Gate Web3 - Privacy Policy

*LAST REVISED on 24th September, 2025

GENERAL

a. This Privacy Policy (henceforth referred to as the "Policy"), outlines the privacy practices of Gate and any of its affiliates, related body corporates ( "Company", "we", "us", or "our") for gathering, utilizing, and revealing information about individuals who visit our Sites and those who use the features accessible through our Sites, including any Services.

b. All natural persons or other subjects who access our Sites and/or use our Services shall be users of the Sites. For the convenience of wording in this Policy, the users are referred to as 'you' or any other applicable forms of the second-person pronouns whereas you and we are referred to as both parties, and individually as a party or one party.

c. Unless otherwise defined herein, all capitalised terms used shall have the same meanings ascribed to them in the Gate Web3 - Terms and Conditions ("Terms").

PURPOSES OF THE PRIVACY POLICY

a. The Privacy Policy stipulates the types of data we may collect through your access to the Sites and/or your use of the Services we offer. This data includes personal information provided by you, information we obtain from third parties and information which is collected about you automatically, which identifies a natural person or relates to an identifiable natural person ("Personal Data").

YOUR CONSENT

a. To ensure that you have full confidence in our handling of Personal Data, you are advised to read and understand the clauses of this Policy in detail. In particular, upon accessing our Sites, regardless of whether you have registered or log in, you signify your acceptance, understanding and confirmation to the following:

i. You, on the basis of your own free will and your requisite consent, agree to disclose your Personal Data to us;

ii. You will comply with all the clauses of this Policy;

iii. You agree that we may collect your information through your log into any of the Sites, your registration with the Sites, and/or your use of the Services offered by us;

iv. You agree to any changes and modifications that we may make to our Policy in the future;

v. You agree that our branches, affiliates and employees may contact you in connection with the products and Services in our reasonable opinion that you may be interested in (unless you have indicated in written to us that you do not want to receive such information).

INFORMATION COLLECTED

a. When you use the Sites, you agree to permit us to use "Cookies" to track each of your actions and collect and keep all the information that you leave on the Sites, including but not limited to your IP address, location, and other information. For more details regarding our use of Cookies, please refer to Section 7: Cookies Policy.

b. We may collect, process and store Personal Data via your use of the Service or where you have given your consent. If you use any of the Services offered by the Sites, we may actively or automatically collect, use, store or transfer your Personal Data, which may include the following categories of information:

i. Publicly Available Data. This includes your digital asset wallet address and public blockchain data, which we use solely to provide and enhance our functionalities, as well as to ensure compliance with applicable laws and regulations.

ii. Contact Data. We may collect your contact information along with other data related to your use of the Sites and its functionalities (to the extent provided by you), particularly in connection with survey responses or customer support inquiries.

iii. Identification Information. We may collect your identification information to ensure our compliance with applicable laws and regulations.

iv. Service Information. Information we automatically collect when you use our Services, including but not limited to browsing information and usage data such as Internet Protocol Address, operator and carrier data, or other information stored on or available with regards to devices you allow us access to when you access our Sites.

v. Correspondence Information. Information which arise from your survey responses, information continued in the survey, and your communications with us or our customer support team.

c. When you use any of the Sites or the Services, we may collect more information necessary from our exclusive mailboxes or in other ways that we consider as in compliance with relevant requirements, for the purpose of improving the functions of the Sites, enhancing our experience of using our Sites and Services as well as the security thereof, or as is required by any court order, any applicable laws, administrative regulations or any order of any competent government agency or authorities.

d. Before sharing any third-party personal information with us for specific purposes, you must （i）Obtain the third party's explicit consent, and (ii) Ensure our processing of the data fully complies with all relevant laws. If consent is withdrawn, you must promptly inform us. You bear full responsibility for fulfilling these obligations.

e. If you visit any links to third-party websites, pages, contents or platforms which may be accessible through links from the Sites or any link of any of our third-party partners, you must and will be required to agree to and comply with the separate and independent privacy policy of such third parties. This Policy does not apply to any third-party websites, and we will not bear any liability for the contents and activities of such sites operated by third parties.

