1.              Purpose

This Privacy Policy is incorporated by reference into the Cobo Vault Terms of Service (the “Terms”). The terms “Cobo Vault,” “Cobo,” “we,” and “us” include Cobo Global HK Limited and our affiliates and subsidiaries. This Privacy Policy explains our information practices, the kinds of Personal Information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. All other terms not defined in Section 12 or otherwise herein will have the meanings set forth in the Terms.

2.              Scope

This Privacy Policy applies to Personal Information that is Processed by Cobo Vault in the course of operating our Cobo Vault mobile application (the “App”) and the Cobo Vault hardware (collectively, the “Services”). This Privacy Policy does not apply to any information collected on Cobo’s website or when you purchase the Cobo Vault hardware from a Cobo or third party website. That information is governed by the Privacy Policy of such website when you initially provide the information.  

3.              TRANSPARENCY/NOTICE—TYPES of Personal Information We Collect and How We Use It

3.1           Types of Personal Information We Collect

Cobo Vault collects limited amounts of information in the following circumstances:

  • Automatic Data Collection. We may collect certain information automatically through our Services, such as the destination address where you send cryptocurrency, the amount of cryptocurrency you send, your Internet protocol (IP) address, mobile carrier, mobile advertising or other mobile device identifiers, the serial number of a hardware device you use via the Services, MAC address, IMEI, language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit or events you engage in using the Services, the date and time of your use of the Services, the amount of time you spend in different areas of the Services, information about the links you click and pages you view within the Services, and other actions taken through use of the Services.

  • Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, request to receive customer or technical support, or otherwise proactively communicate with us.


3.2           How Cobo Vault Uses Your Information

We Process Personal Information about Individuals for a variety of business purposes, including:

  • To Provide the Services. Cobo Vault may use the information it collects to provide the Services.

  • Administrative Purposes. Cobo Vault may use Personal Information about you for its administrative purposes, including to:

    • Measure interest in Cobo Vault’s Services;

    • Develop new products and Services;

    • Ensure internal quality control;

    • Verify Individual identity;

    • Process transactions;

    • Prevent potentially prohibited or illegal activities;

    • Enforce our Terms.

  • Research and Development. Cobo Vault may use the information it collects to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. We may share de-identified Individual and aggregate data for research and analysis purposes.

  • De-identified and Aggregated Information Use. Cobo Vault may use information it collects from your use of the Services to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access Cobo Vault’s Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified or aggregated information is not Personal Information, and Cobo Vault may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Cobo Vault and with Third Parties for our or their purposes in de-identified or aggregated form that is designed to prevent anyone from identifying you.

  • Other Uses. Cobo Vault may use Personal Information for which we have a legitimate interest, such as direct marketing, research (including marketing research), network and information security, fraud prevention, disclosure to affiliated organizations for administrative purposes, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

4.              Onward Transfer—Cobo Vault May Disclose Your Information

4.1        Information We Share

We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

  • We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information you have requested and/or the Services; (iii) payment processing; and (iv) customer service activities.

  • Business Partners. Cobo Vault may share the information it collects with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested.

  • Information Displayed on the Blockchain. When you transfer or receive cryptocurrency through the Services, transactional details such as the destination address and the amount of cryptocurrency may be publicly displayed on the blockchain. This information cannot be deleted and we are not responsible for the privacy practices of others who will view and use the posted information.

  • Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose the information we collect if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Cobo Vault policies or contracts; (v) to collect amounts owed to Cobo Vault; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

  • Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Cobo Vault will endeavor to direct the transferee to use the information we collect in a manner that is consistent with the Privacy Policy in effect at the time such information was collected.

4.2        INTERNATIONAL Data Transfers

You agree that all information collected via or by Cobo Vault may be transferred, processed, and stored anywhere in the world, including but not limited to, Hong Kong, the People’s Republic of China, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers, in order to provide the Services.

5.              Opt-Out (RIGHT TO Object to PROCESSING)

5.1        General

You have the right to opt out of and object to certain uses and disclosures of your Personal Information. Where you have consented to Cobo Vault’s Processing of your Personal Information or, you may withdraw that consent at any time and opt-out to further Processing by contacting us as described below.

5.2             Mobile devices

Cobo Vault may occasionally send you push notifications through our mobile applications with alerts and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Cobo Vault may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

6.               Rights of Access, Rectification, Erasure, and Restriction

We value your rights to your Personal Information. In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information or; (v) seek correction of inaccurate, untrue or incomplete Personal Information; or (vi) request erasure of Personal Information held about you by Cobo Vault, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.  

We will process such requests in accordance with local laws. To protect your privacy, Cobo will take steps to verify your identity before fulfilling your request. Note that due to the nature of the Services, we may be unable to authenticate or link you to information we have, and therefore may not be able to fulfill your request.

7.              Data Retention

Cobo Vault retains the information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8.              Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Services or providing information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.

9.              Children’s Privacy

The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and Cobo Vault does not knowingly collect Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate that Individual’s account.

10.           Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact Cobo Vault by email at []. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

11.           Other Rights and Important Information

11.1       Changes To Our Privacy Policy and PRactices

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, Cobo Vault will notify you within the Services or as otherwise required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy in effect, you must immediately stop using the Services.

11.2       California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Cobo Vault does not share Personal Information with Third Parties for their own marketing purposes.


For users of our Services located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.

12.           Definitions

The following capitalized terms shall have the meanings herein as set forth below.

  • Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Cobo Vault or to which Cobo Vault discloses Personal Information for use on its behalf.

  • Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).

  • Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

  • Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Cobo Vault or Cobo Vault’s Agent.