal information, announce the cessation of operations on Hi AiPay, and delete or anonymize the personal information we hold witn a reasonable period.

2. To protect your personal information, we will adopt data security technical measures, enhance internal compliance levels, strengthen internal employee information security training, and set strict access permissions for relevant data, among other methods, to securely safeguard your private information.

3. We will push messages about information security in the Hi AiPay "Wallet Guide" and periodically update materials on wallet usage and information protection in the Hi AiPay "Wallet Guide" section for your reference.

6. Protection of Minors

We have established the following special provisions for the protection of minors under the age of 18:

1. Minors should use the services we provide under the guidance of their parents or guardians.

2. We recommend that the parents and guardians of minors read ts Policy, the Hi AiPay Service Agreement, and our other relevant rules before guiding minors to use Hi AiPay.

3. Hi AiPay will protect the confidentiality and security of minors' personal information in accordance with relevant national laws and regulations.

7. Disclaimer

1. Please note that after you access trd-party DApps through Hi AiPay, the privacy policy published by that trd-party DApp will apply. The collection and use of your personal information by such trd-party DApps is beyond our control and is not bound by ts Policy.

2. We cannot guarantee that any trd-party DApp will necessarily adopt personal information protection measures as required by us or by laws and regulations. You should prudently select and use trd-party DApps and properly protect your personal information. We are not responsible for the privacy protection practices of any trd-party DApp.

3. We will take reasonable security measures to protect your personal information to the extent possible given the current level of technology, to avoid leakage, alteration, or damage of information. However, as we use wireless networks to transmit data, we cannot ensure the absolute privacy and security of data transmitted via wireless networks.

8. Other

1. As the service provider, we will not proactively provide your personal information to trd parties outside the scope agreed in ts Policy, unless we obtain your consent. If service requirements necessitate the processing of your sensitive personal information, we will seek your explicit consent again separately.

2. If you are a user outside the jurisdiction of registration, you need to fully understand and comply with all laws, regulations, and rules related to using our services in your jurisdiction. We have appointed a dedicated Data Protection Officer/Department. If you encounter any issues regarding the use of personal information wle using our services, you can contact us by submitting feedback witn Hi AiPay, among other methods.

3. You can view ts Policy and our other service rules witn Hi AiPay at any time. We encourage you to review our Service Agreement and Privacy Policy each time you visit Hi AiPay. Any translated version of ts Policy is provided for the convenience of users only. If there is a conflict between the Cnese version and a non-Cnese version, the Cnese version shall prevail.

Ts Policy is effective from [03/10/2025].

For matters not covered in ts Policy, you shall abide by our periodically updated announcements and relevant rules.