HOW WE COLLECT PERSONAL DATA

We collect your personal data in the following manner:

a. We collect your Personal Data in the following ways:

i. Information you provide to us directly when contacting us;

ii. Information we receive from third parties, such as our affiliates, subsidiaries, vendors and service providers;

iii. Information acquired by us during the course of our relationship and dealings with you;

iv. Information collected automatically through your use of our Sites and Services such as using s and other tracking technologies; and

v. Information gathered from publicly available sources.

TRANSFER OF PERSONAL DATA

a. Data we collect from you may be transferred to, and stored at, servers outside of the jurisdiction of your residence. In such cases, you consent to the transfer of your Personal Data to such jurisdiction for purposes of providing the Services to you, even if such jurisdiction has less protection for Personal Data than your jurisdiction of residence. We will ensure security measures are in place consistent with our obligations to maintain security of your Personal Data under the laws of your jurisdiction of residence.

COOKIES POLICY

a. Cookies are small text files and/or identifiers that are placed in your device browsers when you visit a website. Cookies store information about the user's visit, which may include browsing history, preferences, time and duration of each visit and advertisement accessed for facilitation and enhancement of user's experience.

b. Cookies are classified into two categories, namely session Cookies and persistent Cookies. Session Cookies exist only during an online session on our Sites and these Cookies will disappear once the browser is closed. We use session Cookies to allow our Cookies to identify you uniquely during a session or while you are logged into the Sites. Persistent Cookies are added when you start to browse our Sites or interacts with a specific feature but may remain stored on your device after you have closed your browser. We use persistent Cookies to track statistical and aggregate information about your activity. Please note that we do not respond to or honor Do Not Track signals or similar mechanisms transmitted by browsers.

c. We may use Cookies to record the habits and preferences of visitors accessing our Sites. The information collected by Cookies is non- registered and does not involve Personal Data. We use Cookies to improve our Sites and enhance your user experience based on your profile, to the extent legally permissible in certain jurisdictions. We may also use information collected to ensure compliance with our Anti-Money Laundering requirements, and to detect irregular, suspicious activities to ensure your account has not been compromised. Some Cookies, web beacons and other tracking and storage technologies that we use are from third party service providers to provide us with web analytics and intelligence about our Sites which may also be used to provide measurement services and target ads.

d. Most browsers are designed to accept Cookies automatically. You may opt to stop or restrict the placement of Cookies on your devices or remove them by adjusting your preferences as your browser or device permits. However, if you set your browser to disable Cookies, it is possible that you may not be able to access and/or use certain functions of our Sites and/or Services.

USE OF INFORMATION

a. We will use your Personal Data that we collect for the following purposes or in the following ways:

i. to provide you with our Services through our Sites pursuant to our Terms;

ii. to identify and confirm your identity in accordance with applicable laws and regulations when you use our Sites and/or Services;

iii. to improve and enhance the Services and/or Sites (your information and feedback received by us can help us improve the Services and the functions and performances of the Sites, so that we can more effectively respond to your enquiries and other needs);

iv. to keep statistics relating to the use of our Sites and to be used for data analysis carried out in cooperation with government agencies and/or public affairs institutions;

v. to better understand how users access and use the Sites in order to personalize your experience (your information will help us to better respond to your personalized needs);

vi. to carry out product marketing and promotions including newsletters, updates, related products or Services information (you can opt out at anytime if you do not wish to receive marketing communications from us);

vii. to communicate with you about your account, activities on our Services, and policy changes including but not limited to requesting for any additional information or documentation;

viii. to maintain the security of your account and the Sites, including without limitation, to carry out two-factor authentication;

ix. to detect and reduce risks of fraud;

x. to enforce/defend our rights, agreements and/or policies;

xi. to satisfy additional purposes with your consent;

xii. to comply with applicable laws, regulations and/or orders required by competent authorities; and

xiii. to meet other purposes as specified in the Terms of the Sites, or other reasonably expected business purposes as permitted by law or when required to comply with legal obligations.

