Privacy and Security

COCREA Privacy Policy

Effective Date: June 1st, 2022

OUR COMMITMENT

2ndR (HK) Limited (collectively with its affiliates, the "COCREA" or "We") attach great importance to your information security and respects your privacy. We are committed to protecting the privacy of our users and we want to provide a safe and secure user experience. We will use our best efforts to ensure that the information you submit to us remains private and is used only for the purposes set forth herein.

APPLICABILITY OF PRIVACY POLICY

This policy applies to all information we collect through COCREA's products and services (hereinafter referred to as "COCREA Services") through websites, applications, clients, related WeChat Open Platform accounts or applets, software development kits (SDKs) and application programming interfaces (APIs) for use on third-party websites and applications.

This Privacy Policy will help you understand：

1. INFORMATION COLLECTED

2. HOW YOUR INFORMATION IS USED

3. INFORMATION FROM MINORS

4. HOW TO USE COOKIES AND OTHER TRACKING TECHNOLOGIES

5. DO NOT TRACK

6. HOW TO SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR INFORMATION

7. CALIFORNIA CONSUMERS

8. DATA TRANSFER

9. PROTECTION & STORAGE OF PERSONAL INFORMATION

10. INDIVIDUAL RIGHTS

11. UPDATING ACCOUNT INFORMATION

12. DEACTIVATE YOUR ACCOUNT

13. CHANGES TO OUR PRIVACY POLICY

14. THIRD PARTY RESPONSIBILITY

15. CONTACT US

1. INFORMATION COLLECTED

When you use the COCREA Services, you may be asked for certain personal information, including your name, gender, date of birth (year-month-day), nationality, email address, phone numbers, location information, Digital Currency account ID, Non-Fungible Token Assests. If you only need to use basic services such as browsing and search, you do not need to register as our user and provide the above information.

In order to meet the purpose of providing you with better services, you may also need to provide us with further information related to the functions of the above services(such as nickname, profile picture, personal identification number, relationship status, astrological sign, school, photo of real person, occupation, hobbies, your voice and image (in any content you upload), transaction information, etc.).

In order to provide better services and improve user experience, we will collect device attribute information (such as your hardware model, operating system version, device configuration, unique device identifier, International Mobile Equipment Identity (“IMEI”), network device hardware address Media Access Control Address (“MAC”), etc.), device connection information (browser type, telecom operator, language used) and device status information (such as device sensor data, device application installation list).

Our website also automatically receives and records information on our server logs from your browser, including your IP address, browser type and cookie information.

We may also obtain information about you from third parties. We collect data to operate effectively and provide better quality experiences. If you do not agree to our collection of the information, you may be limited or restricted in the available COCREA Services. If we combine or associate information from other sources with information that we collect through the COCREA Services, we will treat the combined information in accordance with this Privacy Policy.

2. HOW YOUR INFROMATION IS USED

COCREA uses this information to:

· Provide, maintain, and improve the COCREA Services;

· Personalize the content you see;

· Provide Customer Service;

· Help protect the safety of COCREA and its users, which includes blocking suspected spammers, investigating and addressing abuse, and enforcing the COCREA Terms of Use and Privacy Policy;

· Inform you of updates to our services, security alerts, and other support and administrative messages;

· Communicate with you about products, services, and events, and provide other news and information we think will be of interest to you (for information about how to opt out of these communications, see “INDIVIDUAL RIGHTS” below).

· Monitor and analyze trends, usage, and activities in connection with the COCREA Services.

In certain cases, we have a legal obligation to collect and process your personal information (such as our obligation to share data with tax authorities).

We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop the processing of your data for that purpose.

COCREA will rely on legal grounds to process your personal information to the extent permitted by applicable law, which may include, without limitation: to honor contractual commitments, to take steps in anticipation of entering into contract, to fulfill legal obligations, your consent, and COCREA’s legitimate interests.

