Privacy Policy

Updated: December 18, 2025

Effective Date: December 18, 2025

Your trust is very important to us. We understand the importance of your personal information and will take corresponding security measures in accordance with laws and regulations to protect your personal information security and controllability to the best of our ability. As a service provider (hereinafter referred to as "we"), MUFIN LIMITED have formulated this Privacy Policy (hereinafter referred to as "this Policy") and remind you:

This Policy applies to your use of our products and services in any way. Before using our products or services, please be sure to carefully read and thoroughly understand this Policy, and use the relevant products or services only after confirming that you fully understand and agree to it. Once you start using our products or services, it means that you have fully understood and agreed to this Policy. If our affiliated companies' products or services use products or services provided by us but do not have a separate privacy policy, this Policy also applies to those products or services.

Unless otherwise specified by applicable laws in your region, "personal information" under this policy refers to various information recorded electronically or otherwise relating to an identified or identifiable natural person, excluding anonymized information. We will comply with this policy in using this information.

If you have any questions, comments, or suggestions regarding the content of this policy, please contact us using the contact information provided in this policy.

This Privacy Policy will help you understand the following:

I. How We Collect and Use Your Personal Information
II. How We Use Cookies and Similar Technologies
III. How We Share, Transfer, and Publicly Disclose Your Personal Information
IV. How We Protect Your Personal Information
V. How We Store Information
VI. Your Right to Manage Your Information
VII. How Your Personal Information Is Transferred Globally
VIII. Information We May Send You
IX. Information You Share
X. How This Policy Is Updated
XI. Scope of Application of This Policy
XII. How to Contact Us

I. How We Collect Your Personal Information

1. In order to provide you with the basic functions of our products and services, you need to authorize us to collect and use necessary information; if you refuse to provide such necessary information, you will not be able to use our products and services normally.
2. If you refuse our collection of any of your personal information, we will not be able to provide you with the complete basic service functions of this platform. In this case, we will provide you with a "Browse Only" mode to help you experience some of the platform's basic service functions before deciding to accept this privacy policy. This involves browsing some content, which generally consists of information and content generated based on other users' consent to this privacy policy.
3. To provide you with extended functionality of our services and products, you may choose to authorize us to collect and use information beyond what is necessary to achieve basic functions. If you refuse to provide such information, you will not be able to use the related additional functions or achieve the intended functional effects, but this will not affect your use of the basic functions of our products and services.
4. If a piece of information cannot identify you personally, either alone or in combination with other information, then that information does not constitute your personal information in the legal sense. When the information we possess can objectively identify you personally in combination with other information, even if we do not intend or cannot ultimately identify you personally by obtaining or combining any other information, this information will be processed and protected as your personal information in accordance with this policy during its use.
5. The functions and services we provide are constantly being updated and developed. If a function or service collects your information that is not described below, we will separately explain the content, scope, and purpose of the information collection to you through page prompts, interactive processes, website announcements, etc.
6. The information you provide may contain your sensitive personal information. Sensitive personal information is personal information that, if leaked or illegally used, could easily lead to infringement of a natural person's personal dignity or endanger their personal or property safety. This includes biometric information (such as facial information, fingerprint information, iris information), religious beliefs, specific identities, medical and health information (such as heart rate information, disease information, medical treatment information), financial account information (such as financial account, transaction password), location tracking information, and personal information of minors under the age of fourteen. Please be cautious and attentive to sensitive personal information. You agree that we may process your sensitive personal information in accordance with the purposes and methods described in this policy.
7. We highly value your data subject rights and provide you with convenient access points so you can quickly and easily withdraw your authorization to use your information, or make changes or modifications to that information.

Principles for Collecting and Using Personal Information

When collecting and using your personal information, we always adhere to and abide by the following principles: consistency of rights and responsibilities, clear purpose, choice and consent, minimum necessity, security, subject participation, and transparency.

1.2 Purpose of Our Collection and Use of Personal Information

To comply with the relevant laws and regulations, and to provide you with services and ensure the security of your account and system operation, and to optimize our service experience, we collect information that you voluntarily provide, authorize to provide, or provide at your request when registering and using our products and services, as well as information generated based on your use of our products and services, for the purposes and methods described in this policy:

1.2.1 Registration, Login, and Authentication

(1) When you register or log in to our products or services, you can create an account using your mobile phone number (during this process, we will send a verification code to your mobile device via SMS), and you can complete relevant online identity information (avatar, nickname, password). The collection of the aforementioned information is to help you complete account registration. You can also choose to submit your email address, gender, birthday, region, personal profile, and bind a third-party account to complete your personal information according to your needs.