b. We do not sell, trade, or otherwise transfer your Personal Data or allow third parties to collect, access or use your Personal Data; however, you agree that we may disclose and transfer your Personal Data in the following circumstances:

i. To our affiliates (includes subsidiaries, holding companies and companies under common control including their respective contractors, affiliates, employees or representatives);

ii. To service providers and other trusted third parties who assist us in operating our Sites, manage our business, or provide Services to you, provided that such parties agree and have adopted appropriate measures to keep such information confidential;

iii. To our professional advisors, including accounting, legal or other consulting services for purposes of complying with our legal obligations or audits;

iv. To entities in connection with any corporate financing, merger, acquisition, due diligence, reorganization, receivership, or dissolution proceedings which involve disclosing certain portion or all of our business or assets;

v. When we believe that relevant information disclosure is appropriate, or it is required by any applicable laws, regulations, rules, requests, subpoenas or order of courts, law enforcement agencies or other competent authorities, and is necessary for using the strategy of our Sites and ensuring the proper functioning of the Sites, or as may be necessary to provide Services, or for the protection of the rights, property or safety of us or other persons.

c. If we disclose your Personal Data to service providers or third parties that perform business activities for us, they may only use your Personal Data for the specific purpose for which we supply it.

d. Your information will not be provided to other parties for marketing, advertising or other similar purposes. We have implemented international standards to prevent money laundering, terrorist financing and circumventing trade and economic sanctions, which requires us to undertake due diligence on our customers. This may include the use of third-party data and services providers which we will cross-reference with your Personal Data for detecting fraud, verifying identity, verifying credit risk and monitoring transactions.

PROTECTION OF PERSONAL DATA

a. We adopt appropriate physical, electronic, management and technical measures to protect and safeguard the security of your Personal Data. We will, to the greatest extent possible, ensure that any Personal Data collected through our Sites shall not be subject to nuisance by any third party unrelated to us. These measures encompass internal reviews of our data collection, storage, and processing practices, as well as standard security protocols. If you are aware of any security flaws in our Sites, please contact us immediately so that we can take appropriate actions as soon as possible.

b. We have implemented commercially reasonable precautions to protect the information (including your Personal Data) we collect from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Despite the above-mentioned measures, no security measures can provide 100% security. Therefore, we cannot guarantee that the information transmitted via the Sites is absolutely secure, and we cannot guarantee nor warrant that the Personal Data that you provide to us through our Sites will be safe at all times. To the fullest extent permitted by applicable laws, we will not be held liable for any losses or damages arising from or caused by any event that may occur in connection with unauthorized access to your Personal Data, and we shall not be held liable for compensation for such losses or damages.

DATA RETENTION

a. We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security.

b. We keep Personal Data only for as long as is reasonably necessary to provide Services to you, to fulfil the purpose(s) for which it was collected, to comply with any applicable legal or ethical reporting or document retention requirements, pursue legitimate business purposes, enforce our agreements and resolve disputes. We will not retain your Personal Data in a form which permits the identification of the data subject for longer than needed for the legitimate purpose or purposes for which we originally collected it, including for the purpose of satisfying any legal, accounting or reporting requirements.

c. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we will anonymize your personal information so that it can no longer be associated with you, in which case we will use such information without further notice to you.

d. At the end of the retention period, we will securely delete or destroy data retained, and require our sub-processors or third-party suppliers to do likewise.

MINORS

a. Our Sites and Services are not directed to persons who may be defined as minors under applicable laws. As such, if you are below 18, please terminate all access to our Sites and Services immediately. We reserve the right (but not the obligation) to demand at any time evidence for our review to verify that you are above 18 years of age. In the event that you are under 18 years of age, or we reasonably suspect that you are under 18 years of age and you are unable to prove otherwise, we shall delete any Personal Data we have collected, unless we have a legal obligation to retain it, and all your use of our APIs, account registrations, access to the Sites, shall be immediately terminated.

b. To clarify, we do not knowingly collect Personal Data from minors, however, through the internet, we are unable to ascertain on our end whether such individuals are minors. It is thus the responsibility of parents or guardians to ensure that their minors do not access or use our Sites and/or Services or provide us with Personal Data. If a parent or guardian becomes aware that his or her minor has accessed our Sites or provided us with Personal Data, please contact us at dpo@gate.com promptly so we can take appropriate action.

