TrustedUp Protocol Privacy and Policies...


1.1 This Privacy
Policy describes how Bullperks (BVI) Corp. (the “
Company“) collects, uses, processes, discloses,
shares, transfers, and protects the information you provide on the Bullperks
(BVI) Corp. website. This Privacy Policy constitutes a part of the Terms and
Conditions of the Company (“
TrustedUp“). The terms used in this Privacy Policy
shall share the same definition as those stipulated in the 
TrustedUp Protocol except for others indicated herein.

1.2 The Company
respects and values your privacy as well as the integrity of the information
you have provided and/or permitted the Company to collect. The Company will
endeavor to follow industry standards to ensure the security and
confidentiality of your Personal Information when you use the Company Services
or access the Company’s Platform.

1.3 When accessing,
registering, downloading, using, clicking, or engaging in any Services provided
on the Company’s Platform, you are strongly advised to carefully read,
acknowledge, understand, and accept all terms stipulated in this Privacy
Policy. The Company will not use your information, in any shape or form, for
any other purpose that has not been indicated in this Privacy Policy or the 
TrustedUp Protocol without providing you prior notification or
obtaining consent from you.

1.4 This Privacy
Policy has incorporated several provisions from the General Data Protection
Regulation (“
specifically following its Personal Information Processing rules within the
European Economic Area (EEA).

This Privacy Policy
shall inform you about the following matters among several others:

  • Acceptance of the Privacy
  • Personal Information collected
    by the Company
  • How the Company collects
    Personal Information
  • How the Company uses Personal
  • How the Company stores Personal
  • How long the Company retains
    Personal Information
  • Cookies
  • Sharing your Personal
  • Third-Party Collection of
    Personal Information
  • Your Legal Rights
  • Rights of the residents of the
    European Economic Area (EEA)
  • Limitations
  • Updates or amendments to the
    Privacy Policy
  • How to contact the Company

2. Acceptance of the Privacy Policy

By accessing, using,
or engaging in the Company’s Services, you indicate and confirm that you have
agreed to the terms of this Privacy Policy. The Company shall not use your
Personal Information for any other purpose that has not covered in this Privacy
Policy or the 
TrustedUp Protocol without providing you prior notification or obtaining your

If you do not agree,
either partially or wholly, to this Privacy Policy, you must immediately
discontinue accessing, using, or engaging in the Company’s Services and

3. Personal Information Collected

For the purposes of
this Privacy Policy, Personal Information is information that can be used to
identify, describe, relate, or associate with a particular individual. The
following are the types of information the Company collects and stores when you
use the Company’s Services:

3.1. Information provided
when registering with the Company

When you first sign up
to use the Company’s Services by opening an account on the Company’s website,
you may be required to provide the Company with your real name, date of birth,
nationality, home address, email address, signature, and other information
which can be used to distinguish your identity.  Generally, the Company
will not collect nor process “Sensitive Information” such as racial or ethnic
origin, political opinions, religious or philosophical beliefs, trade union
membership, genetic data, biometric data that uniquely identify specific
persons, or any information concerning health or sexual orientation. If you use
biometric authentication methods to sign into your account on the Company’s
website, you shall be required to provide the Company with your fingerprint
data, facial recognition data, and, more importantly, explicit consent to
process your biometric data.

3.2. Information collected
by the Company for Compliance and Anti-Money Laundering Purposes

To allow the Company
to comply with domestic and international industry standards, government rules
and regulations, particularly Anti-Money Laundering (AML) regulations, Know
Your Customer (KYC) rules, and Counter-Terrorist Financing (CTF) regulations,
the Company is required to collect your Personal Information from
identification documents such as your passport, national identification card,
driver’s license, tax identification, and visa. Other documents the Company may
use include, but are not limited to, your proof of the address, source of fund
declaration, purpose and source of wealth etc.

3.3. Information collected
by the Company during use the Company’s Services

(a) Usage
you engage or use the Company’s Services, the Company will monitor and track
your information in relation to your usage of the Company’s Services such as
your IP address, phone number, the type of device you use to access the
Company’s Platform, device information, operating system and hardware settings,
browser type, and network operator. This information shall either be directly
obtained by the Company or through third-party service providers.  The
Company collects this type of information to ensure that its interface and/or
Platform is seamlessly accessible for all users around the world.

(b) Communication
: You hereby agree
that the Company is entitled to collect and use the Personal Information you
have provided on the Company’s Platform or generated through your usage of the
Company’s Services for the purpose of being able to communicate with you
through messages, requests, emails, telephone conversions, voicemails, live
chats, file attachments in connection with your transactions on the Company’s
website or online platforms, or any other information related to your contact
with the Company.

