Privacy Policy��for app��

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in Privacy Policy and it is important that you read that information.

Before installation of this App and using this app provided by us, you indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy��

I consent to the installation of the App for the purposes of PURPOSE OF APP.

How you can withdraw consent

Once you provide consent by using this app, you may change your mind and withdraw consent at any time by contacting us: [[email protected]], but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Consent to processing Location Data

I consent to processing of my Location Data ([including details of my current location disclosed by GPS technology OR OTHER TECHNOLOGY so that location-enabled Services are activated to PURPOSE OF LOCATION-ENABLED SERVICES.


PumpX (we) are committed to protecting your personal data and respecting your privacy.


This policy applies to your use of:

��       PumpX mobile application software (AppOR hosted on WEB ADDRESS (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

��       Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

PumpX refers to an ecosystem comprising PumpX app, website and other applications that are developed to offer PumpX Services (PumpX Group). Including but not limited to:



The service ecosystem is made up of different legal entities and individuals. When we mention ��PumpX��, we are referring to the relevant company in the PumpX group responsible for processing your data which will be clear to you when you use our App, INITIAL BLOCKCHAIN TECH PTE., LTD is the controller responsible for this App.

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

Full name of legal entity: INITIAL BLOCKCHAIN TECH PTE., LTD

Name or title of data privacy manager: Xavier Zheng

Email address: [email protected]

Postal address: 9-13 ST ANDREW STREET, LONDON, UK EC4A 3AF

Telephone number: +44 (0) 7803785431

You have the right to make a complaint for data protection issues at any time to the Information Commissioner's Office (ICO) in the UK or other regulators in jurisdictions that we provide PumpX service.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 2022.2.15. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our App or Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

��       Identity Data.

��       Contact Data.

��       Financial Data.

��       Transaction Data.

��       Payment Data.

��       Device Data.

��       Content Data.

��       Profile Data.

��       Usage Data.

��       Marketing and Communications Data.

��       Location Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

How is your personal data collected?

We will collect and process the following data about you:

��       Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey, or OTHER ACTIVITIES COMMONLY CARRIED OUT IN CONNECTION WITH AN APP and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

��       Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.

��       Location Data. We also use GPS technology OR OTHER TECHNOLOGY to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by sending written withdraw application to our [CONTACT DETAILS]

��       Information we receive from other sources including third parties and publicly available sources. We may receive personal data about you from various third parties as set out below:

��       Device Data from the following parties:

analytics providers;

advertising networks; and

search information providers.

��       Contact, Financial and Transaction Data from providers of technical, payment and delivery services that have connection with us;

��       Identity and Contact Data from data brokers or aggregators;

��       Identity and Contact Data from publicly available sources.


We use cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites.

If you would like to opt-out of the Technologies we employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits. However, certain aspects and features of the Services and this Site are only available through the use of Cookies, so if you choose to disable or decline Cookies, the Services may not work properly.

Do Not Track (��DNT��) is a privacy preference that users can set in certain web browsers. You can use DNT as a way for Users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that at this time no formal ��Do Not Track�� standard has been adopted and we do not respond to or honor DNT signals.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

��       Where you have consented before the processing.

��       Where we need to perform a contract we are about to enter or have entered with you.

��       Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

��       Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We may also transmit some of your data to third parties such as payment services, infrastructure, logistics, and other services providers.

We enter into contractual arrangements with these third parties to ensure that personal data they could have to process for the provision of their tasks is adequately secured and that your privacy is protected. These providers have privacy policies which you may refer to for information about how they process your information and how to exercise your data subjects�� rights as provided under Applicable Laws. All personal data processed by these third parties shall solely be used to perform the services they provide to us and for the purposes set out in this Privacy Policy.

In certain circumstances and only where required by Applicable Laws, we may disclose some of your data to competent administrative or judicial authorities or any other authorized third party.

We will stop share your personal data with any third party for marketing purposes after we get your express opt-out statement.

Purposes for which we will use your personal data


Type of data

Lawful basis for processing

To install the App and register you as a new App user





Your consent

To process in-App purchases, on-line trade and cash-out Services including managing payments and collecting money owed to us







Marketing and Communications


Your consent

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you including notifying you of changes to the App or any Services





Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey





Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing




Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App







Marketing and Communications



Necessary for our legitimate interests (to develop our products/Services and grow our business)

International transfers

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules".

Many of our external third parties are based outside the UK or outside the EEA, so their processing of your personal data will involve a transfer of data outside the UK or the EEA.

Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

��       We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

��       Where we use certain service providers, we may use specific contracts approved by the UK or other jurisdictions which give personal data the adequate protection.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

We notably implement the following security measures, among others:

��       Payment Data security: If you provide us with credit card information, such information is encrypted using a secure Internet Trade Protocol (TLS) and sent directly to our Payment Service Provider (PSP). This information is never stored on our server.

��       Awareness program and employee trainings

��       Data encryption in transit and at rest

��       Data centres routinely audited

��       Data redundancy for resilience in case of disasters

��       Role-based authentication

��       Two-factor authentication of our authorized employees

��       Continuous system monitoring

��       Industry-standard security evaluations

��       Independent third-party security reviews and penetration tests

Data retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 5 years after they cease being customers.

In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 5 years then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

��       Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

��       Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

��       Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

��       Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

��       Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a)        if you want us to establish the data's accuracy;

(b)        where our use of the data is unlawful but you do not want us to erase it;

(c)        where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d)        you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

��       Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

��       Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you execute the abovementioned legal rights, we shall acknowledge the receipt of your request and, within a maximum one-month period, we shall stop processing your personal data or erase it from our IT systems, except where PumpX has legitimate and compelling grounds for processing, or for the purpose of ascertaining, exercising or defending its legal rights in accordance with the Applicable Laws. If necessary, PumpX shall inform you of the legal grounds and reasons why your request could not be satisfied in whole or in part.

You can exercise any of these rights at any time by contacting us at [CONTACT DETAILS].


Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal third parties

Other companies in the PumpX Group acting as joint controllers or processors and provide IT and system administration services and undertake leadership reporting].

External third parties

Service providers who provide regulated payment service, regulated trading service or other service that is necessary to PumpX��s business.