(2) You may also register, log in, and use our products or services using third-party accounts, such as your Google or Apple account. You will authorize us to obtain your publicly available information (avatar, nickname) registered on the third-party platform for binding with your company account, allowing you to directly log in and use our products and services. Unless you choose to do so or comply with relevant laws and regulations, we will not provide the aforementioned information to any third party, nor will we use it for any purpose other than this function.

(3) When you use facial recognition information to unlock or log in to our company account, we will request your facial unlock permission for identity verification. If you refuse to provide this permission, you will not be able to use the relevant services, but this will not affect the normal use of other functions and services.

(4) When you choose to log in to our company account using a verification code, we will request the use of your device's SMS sending function. Sending SMS messages may incur SMS charges, which are collected by the mobile network operator; we do not charge any SMS fees. If you refuse to send SMS messages, you will not be able to use the verification code login function, but you can still choose to use other login methods.

(5) Please note that if you refuse to provide any personal information, you will only be able to use the "Browse Only" or "Unavailable" mode, and we will not be able to provide you with our complete basic service functions.

1.2.2 Account Security and Identity Verification

(1) When you reset the mobile phone number bound to your account with our company, we will assess the security level of your account and verify your identity if necessary. If you choose facial recognition for identity verification, our company will request to use the device's camera function and collect your facial information, but we will not store your facial information. If you choose to upload your ID for identity verification, our company will request to use the device's camera function and collect your ID information. The aforementioned personal information is only used for identity verification. If you do not agree to the above, you will not be able to use the relevant functions for identity verification, and therefore will not be able to reset your mobile phone number, but this will not affect your use of other services provided by our company.

(2) When you use account services such as password retrieval and modification, unbinding, and account cancellation, we need to verify your personal information, mainly including identity information, device information, security status, and account information. This is based on the need to protect your account security.

1.2.3 Browsing and Searching Market Information

(1) When you use the reminder or major event preview function of our company's market information system, we will request to use the device's calendar permission so that you can obtain relevant information in a timely manner. If you refuse access, you will not be able to use the notification function, but this will not affect your use of other services provided by our company.

(2) When you browse or search for market information on our website, we will collect information generated during your access and use, such as clicks, browsing, following, favorites, searches, queries, and sharing.

(3) To ensure that you can normally receive and use relevant market information rights and services, we will use your mobile phone number and IP address for regional or account validity identification. If you do not agree to the above, it may affect the determination of regional or account validity, thereby affecting your receipt and use of relevant market information rights and services.

(4) We provide you with basic market information services to meet your trading needs. When you need more professional market information services, based on the compliance requirements of the professional market information provider, you may be required to provide additional personal information, which may include your name, contact number, residential address and postal code, email address, occupation, position, or workplace address. We remind you to be cautious when providing such information, and we will also obtain your separate consent before assisting in providing such professional market information services.

1.2.4 Account Opening and Investment

(1) When you access the brokerage account opening function through our company's account, we will request access to your device's camera and microphone. If you refuse to provide camera and microphone access, the account opening process will not be completed normally.

(2) You may choose to have the corresponding brokerage directly collect the personal information required for account opening from you. According to relevant securities laws and regulations and brokerage account opening rules, such information includes photos of the front and back of your ID document, a passport photo, a video (one-way or two-way) proving your real-name account opening and intention to open an account, as well as your mailing address, your workplace, and your job title. The collection of the aforementioned information is the sole responsibility of the designated brokerage and is not related to us. You must carefully read and agree to the rules or policies of the brokerage regarding information collection before submitting the aforementioned information. If you do not agree to the above, you will not be able to use the account opening function, but this will not affect your use of other services provided by our company.

1.2.5 Community Interaction

(1) When you use the profile picture editing function of our account and post comments or photos, if you choose to use the "take a picture" or "capture" method, we will request the use of the device's camera permission; if you choose to use the "select from album" method, we will request the use of the device's photo permission; if you choose to save the pictures found in the comments to your album, we will not request the use of the device's photo permission.

(2) When you choose to use the online customer service function, we will request the use of the device's microphone permission during communication.

1.2.6 User Service

If you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure your account security. To provide services according to your needs, with your authorization, customer service needs to query or verify your relevant information within the scope of your authorization. We will take technical and management measures to protect your information security and confidentiality as much as possible, and use it within the necessary scope. We may also save your contact information, your communication records and content with us, and other necessary information to provide and record customer service.