We may de-identify and aggregate information collected through the Site for statistical analysis and other lawful purpose, including in research studies intended to improve our understanding of how people use COCREA.

3. INFORMATION FROM MINORS

IF YOU ARE UNDER 13 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE COCREA SERVICES AT ANY TIME OR IN ANY MANNER.

Protecting the privacy of young children is especially important. For that reason, COCREA does not knowingly collect or maintain personal information (as defined by the United States Children’s Online Privacy Protection Act) from persons under 13 years-of-age. If COCREA learns that personal information of persons under 13 has been collected on or through the COCREA Services, COCREA will take appropriate steps to delete this information.

If you are the parent or legal guardian of a child under 13 who has become a COCREA Services member, then please contact COCREA at [e-mail] to have that child’s account terminated and personal information deleted.

4. HOW TO USE COOKIES AND OTHER TRACKING TECHNOLOGIES

As is common practice with almost all professional websites and mobile devices COCREA uses cookies, which are tiny files that are downloaded to your computer or mobile device, to improve your experience. Other than cookies, we — along with certain business partners and vendors — may use cookies and other tracking technologies. We use cookies and other tracking technologies as outlined in the “How Your Information is Used” section.

Unfortunately, in most cases there are no industry standard options for disabling cookies and other tracking technologies without completely disabling the functionality and features they add to COCREA. It is recommended that you leave on all cookies and other tracking technologies if you are not sure whether you need them or not in case they are used to provide a service that you use.

You can prevent the setting of cookies or other tracking technologies by adjusting the setting on your browser or your mobile device. Be aware that disabling cookies or other tracking technologies will affect the functionality of our website that you visit. Disabling cookies or other tracking technologies will usually result in also disabling certain functionality and features of COCREA Service. Therefore, it is recommended that you do not disable cookies or other tracking technologies.

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on COCREA Service.

However, if you are still looking for more information, you can contact us through one of our preferred contact methods: Email:[e-mail].

5. DO NOT TRACK

Do Not Track (“DNT”) is an optional setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

6. HOW TO SHARE, TRANSFER, AND PUBLICLY DISCLOSE YOUR INFORMATION

I Sharing Information We will not share your personal information with any companies, organizations and individuals outside of our company unless we have your express consent. The exceptions are the following：

(1) Sharing with your express consent: we will share your personal information with other parties after obtaining your express consent.

(2) Provided as necessary to comply with applicable laws and regulations, requirements of legal process, or mandatory administrative or judicial requirements.

(3) To our affiliated parties to share your personal information.

(4) Providing your personal information to trusted partners who will process it for us in accordance with our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

Currently, our authorized partners include the following types:

(1) Suppliers of goods or technical services. In order to implement the functionality of the services associated with COCREA and to provide you with a more complete service, we need to share information with vendors, service providers and other partners who support our business. These vendors will provide us with infrastructure technical services, payment services, data processing, customer service support, etc. These vendors may change based on our business, but we will always conduct a rigorous evaluation of the need to share information and also sign a strict confidentiality agreement with that third party requiring them to handle personal information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures, and we do not allow such vendors to subcontract where personal information of minors is involved.

(2) Third party SDKs.

In order to recieve constantly secure and optimized services you need, you may access some SDKs provided by third-party softwares.The third-party SDK providers include mobile phone device manufacturers, social platforms, communication operators, and third-party payment institutions. Different third-party SDKs may call different types of device permissions and may obtain different information, which may include obtaining your location information, reading/writing your external memory card, reading your device status and identity, viewing WLAN connection, and retrieving running application/Bluetooth. Regarding the specific types of device permissions that the third-party SDK calls, and how to collect and use your personal information, it is recommended that you refer to the relevant service agreement and privacy policy of the third-party SDK.

