Privacy Policy

PRIVACY POLICY

Last Updated: January 3, 2026 Version: 1.1

1. INTRODUCTION AXIS Easy Prosper Limited (易發技有限公司) ("Company", "we", "us", or "our") respects your privacy and is committed to protecting the personal and commercial data we process. This Privacy Policy outlines how we collect, use, and handle information in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong ("PDPO").

By using our website, integrating our API, or paying for services via cryptocurrency, you agree to the practices described in this policy.

2. DATA WE COLLECT We limit our data collection to what is strictly necessary for Business-to-Business (B2B) commercial relationships and technical API integration.

A. Corporate & Commercial Information To establish a commercial agreement, we collect:

• Corporate Identity: Including, but not limited to, Company name, business registration documents, and relevant certificate of incorporation details.
• Commercial Contact Details: Business email addresses (e.g., finance@partner.com), Telegram IDs, or other instant messaging handles used for commercial communication.

B. Financial & Cryptocurrency Data As our services are primarily settled in cryptocurrency, we collect:

• Wallet Addresses: Public cryptocurrency wallet addresses used for sending or receiving payments (e.g., USDT, BTC, ETH).
• Transaction Hashes: Blockchain transaction IDs (TXIDs) required to verify invoice settlement.
• Note: We never ask for, collect, or store private keys or seed phrases.

C. Technical Usage Data When you access our API or Client Back Office:

• Network Data: IP addresses, API request logs, and timestamps.
• Session Data: Login activity and technical performance metrics.

3. HOW WE USE YOUR DATA We use the collected data for the following specific purposes:

• Service Provisioning: To authenticate your API credentials and grant access to our game aggregation network.
• Cryptocurrency Billing: To generate invoices, verify incoming crypto transactions on the blockchain, and reconcile accounts.
• Commercial Due Diligence: To verify the existence of the corporate entity we are doing business with.
• Technical Support: To troubleshoot API errors, latency issues, or integration faults using your IP address and error logs.
• Legal Compliance: To comply with relevant Hong Kong statutory obligations applicable to software providers.

4. CRYPTOCURRENCY AND BLOCKCHAIN DISCLOSURE Please be aware that by the nature of blockchain technology, transactions made to settle invoices are public and immutable.

• Public Ledger: Your public wallet address and the transaction amount will be visible on the respective blockchain explorer (e.g., Etherscan, TronScan).
• No Reversals: Once data (such as a transaction hash) is committed to a blockchain, we cannot erase or modify it. This is an inherent feature of the technology and falls outside the scope of our ability to "delete" data under standard privacy requests.

5. DATA SHARING AND TRANSFERS We do not sell your data. We only disclose data in the following limited scenarios:

• Game Studios (Third-Party Providers): We pass technical identifiers (such as Player IDs) to third-party game studios to facilitate gameplay. We do not share your corporate financial details with these studios.
• Service Providers: Cloud hosting providers (e.g., AWS, Google Cloud) that host our infrastructure.
• Legal Requirement: If required by a valid court order from a Hong Kong court or a request from the Hong Kong Police Force.

6. DATA SECURITY We implement industry-standard security measures to protect your data:

• Encryption: All API traffic is secured via SSL/TLS encryption.
• Access Control: Access to our internal billing and client data is restricted to authorized personnel only.
• Wallet Security: Our corporate crypto wallets are secured using multi-signature protocols or cold storage where applicable.

7. DATA RETENTION We retain corporate and financial data only for as long as necessary to fulfill the purposes outlined in this policy or to comply with Hong Kong tax and accounting laws (typically 7 years for financial records).

8. YOUR RIGHTS Under the Hong Kong PDPO, you have the right to:

• Access: Request a copy of the specific personal data we hold about you.
• Correction: Request correction of any inaccurate data.
• Withdraw Consent: You may withdraw consent for us to contact you via specific channels (e.g., email marketing).

To exercise these rights, please contact our Data Protection Officer. Note that requests regarding public blockchain data cannot be fulfilled as we do not control the blockchain.

9. CONTACT US

For privacy inquiries, please contact: privacy@axiseasyprosper.com

AXIS Easy Prosper Limited Address:
Unit S-V, R18, 6/F, Valiant Industrial Centre, Nos 2-12 Au Pui Wan Street, Fo Tan, Hong Kong

__Email:__privacy@axiseasyprosper.com