Privacy Policy

1. Introduction

This Privacy Policy sets out how AULINK TECH LIMITED ("we", "us", "our") collects, uses, stores, discloses and protects personal data obtained from clients, business partners, platform users, website visitors and individuals who use our services, including blockchain infrastructure services, RWA (Real World Asset) platform development, system customization, and KYC verification services integrated with Sumsub.

This Policy complies with the Personal Data (Privacy) Ordinance of Hong Kong (PDPO), the General Data Protection Regulation (GDPR), and applicable global data protection and anti-money laundering (AML) regulations. This Policy applies to all our websites, platforms, business services, and KYC identity verification processes provided via Sumsub.

2. Personal Data We Collect

We may collect the following categories of personal information when you register an account, cooperate with our business, use our blockchain and RWA platform services, or complete KYC verification through Sumsub:

• Identity information: full name, date of birth, nationality, identity document, passport, business registration documents of corporate clients.
• Contact information: email address, mobile phone number, residential and business address.
• KYC related data: identity verification materials, selfie photos, proof of address, corporate shareholder and director information collected for compliance and AML review via Sumsub.
• Platform usage data: IP address, device information, browser type, operating system, access time, browsing records, operation logs on blockchain and RWA platforms.
• Business transaction data: service cooperation records, platform operation records, asset interaction records generated on our RWA and blockchain systems.

3. Purpose of Using Personal Data

We use collected personal data for the following legitimate purposes:

• To provide, maintain and optimize our blockchain infrastructure, RWA platform construction and related technical services.
• To conduct KYC identity verification, anti-money laundering (AML) and counter-terrorism financing compliance review through Sumsub.
• To verify user identity, protect account security, prevent fraud, abnormal transactions and network risks.
• To perform business contracts, provide customer support, technical maintenance and after-sales services.
• To comply with legal obligations, regulatory requirements, court orders and government official inquiries.
• To improve product iteration, platform function optimization and service experience analysis.
• To send necessary service notifications and compliance reminders (we will not send commercial marketing messages without your explicit consent).

4. Sharing and Disclosure of Personal Data

We will not sell, rent or trade your personal data to unauthorized third parties for commercial purposes. We may share your data only under the following circumstances:

• With authorized service providers including Sumsub, who provide KYC verification, technical support, cloud server, security and compliance services, and are bound by strict data protection obligations.
• With regulatory authorities, law enforcement agencies, courts or government departments as required by applicable laws and regulations.
• Within our corporate group affiliates for internal compliance management and service coordination.
• In the event of corporate merger, acquisition or asset restructuring, where personal data will still be protected by this Privacy Policy.

5. Data Storage and Cross-border Transmission

Your personal data may be stored and processed in Hong Kong or other jurisdictions where our service providers (including Sumsub) operate. Cross-border data transmission will be conducted in compliance with Hong Kong PDPO, GDPR and relevant legal requirements. We will adopt adequate technical and contractual measures to ensure the security and confidentiality of cross-border personal data.

We will retain your personal data only for the period necessary to fulfill the collection purpose, comply with legal retention requirements, and resolve potential legal disputes. After the retention period expires, we will securely delete or anonymize your data.

6. Use of Cookies

Our website and platform use Cookies and similar tracking technologies to record access habits, optimize page experience, maintain login status and analyze traffic data. You can disable Cookies through your browser settings. Please note that disabling Cookies may affect the normal use of some functions of our website and platform.

7. Data Security Protection

We adopt industry-standard encryption technology, access permission control, physical security measures and internal management rules to protect your personal data from unauthorized access, disclosure, tampering, loss and leakage. Meanwhile, we require third-party service providers such as Sumsub to maintain equivalent data security protection standards.

8. Your Rights

In accordance with Hong Kong PDPO, GDPR and applicable laws, you have the following rights:

• The right to access and obtain a copy of your personal data held by us.
• The right to rectify inaccurate or incomplete personal data.
• The right to request deletion of your personal data within legal scope.
• The right to restrict the processing of your personal data.
• The right to withdraw consent for data processing at any time.
• The right to lodge a complaint with local data protection regulatory authorities.

9. Voluntary Provision of Data

The provision of your personal data is voluntary. However, if you refuse to provide necessary identity and KYC information, we may not be able to complete identity verification, provide blockchain and RWA platform services, or perform business cooperation agreements.

10. Policy Updates

We reserve the right to update this Privacy Policy from time to time in response to business adjustments, regulatory changes and service upgrades. The updated Policy will be published on our official website. Your continued use of our services after the update constitutes acceptance of the revised Privacy Policy.

11. Contact Us

If you have any inquiries, objections or requests regarding this Privacy Policy, personal data processing and Sumsub KYC related data matters, please contact us:

Company Name: AULINK TECH LIMITED
Business Registration No.: 78673275-000-08-25-7
Location: Hong Kong