II Sharing with Affiliated Parties Your personal information may be shared with our affiliates and/or their designated service providers within the scope of the purposes specified in this Privacy Policy. We will only share personal information that is necessary and subject to the purposes stated in this Privacy Policy, and will seek your authorized consent again if we share your personally sensitive information or if our affiliates change the purposes for which the personal information is used and processed. Where personal information of minors is involved, we do not allow subcontracting by affiliates.

III Complaint handling Mechanism When you lodge a complaint to others or are complained by others, COCREA may provide your name, cell phone number, contact information, complaint-related content to the other party, consumer rights protection departments or regulatory authorities, for protecting the legitimate rights and interests of you and others,and timely resolving the complaint dispute, except for those explicitly prohibited by laws and regulations.

IV Public Disclosure We will not disclose your personal information publicly unless we have your express consent. However, we may disclose your personal information to the relevant authorities if we are compelled to do so by law, legal process, litigation or government authorities.

Ⅴ Transfers We will not transfer the personal information we collect from users to any company, organization or individual unless we obtain the express consent of the user, except to meet the requirements of laws, regulations, legal procedures or mandatory governmental requirements or judicial decisions, or in the event of a merger, demerger, acquisition or other equity or asset reorganization or bankruptcy liquidation of us or our affiliates that requires the transfer of the user's personal information, in which case we will require the new subject holding your personal information to continue to be bound by this policy.

Ⅵ Exceptions to Obtaining Prior Authorization and Consent when Sharing, Transferring and Publicly Disclosing Personal Information

We are not required to obtain your prior authorization or consent when sharing, transferring, and publicly disclosing your personal information in the following circumstances:

1. related to national security and the security of national defense;

2. related to public security, public health and significant public interests;

3. related to investigation of a crime, prosecutions, trials, enforcement of judgments, etc.;

4. the personal information is collected for the protection of the life, property and other significant legitimate rights and interests of you or other persons, and it is difficult to obtain your consent;

5. the collected personal information has been publicly disclosed to the public by you at your own discretion; or

6. the personal information collected from information that has been lawfully and publicly disclosed, such as lawful news reports, government information disclosures and other channels.

Ⅶ Please be aware that if we take technical measures and other necessary measures to process personal information so that the recipient of the data cannot re-identify a specific individual and cannot recover it, the sharing, transfer, or public disclosure of such processed data does not require separate notification to you and your consent.

Ⅷ Special Note Personal information that you voluntarily and publicly share during using COCREA Service is not subject to this Privacy Policy (such as forwarding content to other Internet platforms). You should be aware that any information you share can be read, collected and used by any third party. You should carefully consider posting and disseminating through COCREA and the information that may be directed to you personally therein. You fully understand that when you make your own disclosures, COCREA is merely storing content or system logs containing such information and has no ability or obligation to actively identify such information as your personal information. As long as you do not delete your publicly posted information, such information may remain in the public domain; in some cases, even if you delete your publicly posted information, such information may still be independently cached, copied or stored by other users or third parties not affiliated with and controlled by the Platform, or kept in the public domain through other users or third parties. For example, when you forward your answers published on COCREA to other Internet platforms, COCREA will independently display, cache or store your forwarded content, and other Internet users will forward and store your answers, and the corresponding pages will not be under the control of COCREA.

7. CALIFORNIA CONSUMERS

Pursuant to the California Consumer Privacy Act (CCPA) and other privacy protection related policies in California, we provide a separate <Privacy Notice for California Consumers> which addresses how we respect California's users' privacy.

8. DATA TRANSFER

COCREA is a worldwide service. Our operational body to provide the COCREA Services is in Hong Kong. The information we collected is governed by U.S law and Hong Kong law. By accessing or using COCREA Service or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the U.S., Hong Kong, and other countries, where you may not have the same rights as you do under local law. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Service.

9. PROTECTION & STORAGE OF PERSONAL INFORMATION

1. Storage Period. During your use of COCREA Service, we will continue to store your personal information for you. If you cancel your account or voluntarily delete the information, we will store your information in accordance with applicable laws and regulations. After you cancel your account or voluntarily delete the above information, we will no longer use your personal information for commercial purposes, however, we may use your personal information after anonymization of your personal information.