1.2.7 Secure Operation

To ensure your normal use of our services, the security of your account, and to identify abnormal account status, we will collect log information generated during your use of our services and associate this information.

II. How We Use Cookies and Similar Technologies

2.1 Cookies

To provide you with a more convenient access experience, when you use our products or services, we may collect and store relevant data about your access to our services using various technologies. When you access or revisit our services, we can identify you and provide you with better and more services by analyzing the data, including using small data files to identify you. This is done to understand your usage habits, save you the step of repeatedly entering account information, or help determine your account security. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (collectively, "Cookies"). We will not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences. For details, please see AboutCookies.org. You can clear all cookies stored on your computer; most web browsers have a function to block cookies. However, if you do this, you may be unable to use certain features of our services that rely on cookies in some situations, and you will need to manually change your user settings each time you visit our website.

2.2 Web Beacons and Pixel Tags

In addition to cookies, we may also use other similar technologies on our website, such as web beacons and pixel tags. For example, emails we send you may contain click-through URLs linking to content on our website. If you click on such a link, we will track this click to help us understand your product or service preferences and improve customer service. Web beacons are typically transparent images embedded in a website or email. Pixel tags in emails allow us to know whether an email has been opened.

2.3 Do Not Track

Many web browsers have a Do Not Track feature, which sends a Do Not Track request to websites. Currently, major internet standards organizations have not established policies on how websites should respond to such requests. However, if your browser has Do Not Track enabled, we will respect your choice.

III. How We Share, Transfer, and Publicly Disclose Your Personal Information

3.1 Sharing

Unless otherwise stated below or you consent to us sharing your personal information with third parties, we will not transfer your personal information to third parties. If a third party undergoes a merger, acquisition, reorganization, or sale, or for legal or other reasons, we will transfer your information to such entities to continue providing services to you. In such cases, we will always require the relevant third party to comply with this Privacy Policy.

We will only share your information with selected third parties when reasonably necessary, including:

3.1.1 Our Affiliates

Your personal information may be shared with our subsidiaries and affiliates, who may only use your personal information in accordance with this Privacy Policy. If the purpose of processing personal information needs to be changed, we will separately seek your authorization and consent.

3.1.2 Service Providers

Some of our services will be provided by service providers solely for the purposes stated in this policy, which may include website hosting, data analytics, payment facilitation, information technology and related infrastructure provision, customer service, email delivery, targeted advertising identification and delivery, mailing services, and other service provider services. We will only share your personal information for legitimate, proper, necessary, specific, and explicit purposes, and will only share the personal information necessary to provide the service. Our service providers are required to provide the same or equivalent user data protection as described in this Privacy Policy and are prohibited from retaining, using, or disclosing your personal information except as necessary to provide services to us.

When you use third-party services, we may receive your personal information from such third-party service providers and/or share your personal information with such third-party service providers:

(1) Registering, logging in, and using our products or services using a third-party account, such as Google or Apple account;

(2) If you publish information and/or content on our related products and services (such as forums or other message boards, chats, profile pages, blogs, or any other service where you can publish information and/or content), the information and/or content you publish will be open to anyone who can view that page or service. If you choose to share such information and/or content to your other social media accounts, your friends, other users of the platform, and social media accounts will be able to access such information and/or content. If you choose to use the sharing function to share information, you authorize us to facilitate the sharing of the information you choose, and you understand that the use of shared information will be subject to the privacy policies of the social media providers.

(3) Currently, the third-party SDK services we integrate mainly include the following types:

• Providing IM messaging functionality;
• Performing user behavior data reporting and analysis;
• Providing payment services;
• Performing program crash information reporting;
• Performing performance statistics;
• Providing live streaming support functionality;
• Providing browser services;
• Used for advertising statistics, monitoring, and optimization;
• Used for third-party account login;
• Used to facilitate your sharing of our company's content to third-party platforms.

All integrated third-party services are operated by the respective parties and are subject to their own terms of service and information protection statements (not this Privacy Policy). Regarding the specific device permission types invoked by the third-party SDKs, and how your personal information is collected and used, we recommend that you refer to the relevant service agreements and privacy policies of the third-party SDKs.

3.1.3 Advertising Partners

We may share reports on trends and their advertising effectiveness with our advertising partners to help them better understand their audiences. We will not share your personally identifiable information, such as your name or email address, unless you permit us to do so.