(c) Financial Information: You hereby agree that, for the purposes
stipulated in this Privacy Policy, the Company is entitled to collect and use
the information contained in or related to your financial information when you
use the Company’s Services. This includes, without limitation, your transaction
history such as your initial deposit amount, your withdrawal requests, your
digital wallet address(es), your investment details etc. The Company collects
this financial information to monitor suspicious financial activities to
protect users from fraud, resolution of legal cases, as well as any other
purposes disclosed in this Privacy Policy.

4. Methods of Collection of Personal Information

4.1. Information
automatically collected by the Company
:  The Company will collect and process
Personal Information automatically provided by you under the following

(a) when you register
an account, log in, or visit the Company’s Website;

(b) when you
voluntarily complete any user survey or provide feedback to the Company via
emails or any other electronic channels;

(c) when you use
browser cookies or any other relevant software upon visiting the Company’s
Website; and

(d) other situations
where the Company may automatically collect your information as described in
this Privacy Policy or the Company’s 
Coins Drivers.

4.2. Information collected
by third-parties: 
The Company shall collect your Personal Information from third
parties as required or permitted to the extent of applicable laws. Information
from the third-party sources may include, but may not be limited to, public
databases, credit bureaus, ID verification partners, blockchain data, marketing
partners and resellers, advertising partners, and analytics providers.

4.3. Anonymized &
Aggregated Data: 
The Company will also collect other Information in the form of
anonymized and aggregated information where all information shall be combined
and then removed of personally identifiable information, making it unusable for
the identification of specific individuals. The Company may use anonymized or
aggregate users’ information for the purposes stipulated in this Privacy Policy
at any time, including gaining better understanding of users’ needs and
behaviors, conducting business intelligence and marketing initiatives, and
detecting security threats. The Company reserves the right to implement
innovative technologies as they become available to be used for strategic
planning and operational processes.

5. How the Company may use Personal Information

Your Personal Information
shall be made available to the Company, affiliates of the company, and/or
within the Company’s group of companies. This will include, but not be limited
to, the employees and/or any persons or third parties working for the Company
who are responsible for using and protecting your Personal Information. The
Company may use and process your Personal Information for the following
purposes or in the following ways:

5.1. To provide the
Company’s Services:
Company uses Personal information, either collected or delivered, in order to
maintain and provide efficient Services (including, but not limited to,
processing transactions), to improve the efficiency of day-to-day Services, and
to verify your identity. The Company uses IP addresses and unique identifiers
stored in your device’s cookies to help the Company authenticate your identity
and activities and provide the Company’s Services.

5.2. To protect users: The Company uses the information collected
to protect on the Company’s Platforms, Users’ accounts, and archives. The
Company also uses IP addresses and cookies to detect suspicious activities and
to protect against automated abuse such as spam, phishing, and Distributed
Denial of Service (“

5.3. To comply with
regulations and compliance for the Company’s legitimate interests
: The Company shall use the information in
compliance with the Company’s legal obligations, global and local industry
standards, government requests, and the Company’s AML/KYC/CTF procedures. In
the case where it is strictly necessary (i.e. to protect the vital interests of
the users or other natural persons, to fulfil the purpose of public interest,
or to pursue the Company’s reasonable interests), the Company may use and
process your Personal Information without obtaining your consent.

5.4. For measurement,
research and development purposes
: The Company actively measures and analyzes your information to
understand the way you use and interact with the Company’s Services. This
review is continuously conducted by the Company’s operation teams to
continuously improve the Company’s Platforms’ performance and to resolve issues
with user experience. In addition, the Company uses such information to
customize, measure, and improve the Company’s Services, administration, content
and Website layout, and to develop new services for you.

5.5. For communication
: The Company uses
your Personal Information, collected or derived from your communication devices
or your email address, to interact with you directly, to provide you with
necessary support, and/or to keep you informed of logins, transactions, account
security details, as well as other aspects. All direct communications shall be
appropriately maintained at by the Company, or the Company’s service providers,
to be reviewed for accuracy, retained as evidence, or used to perform other
statutory requirements or other obligations as stipulated in this Privacy
Policy and the 
TrustedUp Protocol.

5.6. To enforce T&Cs: Personal Information is also used to
continuously and actively enforce the Company’s 
TrustedUp Protocol among the Company’s users. Activities in this
regard include, but are not limited to, reviewing, investigating, and
preventing any potentially prohibited or illegal activities that may violate
preceding provisions, or disclose relevant information to third parties
accordingly. In light of this, the Company reserves the right to suspend or
terminate any of the Company’s Services to any Users found to be engaged in any
activities that violate the Company’s 
TrustedUp Protocol.