2. Storage Region. Your personal information is stored in the United States. If cross-border transfer is required, we will strictly follow the laws and regulations.

3. Security measures.

1) We will collect, use, store and transfer user’s information based on the principle of "minimization” and inform you of the purpose and scope of use of relevant information through Term of Use and Privacy Policy.

2) We attach great importance to information security. We have established a dedicated team responsible for the development and application of a variety of security technologies and procedures. We will conduct security background reviews on security management personnel and personnel in key security positions. We have established a sound information security management system and internal security incident handling mechanism. We will take appropriate industry-standard security measures and technical means to store and protect your personal information to prevent your information from being lost, being accessed without authorization, publicly disclosed, used, damaged, lost or leaked. We will take all reasonable and feasible measures to protect your personal information. We will use encryption technology to ensure the confidentiality of data; we will use reliable protection mechanisms to prevent malicious attacks on data.

3) We will cultivate employees' awareness of data security, provide trainings on and conduct assessments on their security capabilities, and strengthen employees’ awareness of the importance of protecting personal information. We will conduct identity authentication and authority control for employees who process personal information, sign confidentiality agreements with employees and partners who access to your personal information, clarify job responsibilities and code of conduct, and ensure that only authorized personnel can access to personal information. If there is any violation of the confidentiality agreement, the cooperation relationship with the company will be terminated immediately, relevant legal responsibilities will be investigated. Confidentiality requirements will also be imposed on the personnel having access to personal information after they leave their positions.

4) We remind you that the Internet is not an absolutely secure environment. Despite our efforts, we cannot guarantee the security of your personal information or that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. We cannot guarantee that personal information may not be accessed, disclosed, altered, or destroyed by breach of our administrative, managerial, or technical safeguards. We also have no way of protecting any of your personal information that is not in our control, such as any information transmitted via email or wireless connections.

5) In the meantime, maintaining the security of your personal information is also your responsibility. Where we require you to register an account, you should choose a password of sufficient length and complexity and keep your password confidential. Do not leave your device unlocked so that other individuals may access it. Make sure you trust the wireless connections you are using to access or use COCREA Services.

6) In accordance with our security management system, personal information leakage, damage or loss is listed as the most serious security incident. Once it occurs, the company's highest-level emergency plan will be activated, and a joint emergency response team will be formed by personnel including security personnel to handle the incident.

4. Security Incident Notification

1) We will formulate emergency plans for network security incidents, and promptly deal with security risks such as system vulnerabilities, computer viruses, network attacks, and network intrusions. When an incident that endangering network security occurs, we will immediately activate emergency plans, take corresponding remedial measures, and report to relevant competent authorities according to provisions.

2) Leakage, damage, or loss of personal information is listed as the most serious security incident. We will regularly organize working group members to conduct security plan drills to prevent such security incidents from happening. In the event of an unfortunate occurrence, we will activate the emergency plan as the highest priority and form an emergency response team to trace the cause and reduce the loss in the shortest time.

3) In the event of an unfortunate occurrence of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the processing measures we have taken or will take, and suggestions on the risks you can prevent and reduce on your own, remedies for you, etc. We will promptly inform you of the event-related information through site notifications, SMS notifications, phone calls, emails and other contact methods you reserved. When it is difficult to notify one by one, we will adopt a reasonable and effective way to make announcements. In the meantime, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

10. INDIVIDUAL RIGHTS

We provide you with the right described below when you use our Services. Please contact us at [e-mail]. If you would like to exercise your rights under applicable law. When we receive an individual request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:

·Where denial of exercising Individual Rights is required or authorized by law or regulations;

·When exercising Individual Rights would have negative impact on your privacy or other rights, or on other individuals’ or organizations’ privacy or other rights.