3.1.4 Government, Public Sector, Regulatory, Judicial, and Law Enforcement Agencies or Authorities

In certain circumstances, we may be legally required to disclose your information, including:

(1) To comply with legal obligations or requirements, such as court orders, subpoenas, or other legal proceedings;
(2) To enforce our terms;
(3) To handle matters related to security or fraud; or
(4) In the event of an emergency involving death, serious personal injury risk, or any risk to children;
provided that the entity requesting the information has valid jurisdiction to obtain your personal information.

3.2 Transfer

We will not proactively transfer your personal information to third parties except in the following circumstances:

(1) When your explicit consent has been obtained beforehand;
(2) In the event of a merger, acquisition, or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy; otherwise, we will require the company or organization to obtain your authorization and consent again;
(3) Other circumstances where we need to transfer your personal information according to laws and regulations or as required by competent authorities.

3.3 Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

(1) After obtaining your explicit consent;
(2) As required by applicable laws and regulations, or as required by court judgments, rulings, or other legal procedures, or as required by the legitimate mandatory requirements of government authorities (including other legally authorized organizations);
(3) For reasonable and necessary purposes to implement relevant service agreements or this policy, maintain public interests, and protect the personal and property safety or other legitimate rights and interests of our customers, ourselves, our affiliates, other users, or employees.

3.4 Exceptions to Obtaining Prior Authorization and Consent for Sharing, Transferring, and Publicly Disclosing Personal Information

(1) Related to national security and public safety;
(2) Related to public health and major public interests;
(3) Related to criminal investigation, prosecution, trial, and execution of judgments;
(4) For the purpose of protecting your or other individuals' life, property, or other major legitimate rights and interests, but obtaining the individual's consent is difficult;
(5) Personal information that you have voluntarily disclosed to the public;
(6) Personal information collected from legally publicly disclosed information, such as legitimate news reports and government information disclosure channels;
(7) Other circumstances stipulated by laws and regulations.

Please note that, according to legal provisions, sharing or transferring anonymized personal information, and ensuring that the data recipient cannot restore and re-identify the personal information subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such data will not require further notification or your consent.

IV. How We Protect Your Personal Information

We will take various preventative measures to protect your personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, or destruction. To ensure the security of your personal information, we have strict information security regulations and procedures, and a dedicated information security team strictly enforces these measures within the company.

We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will only retain your personal information for the period necessary to achieve the purposes described in this policy, unless a longer retention period is required or permitted by law. If the aforementioned data storage period exceeds the limit, we will delete your personal information or take technical measures to anonymize it within a reasonable period, unless otherwise stipulated by laws and regulations.

The internet is not an absolutely secure environment, and email, instant messaging, and other communication methods with other users of our company are not encrypted. We strongly recommend that you do not send personal information through these methods.

We will establish emergency response plans. In the event of a security incident such as a personal information leak, we will activate the emergency response plan to prevent the security incident from escalating. We will promptly inform you of the relevant circumstances of the incident via email, letter, telephone, push notification, etc. If it is difficult to notify each individual data subject, we will take reasonable and effective measures to issue a public announcement. The internet environment is not 100% secure. Although we have these security measures, please note that there is no "perfect security measure" on the internet. We will do our best to ensure the security of your information.

You can prevent password leaks that could compromise your account security by not disclosing your login password or account information to anyone (unless that person is formally authorized by you). We recommend that you do not use our products and services on any devices or operating systems modified outside the scope of the device supplier's license or warranty (e.g., jailbroken mobile devices). Using our products on such devices or operating systems may carry the risk of personal information leakage.

We are not liable for security breaches caused by third-party access to your personal information due to your failure to maintain its confidentiality. Notwithstanding the foregoing, you should immediately notify us if any other internet user uses your account without authorization or if any other security vulnerability occurs. Your assistance will help us protect the privacy of your personal information.

V. How We Store Information

5.1 We will store your personal information collected within New Zealand within New Zealand in accordance with relevant laws and regulations, and will strictly protect the confidentiality of this information in accordance with the law. In some cases, if it is necessary to transfer relevant user personal information collected domestically to overseas institutions, we will comply with the provisions of applicable laws and relevant regulatory authorities, and will require overseas institutions to keep your personal information confidential through effective measures such as signing agreements and on-site verification.