5.7. For marketing and
: The Company will
share your Personal Information with marketing partners for the purposes of
targeting, modelling, and/or identifying analytics as well as marketing and

5.8. For Rebates: The Company shall share the Personal
Information collected from you, including, but not limited to, your
Identification Information and Transaction Information, with your referrer for
the purposes of rebates and other benefits.

5.9. For other purposes: The Company shall not use your Personal
Information for purposes other than the purposes stipulated in this Privacy
Policy without your prior consent. If the Company needs to process or use your
Personal Information for other purposes, the Company shall notify and request
for your consent to use such information.

6. Storage of Personal Information

6.1 The Company shall
take great care in implementing and maintaining the security of its Services as
well as that of your Personal Information. The Company employs procedures and
policies that incorporate industry best practices to ensure the integrity of
your Personal Information and to prevent instances of unauthorized use. 

6.2 It is, of course,
impossible to fully guarantee the security of your Personal Information and
while the Company takes reasonable steps to safeguard your Personal
Information, it cannot be held responsible for the acts committed by those who
gain unauthorized access or abuse your information and services.  It is
therefore recommended that you independently take safety precautions to protect
your Personal Information, particularly your credential information such as
your username and password. You agree that the Company shall not be liable for
any information leakage and other losses not caused by the Company’s intention
or gross negligence, including, but not limited to, hacker attacks, power
interruptions, or unavoidable technical failures.

7. Retention of Personal Information

The Company is be
required by applicable laws and regulatory requirements to retain certain
information, including Personal Information of users, users’ profiles,
identification verification materials, information relevant to AML/KYC/CTF
procedures, account information, account agreements, and other agreements between
the Company and third-parties, account statements, and other records. 
Such records shall generally be retained as required by law for the minimum
amount of time necessary to accomplish the purpose for which it is collected;
and thereafter no longer than is permitted under the Company’s information
retention policy.  However, even after you deactivate your account, the
Company may retain copies of information about you and any transactions or
services which you may have participated in for a period of time that is
consistent with applicable laws, the applicable statute of limitations or as we
believe is reasonably necessary to comply with applicable laws, regulations,
legal procedures, or governmental requests in order to detect or prevent fraud,
collect fees owed, resolve disputes, address problems with the Company’s
Services, assist with investigations, enforce any of the Company’s 
TrustedUp Protocol and conditions or other applicable agreements
or policies, or to take any other actions consistent with applicable laws.

8. Cookies

8.1 The Company shall
use cookies and other technologies or methods of web analysis to gather, store,
and track certain information related with your access to and activities
through the Services, including when you visit the Company’s website.  

8.2 The term “cookie”,
as used herein, shall be deemed to be a small piece of information that a
website assigns to your device while you are viewing a website. Cookies are
beneficial and may be used for various purposes. including allowing you to
navigate between pages efficiently, enabling automatic activation of certain
features, remembering your preferences and making the interaction between you
and the Services quicker, easier and smoother. 

8.3 The Company’s
Website shall use the following types of cookies:

(a) Strictly Necessary
: These cookies are
essential to enable you to log in, navigate a website, and use its features or
to provide a service requested by you. The Company shall not need to obtain
your consent in order to use these cookies.

(b) Functionality Cookies: These cookies allow the Website to remember
choices you make (such as your username, language, or the region you reside in)
and provide enhanced, more personal features. The information these cookies
collect remains anonymous, and they cannot track your browsing activity on
other websites.

(c) Performance cookies: These cookies collect information about how
you use a website, for example, which pages you go to most often, record
difficulties you may experience while using the Website such as error messages.
All information collected by these cookies is aggregated and therefore
anonymous. It is only used to improve the efficiency of the Website.

(d) Targeting Cookies or
Advertising Cookies
These cookies are used to deliver advertisements tailored to you and your
interests specifically. They are also used to limit the number of times you see
an advertisement as well as help measure the effectiveness of the advertising
campaign. These cookies remember that you have visited a website, and this
information is shared with other organizations such as advertisers. It may be
the case that targeting or advertising cookies shall be linked to the sites
functionality provided by the other organizations.

8.4 You may remove
these cookies by following the instructions of your device preferences.
However, if you choose to disable cookies, some features of the Company’s
Services may not operate properly, and your online experience may be limited.