·To protect our rights or properties;

·Where the request is frivolous or burdensome;

·When exercising Individual Rights may directly related to national security or national defense security;

·When exercising Individual Rights may directly related to public safety, public health, and significant public interest;

·When exercising Individual Rights may directly related to crime investigation, prosecution, trial and execution of judgements, or

·When exercising Individual Rights may involving trade or commercial secrets.

Right to withdraw consent. If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

Rights of access and rectification. If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us unless you can already do so directly via the Services.

Right to erasure (the “Right to be Forgotten”). You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

Right to restriction. You have the right to restrict our processing your personal information where one of the following applies:

·You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the COCREA Services, during the period necessary for us to verify the accuracy of your personal information;

·The processing is unlawful, and you oppose the erasure of your personal information and request the restriction of its use instead;

·We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or

·You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.

·We will only process your restricted personal information shall with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.

Right to object of processing. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract, or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

Right to data portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used, and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

Notification to third parties. If we share your personal information with third parties, we will notify them of any requests for rectification, erasure, or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.

Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

Right to Lodge a Complaint. If you believe we have infringed or violated your privacy rights, please contact us at [e-mail] so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority of alleged infringement.

Right to choose. We also provide you with the opportunity to opt-in to receive these types of communications at the time of registration, but later decide to opt out of several types of communications at the time of registration. If you no longer want to receive them, simply change your preferences on your account settings or communicate your preferences to us via email. You may opt out of receiving promotional communications from us by following the instructions in those communications. If you opt out, we may still send you non-promotional communications, such as information about your account or your use of the COCREA Services.

11. UPDATING ACCOUNT INFORMATION

We allow you to change your personal information at any time. To do so, simply log on to COCREA with your username and password, and you will be able to update the information you have submitted.

12. DEACTIVATE YOUR ACCOUNT

If you deactivate your account or request COCREA to delete your personal information. COCREA may not delete your personal information instantly, and COCREA may still retain certain information associated with your account for analytical purposes and record-keeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our website or our users, or take other actions otherwise permitted by the applicable law or regulations. In addition, if certain information has already been provided to third parties as described in our Privacy Policy, retention of that information will be subject to those third parties’ policies.

13. CHANGES TO OUR POLICY

We may update this Privacy Policy from time to time. We will place any updates to this policy on our website. You may also request a digital copy of the Privacy Policy by contacting us at email or address noted below.

You are bound by any changes to the Privacy Policy by using the COCREA Service after such changes have been posted to our website.

14. THIRD PARTY RESPONSIBILITY

You should understand that the third party website operators, partner platforms, third party services accessed through COCREA and third parties receiving your personal information through COCREA you visit may have their own privacy policies, please read them carefully. If you agree to accept and provide information to the third party, the third party shall be independently responsible for the collection, use, sharing, storage and protection of your information. If a third party shares information with us in accordance with your authorization and privacy policy, we will use and protect your information in accordance with this policy.

When you view web pages created by third parties or use applications developed by third parties, these third parties may place their own cookies or pixel tags that are not controlled by COCREA and their use is not governed by this Policy. If you find that the web pages created by these third parties or applications developed by third parties are at risk, you are advised to terminate the relevant operations to protect your legitimate rights and interests.

15. CONTACT US

Whether you live in the United States or outside the United States, COCREA is responsible for your information. If you have any questions, you can contact COCREA via the following methods:

email [e-mail].

APPENDIX I

List of COCREA Vendor Third Parties

· Gmail

· FaceBook

· Metamask

· Google Analytics

To receive a copy of the complete list of third parties, please contact [e-mail] and use the subject line "Third Party Request". The list is proprietary and confidential and may not be used for any other purpose or distributed in any form; violation of this requirement is a violation of the Terms of Use governing COCREA Services, and its use and is subject to the Commercial Use provisions in the Terms of Use.

2ndR (HK) Limited

June 1st, 2022