Last updated on: Sept 25, 2019.

Dear Users,

NingBo Fenglian Information Technology Co., Ltd. (“Company”, “we”, “us”, or “our”) respects and protects the privacy of Users (“you”, “your” or “Users”). The Company will collect, use, disclose and process your Personal Information, in accordance with this Privacy Policy (“Policy”) when you:

(a) use our mobile applications (“Applications”) and services; and/or

(b) provide us with your Personal Information, regardless or the medium through which such Personal Information is provided.

The Company recommends that you shall carefully read and understand the whole contents of this Policy before your use of the Applications. Additionally, significant information including the Disclaimer is in bold form in this Policy. Definitions of key words in this Policy are consistent with those in the NeoLine User Terms of Service of the Company. If there is any discrepancy between the definitions of any defined term used in this Policy and the NeoLine User Terms of Service , the definition of any defined term used in this Policy shall prevail.

By providing us with your Personal Information, you consent to our collection, use, disclosure (including transfer) and processing of your Personal Information in accordance with this Policy. Please DO NOT provide any Personal Information to us if you do not accept this Policy.

The Company reserves the right to update this Policy online from time to time, without notice to you, and the revised Policy will come into effect and supersede the older versions once posted on our Applications. The revised Policy will apply to Personal Information provided to us previously. In particular, if you do not accept the revised Policy, please immediately stop your use of the Applications. Your continuous use of our Applications will be regarded as your acceptance of the revised policy.

一、Information We Collect

1. You confirm that your Wallet Password, Private Key, Keystore on the Applications are not stored or synchronized on the Company’ servers. The Company does not offer the service to recover your Wallet Password, Private Key or Keystore.

2. To the extent permitted by applicable laws and regulations, the Company may collect and use the Personal Information in the following circumstances without your prior consent or authorization:

(1) information related to national security and national defense;

(2) information related to public security, public health, significant public interests;

(3) information related to criminal investigation, prosecution, trial and enforcement;

(4) Personal Information in the public domain;

(5) Personal Information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

(6) Personal Information necessary to maintain the security and compliance of services, such as to detect or to solve the malfunction of products and services; and/or

(7) other circumstances permitted by laws and regulations.

3. We collect information in the following ways:

(1) when you provide us with your Personal Information for whatever reasons;

(2) when you register for a user account on our Applications;

(3) when you contact us or interact with our employees through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;

(4) when you request to be included in an email or our mailing list; and/or

(5) when we copy all or part of your transaction records on the blockchain. However, you should refer to the blockchain system for your latest transaction records.

4. Your provision of Personal Information to us is voluntary and you may withdraw your consent for us to use your Personal Information at any time. However, if you choose not to provide us with the Personal Information we require, it may not be possible for you to use the Applications or for us to contact you, or provide products or services which you need from us.

5. In certain circumstances, you may also provide us with the Personal Information of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her Personal Information and that he/she has consented to your disclosure of his/her Personal Information to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such Personal Information in accordance with the terms of this Policy.

6. You are responsible for ensuring that all Personal Information that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your Personal Information.

二、How We Use Your Information

1. We collect, use or disclose your Personal Information for one or more of the following purposes:

(1) to provide you with products and/or services that you request for;

(2) to manage your relationship with us;

(3) to facilitate your use of our Applications;

(4) to push important notifications to you, such as software update, update of User Terms of Service and this Policy;

(5) to notify you of our products, services, programmes and events;

(6) to resolve any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct;

(7) to comply with our obligations in accordance with laws, regulations and to cooperate with regulatory authorities;

(8) to comply with international sanctions and applicable regulation for securities and to counter money-laundering or financing of terrorism;

(9) to enforce obligations owed to us, and contractual terms and conditions; and/or

(10) any other reasonable purposes related to the aforesaid.

2. If you agree, we will use your personal information from time to time for other purposes, such as telling you about the latest events, offers and promotions from our strategic partners or affiliates.

三、How You Control Your Own Information

You are entitled to control your Personal Information provided to imToken.

1. You may import your other wallets into imToken through synchronization of wallets and you may export your wallets from imToken to other Tokens management wallets. imToken will display the information of imported wallets to you.

2. You may add or delete Tokens, transfer and collect Tokens using the “Assets” column.

3. You understand that you may submit any questions or suggestions for NeoLine at any time in the "Help and Feedback" column of the "Settings" column. We are glad to communicate with you to improve our services.

4. You acknowledge that since blockchain is an open source system, your transaction records are automatically public and transparent in the whole blockchain.

5. Our Applications may contain links to other websites, applications or Smart Contracts that are not owned, operated, developed or maintained by us. These links are provided only for your convenience. This Policy only applies to our Applications. When using Third-Party Service, you understand that the NeoLine User Terms of Service and NeoLine Privacy Policy will no longer apply. You are encouraged to carefully review their privacy policies and related terms of service.

四、Protection for the Minors

The following special provisions apply to minors who are under the age of 18 years old:

1. The minors shall not use NeoLine without the guidance from their parents or guardians.

2. The parents and guardians of the minors shall provide guidance to the minors on using NeoLine after they read this Policy, NeoLine User Terms of Service and other relevant rules.

3. NeoLine will ensure the confidentiality and security of the minors’ Personal Information in accordance with the applicable laws and regulations.


1. After you use Third-Party Service, you acknowledge that this Policy no longer applies to the collection, use, disclosure and transfer of your Personal Information by these third parties. The Company is unable to guarantee that these third parties will implement reasonable security measures to protect your Personal Information.

2. You are solely responsible for your use of Third-Party Service and agree that you will not hold the Company liable for any damages incurred or injuries inflicted as a result of the collection, use, disclosure and transfer of your Personal Information by these third parties.



1. You shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of the services provided by the Company.

2. You may access this Policy and other terms (e.g. NeoLine User Terms of Service) through our Applications. We encourage you to check the NeoLine User Terms of Service and Policy of the Company each time you log onto our Applications.

3. Any translated versions of this Policy are provided for the convenience of Users, and are not intended to amend the original English version of this Policy. If there is any discrepancy between the English version and non-English version of this Policy, the English version shall prevail.

4. This Policy shall become effective on Sept 25, 2019.

5. As for any issues not covered in this Policy, you shall comply with the announcements and relevant rules as updated by the Company from time to time.