Privacy Policy

1. Introduction

This Privacy Policy (hereinafter referred to as “this Policy”) is established by Shunxing Intelligent Technology Co., Ltd. (Mas Intelligent Technology Ltd.) (hereinafter referred to as “the Company”) and applies to all services provided by the Company, including but not limited to APIs, software tools, the website, and mobile applications (collectively, “the Services”).

This Policy is drafted with reference to Taiwan’s Personal Data Protection Act (PDPA) and, where applicable, includes supplementary provisions for users located in the European Economic Area (EEA), the United Kingdom, and the United States, so as to provide appropriate protection to users in different regions.

2. Categories of Personal Data Collected by the Company

2.1 Information Provided by the User

– Account identification data (e.g., name, contact information, login credentials)

– Identity verification data

– Billing and payment data

– Records of communications with customer service

– Content uploaded by the user and strategy parameters

2.2 Information Automatically Collected

– Device and connection data

– Platform usage logs

– API and system operation data

– Cookies and similar technologies

2.3 Information Provided by Third Parties

– Data from payment processors

– Data from cloud service, information security, identity verification, and analytics providers

– Data from authorized third-party APIs, brokers, or data sources

3. Purposes of Collecting, Processing, and Using Personal Data

The Company collects, processes, and uses personal data for the following purposes: (1) account creation and provision of services; (2) technical integration and execution assistance; (3) billing management; (4) information security and risk control; (5) legal compliance and dispute handling; (6) service optimization and analysis; (7) marketing and notifications.

References in this Policy to API integration, automated execution assistance, or signal transmission do not imply that the Company is a licensed financial institution or that it provides licensed discretionary trading services.

4. Legal Basis for Processing Personal Data

The Company processes personal data on one or more of the following legal bases: performance of a contractual relationship with the user; the user’s explicit consent; compliance with a legal obligation; public interest or the prevention of harm; and other lawful bases recognized by applicable law.

5. Matters Required to Be Disclosed by Law

5.1 The identity of the data collector, the purpose of collection, and the categories of data collected are as set out in this Policy.

5.2 Retention Period: personal data is retained only for as long as necessary to fulfill the purposes described in this Policy or as required by law.

5.3 Region of Processing: personal data is primarily processed in Taiwan; however, it may be processed overseas where necessary for cloud hosting, backup, customer service, or analytics purposes.

5.4 Recipients of Data: as described in Section 6 below.

5.5 Method of Processing: personal data is collected, processed, and used by automated and, where applicable, manual means, subject to appropriate security safeguards.

5.6 Users may exercise the rights described in Section 8 of this Policy.

5.7 Where the user declines to provide data required for the Services, the Company may be unable to provide all or part of the Services to the user.

6. Sharing, Disclosure, Outsourcing, and International Transfer of Personal Data

6.1 General Principle: the Company does not sell users’ personal data.

6.2 Potential Recipients: the Company may share personal data with the following categories of recipients where necessary to provide the Services: payment processors; cloud hosting, CDN, backup, and database service providers; information security, identity verification, monitoring, and analytics providers; partner APIs, brokers, platforms, and data sources; accounting, legal, audit, and consulting service providers; government, regulatory, and judicial authorities; and successors in the event of a business transaction such as a merger or acquisition.

6.3 Outsourcing and Sub-outsourcing: where the Company outsources the processing of personal data to a third party, the Company requires that party to provide an equivalent level of protection and to be bound by confidentiality and data protection obligations.

6.4 Cross-Border Transfers: where personal data is transferred outside Taiwan, the Company implements appropriate management measures to protect such data.

7. Retention, Security, and Incident Response for Personal Data

7.1 Retention Principles: the Company retains personal data only for as long as necessary to achieve the purposes for which it was collected, or as required by applicable law.

7.2 Security Measures: the Company implements encryption; access controls and the principle of least privilege; identity authentication including multi-factor authentication (MFA); access logging and monitoring; monthly vulnerability patching, security testing, and backups; and staff training and vendor management.

7.3 Incident Response Procedures: in the event of a personal data security incident, the Company will investigate, contain, and remediate the incident; assess its impact; notify affected users where necessary by email, in-service notice, SMS, or public announcement; report the incident to the competent authorities where required by law; and maintain records of the incident.

8. Users’ Rights and How to Exercise Them

Subject to applicable law, users have the following rights with respect to their personal data: (1) to inquire about and access their personal data; (2) to request a copy of their personal data; (3) to request correction or supplementation of their personal data; (4) to request that the Company stop collecting, processing, or using their personal data; and (5) to request deletion of their personal data.

To exercise these rights, users may contact the Company as described in Section 13. The Company may verify the user’s identity before processing such requests and will respond within the period required by law. The Company may charge a reasonable fee to cover necessary costs where permitted by law. Users may also opt out of marketing communications at any time, and, where applicable and technically feasible, may request the export or portability of their data.

9. Cookies and Similar Technologies

The Company uses cookies, session identifiers, pixels, and SDKs to maintain login status, remember preferences, perform analytics, and deliver notifications. These technologies are categorized as necessary, functional, or analytical cookies. For further details, please refer to the Company’s separate Cookie Policy.

10. Restrictions on Use by Minors

The Services are intended for use by individuals with full legal capacity. If the Company becomes aware that a minor has provided personal data without the consent of a parent or legal guardian, the Company may terminate or restrict that minor’s account.

11. Third-Party Websites, Services, and Data Sources

The Services may contain links to or integrate with third-party websites, services, or data sources. Except where the Company itself outsources the processing of personal data to such third parties, those third parties’ own privacy policies, not this Policy, govern their handling of personal data.

12. Changes to This Policy and Retention of Prior Versions

The Company may update this Policy from time to time. Updates will be published on the Company’s official website or within the Services, together with the version number, effective date, and last-updated date. Where a change is material, the Company will notify users in advance by email, in-service notice, or public announcement and will obtain renewed consent where necessary. Prior versions of this Policy will be retained for reference.

13. Contact

Company name: Shunxing Intelligent Technology Co., Ltd. (Mas Intelligent Technology Ltd.)

Contact email: mas@mindaismart.com

Address: 8F, No. 25, Chenggong 2nd Road, Zhenbei Li, Qianzhen District, Kaohsiung City, Taiwan