5.2 Generally, we will retain your personal information only for the shortest period necessary to achieve the purposes described in this Privacy Policy, unless you separately agree to extend the retention period or other legally permitted circumstances exist. We may change the storage time of personal information to comply with legal requirements in the following circumstances:

(1) To comply with applicable laws and regulations;
(2) To comply with court judgments, rulings, or other legal procedures;
(3) To comply with the requirements of relevant government agencies or legally authorized organizations;
(4) For purposes reasonably necessary to implement relevant service agreements or this policy, maintain public interests, and protect the personal and property safety or other legitimate rights and interests of our customers, ourselves, our affiliates, other users, or employees.

VI. Your Right to Manage Your Information

During your use of our company, in order to make it easier for you to access, correct, and delete your personal information, and to protect your right to withdraw your consent to the use of your personal information and cancel your account, we have provided you with corresponding operation settings in the product design. You can refer to the following guidelines for operation. In addition, we have also set up complaint and feedback channels, and your opinions will be processed in a timely manner. Please note that the operation settings may differ between different operating systems and different versions of our software; furthermore, in order to optimize your user experience, we may also adjust the operation settings. Therefore, the following instructions are for reference only.

6.1 Accessing Personal Information

6.1.1 Accessing Avatar, Nickname, Gender, and Personal Profile:

1. After entering our company, click "My - Settings";
2. Click "Personal Information";
3. Access and query the information.

6.1.2 Accessing Mobile Number, Email, Third-Party Account Binding, Login Device Management, Login History, and Login Password:

1. After entering our company, click "My";
2. Click "Settings";
3. Click "Account and Security";
4. Access and query the information.

6.2 Correcting Personal Information

6.2.1 Changing Avatar, Nickname, Gender, Personal Profile Information, Mobile Number, Email, and Login Password
After entering our company, click on your avatar to enter the personal information page and perform the update operation.

6.3 Managing Camera, Album, Microphone, and Calendar System Permissions

6.4 Account Cancellation

After logging into our company, click "My - Online Customer Service" to contact customer service to complete the cancellation process. Note: After you cancel your account on our platform, we will retain your relevant information in accordance with applicable laws and regulations. After the statutory retention period expires, we will delete or anonymize your personal information.

6.5 Complaints/Reports/Feedback

After logging into our company, click "My - Feedback," fill in the problem you encountered, and click "Submit" to submit relevant complaints and suggestions.

VII. How Your Personal Information is Transferred Globally

In principle, personal information collected and generated within New Zealand will be stored within New Zealand, except where cross-border transfer is permitted under applicable laws. Because we provide products or services through resources and servers located around the world, this means that, with your authorization and consent, your personal information may be transferred to the country/region where you use the products or services, or accessed from these jurisdictions. Such jurisdictions may have different data protection laws, or even no relevant laws at all. In such cases, we will ensure that your personal information receives protection that is sufficiently equivalent to that within New Zealand. For example, we will request your separate consent for the cross-border transfer of personal information, or implement security measures such as data de-identification before cross-border data transfer.

VIII. Information We May Send You

When you use our services, we may send you emails, text messages, news, or push notifications. You can unsubscribe on your device by following our relevant prompts. We may send you service-related announcements when necessary (e.g., when a service is suspended due to system maintenance). You may not be able to unsubscribe from these service-related announcements that are not advertising in nature.

IX. Information You Share

You can share your information with your friends, family, and other users through our services, such as text and photos you publicly share in comments. You can control the scope of your shared information through the privacy settings in our services, and you can also delete publicly shared information through the settings in the services or the instructions we provide. However, please note that this information may still be independently stored by other users or unaffiliated third parties beyond our control.

X. How This Policy is Updated

We will update this policy in a timely manner in accordance with the requirements of relevant laws and regulations, changes in business, or other necessary circumstances. Without your explicit consent, we will not reduce your rights under this policy. We will post changes to this policy on this page and inform you of the revised policy through our official website or other means that you may be able to receive notification of. In such cases, your continued use of our services indicates your agreement to be bound by the revised and updated policy.

XI. Scope of Application

Except for services that we expressly state are subject to our other specially formulated separate privacy policies or terms, this policy applies to your use of all services provided by our company. However, some services have established their own specific privacy guidelines/statements as needed. If there is any inconsistency between this policy and the privacy guidelines/statements of a specific service, the latter shall prevail.

The headings of all clauses in this policy are for convenience only and have no substantive meaning in themselves, and should not be used as the basis for interpreting the meaning of this policy.

XII. How to Contact Us

If you have any questions, comments, or suggestions regarding this policy or data processing, please contact us by phone or email.