9. Sharing Personal Information

The Company shall not
rent, sell, or disclose your Personal Information to any third parties, except
to those who require access to the information to perform their tasks and
duties and to share with third parties who have a legitimate purpose for
accessing it. The Company may share, transfer, disclose, or allow access to
your Personal Information to the following third parties for the purposes
described below:

9.1. to third parties
in order to administer or process a transaction, or Services you have
authorized or requested, or in the context of facilitating the execution of a

9.2. to validate your
identities by applicable laws and regulatory requirements and rely on
third-party services to perform these validations. Personal Information that
you provide to Us during the account opening process is passed to these
services at account opening and on an ongoing basis thereafter;

9.3. as required by
applicable laws and regulatory requirements, to carry out or aid in certain
functions, such as, but not limited to, account processing, surveillance,
reconciliation, execution, document retention requirements, and document

9.4. with financial
institutions with which we partner to process payments which you have

9.5. analyses based on
anonymous user information or behavior with the Company’s affiliate companies
in order to operate and improve products and services;

9.6. disclose or
transfer information the Company collects to a purchaser of our business;

9.7. disclose or
transfer information the Company collects upon account closing where you have a
deficient balance, or upon excessive instances where you do not have sufficient
funds in your account;

9.8. for certain
promotions and special offers when the nature of the promotion or special offer
requires the Company to gather and share your Personal Information with a
third-party for delivery of goods or services. Should you choose to purchase a
product or service offered by a third party by way of a promotion or special
offer, any Personal Information you share with that third party would no longer
be governed by this Privacy Policy;

9.9. to third parties
that provide services, such as, but not limited to, consulting, sales, client
support operations, payment processing, authentication services, and technical
support or services;

9.10. with law
enforcement, and government officials, or other third parties when this Company
is compelled to do so by a subpoena, court order, or similar legal procedure,
or when the Company believes, in good faith, that the disclosure of Personal
Information is necessary to prevent physical harm or financial loss, to report
suspected illegal activity or to investigate violations of any of the Company’s
Coins Drivers or any other applicable policies;

9.11. disclose
information to third parties about your account or the transactions you make if
you give the Company your written permission;

9.12. other
circumstances under which the Company may disclose your Personal Information
include but is not limited to the following:

(a) comply, as
necessary, with applicable laws and regulatory requirements;

(b) respond to
mandatory legal or governmental requests or demands for information;

(c) meet national
security requirements;

(d) enforce Our
agreements, policies, procedures and/or 
TrustedUp Protocol;

(e) to protect the
Company, its affiliates, its users, its counterparties or the general public
from illegal activities; and

(f) to respond to an
emergency that requires disclosure of specified information. The Company will
not share your Personal Information with affiliates and the third parties for
their benefits unless you have given us your consent. However, you may freely
opt-out of having your Personal Information shared with third parties, or from
allowing the Company to use your Personal Information for any purpose that is
incompatible with the purposes for which the Company originally collected or
subsequently obtained your authorization as stipulated in this Privacy Policy.
All affiliates and third parties with whom the Company shares your Personal
Information have their privacy policies. However, they shall be expected to
protect this information in a manner that aligns with the provisions described
in this Privacy Policy.

10. Third-Party Collection of Personal Information

10.1 This Privacy
Policy only addresses the use and disclosure of the Personal Information the
Company collects from you. To the extent that you disclose your information to
other parties through the use of the Company’s Services such as by clicking on
a link to any other websites, different rules regarding Privacy Policies may
apply to their use or disclosure of the Personal Information you disclose to

10.2 You hereby
acknowledge that the Company shall not be responsible for the products, services,
or descriptions of products or services that you receive from the third-party
websites or to the content or privacy practices of those websites.

10.3 This Privacy
Policy shall not be applied to any such third-party products and services that
you access through the Company’s Platform. You are knowingly and voluntarily
assuming all risks of using third-party websites to purchase products and
services, and you agree that the Company shall have no liability whatsoever
concerning such third-party websites and your usage of them.

11. Your Legal Rights

Under certain
circumstances, you have the rights under the data protection laws in relation
to your Personal Information. These rights include the followings:

11.1. Right to be informed: You reserve the right to be informed about
the collection, use, and process of your Personal Information.

11.2. Right of access: You reserve the right to make a request for
a copy of the Personal Information We hold about you and specific information
regarding the Company’s processing of this information.

11.3. Right to rectify: You reserve the right to request the Company
to update, correct, or complete your Personal Information that you believe to
be outdated, inaccurate, or incomplete. You shall rectify at any time by signing
into your account with the Company and accessing the Profile function in order
to update accordingly.

11.4. Right to erasure: You may request to have your Personal
Information deleted from the Company’s record where certain conditions are met.
In order to deter fraudulent activities by ensuring that those who try to
commit fraud shall not be able to avoid detection simply by closing their
accounts and opening new accounts, the Company shall mark your account in its
database as “Closed,” but shall keep certain account information, including
your request to erase your Personal Information in our database for a period of
time. However, if you close your account, your Personal information shall not
be used by the Company for any further purposes, nor shared with third parties,
except as necessary to prevent fraud and to assist law enforcement as required
by law or in accordance with this Privacy Policy.

11.5. Right to data
: You reserve the
right to request to transfer a machine-readable copy of your Personal
Information to you or the third-party of your choice. The Company shall provide
you, or the third-party, your Personal Information in a machine-readable
format. This right only applies to Personal Information you have consented that
the Company use.

11.6. Right to restrict
: You may request the
Company to restrict or suppress the processing of your Personal Information
under certain circumstances as follows:

(a) to establish the
accuracy of the Personal Information;

(b) when the processing
is considered unlawful, but you do not wish to have your Personal Information

(c) where the Company
no longer need to process your Personal Information, but the information must
be retained for legal reasons; and

(d) where you have
objected to the Company processing your Personal Information, but it needs to
determine whether its legitimate interest overrides your objection.

11.7. Right to object: You may object to our reliance on the
Company’s legitimate interests as the basis of its processing of your Personal
Information that impacts your rights. You may also object to the Company’s
processing of your Personal Information for direct marketing purposes.

11.8. Right to withdraw
consent (“Opt-out”)
You reserve the right to withdraw your consent at any time where the Company is
relying on it to process your Personal Information. Withdrawing your consent
does not affect the lawfulness of the Company’s processing of your Personal
Information prior to withdrawing. If you wish to exercise these rights as
aforementioned, please inform and contact the Company via its Platform,
including the Company’s website.

12. Rights of the residents of the European Economic Area

12.1 If you are a
resident of the European Economic Area, United Kingdom, or Switzerland at the
time your Personal Information is collected, you still reserve every legal
right as stipulated in Clause 10 as mentioned above. 

12.2 The Company shall
specifically apply legal requirements under the General Data Protection Regulation
for collecting, using, or processing your Personal Information.  In the
case where some recipients are located outside the EEA, the Company shall
transfer your Personal Information only to such countries as approved by the
European Commission as providing an adequate level of data protection or enter
into legal agreements ensuring an adequate level of data protection in the
jurisdiction of the party receiving the information.

13. Limitation

13.1. The Company’s
Services are not designed for the individuals who are under the age of eighteen
or under the legal age to provide consent under the applicable laws of the
country or jurisdiction where you are using the Company’s Services. If you are
not over eighteen or of the legal age of your country, you shall not provide
any Personal Information to the Company, or to engage in the Company’s
Services. The Company reserves the right to access and verify any Personal
Information collected from you. If the Company is aware that you are under
eighteen or under the legal age who already shared your Personal Information
with the Company, it shall then discard such information and terminate your
account immediately.

13.2. The Company
cannot guarantee that any losses, misuses, unauthorized accession, or alteration
of your Personal Information shall not occur. You agree that you play a crucial
role in protecting your Personal Information, including your personal
credentials. When registering with the Company’s Services, you are strongly
advised to select a password with sufficient length and complexity and to not
reveal this password to any third parties, or unauthorized persons.  You
agree that you shall immediately notify the Company if you become aware that
unauthorized persons access your Company account.

14. Revisions to the Privacy Policy

The Company shall
revise and update this Privacy Policy periodically, in its sole discretion, and
the most current version shall be published on the Company’s website or the
Platform (as reflected in the “Last Revised” heading). In the event of any
material changes which may affect your usage on the Company’s Services and
Platform, We shall notify you through your email address or other communication
channels you provide to the Company. We encourage you to review this Privacy
Policy actively. If you do not agree, either partially or wholly, the revised
Privacy Policy, you must discontinue accessing or using the Company’s Services.
Your continued access to and use of the Company’s Services after any revisions
to this Privacy Policy constitutes your continuing consent to any such changes
and agreement to continue using the Services.

15. How to contact the Company

For any questions
regarding this Privacy Policy, your Personal Information collected or proceeded
by the Company, or in case you would like to exercise one of your legal privacy
rights as stipulated in Clause 10, please submit your requests to 
[email protected] and visit our the Company’s Website