RESIDENTS WITHIN THE EUROPEAN ECONOMIC AREA (EEA)

a. If you are a resident of the EEA, you may have certain data protection rights. "GDPR" means the European Union General Data Protection Regulation (EU) 2016/679. Information that you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. If you are located in the EEA, you freely consent to the transfer of Personal Data outside of the EEA. Your consent to this Policy constitute your agreement to these transfers.

b. We process Personal Data subject to the GDPR on one or more of the following legal bases:

i. Contractual necessity: To comply with our contractual obligations to you under our Terms, including to provide you with our Services and customer support services, and to optimize and enhance the Sites.

ii. Legitimate interest: Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. This may specifically involve research and development, direct marketing, personalizing your user experience, fraud prevention, network and information security or creating aggregated, de-identified and/or anonymized data.

iii. Consent: Where we have your specific consent to carry out the processing for the purpose in question.

iv. Compliance with legal and regulatory obligations: Including "know your customer" obligations based on applicable anti-money laundering and anti-terrorism requirements, suspicious activity reporting, financial crime and fraud prevention, responding to requests from public authorities, complying with economic and trade sanctions requirements, performing customer due diligence, performing audit and risk assessments, preparing tax reports, fulfilling our retention obligations and handling legal claims.

c. If you are accessing or using the Sites and/or Services from within the EEA, you may have the following rights under the GDPR, subject to certain exceptions:

i. Right of Access: You have the right to obtain confirmation from us as to whether or not we process Personal Data from you and you also have the right to at any time obtain access to your Personal Data stored by us.

ii. Right to Correction: If we process your Personal Data, we use reasonable measures to ensure that your Personal Data is accurate and up-to-date for the purposes for which your Personal Data was collected. If your Personal Data is inaccurate or incomplete, you have the right to require us to correct it.

iii. Right to Deletion: In some cases, you may request us to delete your Personal Data. Please note that under certain circumstances (such as for the purposes of public interest, public health or scientific and historical research), we have the right to retain your Personal Data even if you ask us to delete it.

iv. Right to Restriction of Processing and Right to Object: In some cases, you can lodge an objection to the processing of your Personal Data and ask us to limit the processing of your Personal Data. Similarly, in some cases, we have the right to refuse your request even if you raise objections or ask us to restrict the processing of your Personal Data.

v. Right to withdraw Consent: In some cases, you may withdraw your consent in respect of collection and processing of your Personal Data. If there are other legitimate reasons, we also have the right to continue using or processing without your permission. Withdrawal of consent does not affect lawfulness of processing based on consent before such withdrawal.

vi. Right to Data portability: You may have the right to receive the personal information concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller.

vii. Right to lodge Complaint: If you reside in the EEA and have a concern about our processing of your Personal Data that we are not able to resolve through our internal resolution process, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

d. We will assess all requests and complaints we have received and provide you with timely responses. We may ask you to provide a valid copy of the identity document so that we can fulfill our security obligations and prevent unauthorized data disclosure. We have the right to charge you a reasonable administrative fee if your request for access to data is clearly unfounded or out of our obligation, or if you request us to provide additional copies of your Personal Data.

e. To facilitate with the Services provided to users located in the EEA, we request explicit consent for the transfer of Personal Data from the EEA to countries outside of the EEA where the transfers are necessary to provision of Services to you and/or to optimize and enhance our Sites. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use our Sites and Services. You will still retain the ability to withdraw assets in your Accounts opened with us however, all other functionalities will be disabled.

MODIFICATION TO THE PRIVACY POLICY

a. For expediency and for compliance with any changes in applicable laws, we reserve the right to amend this Policy from time to time in our sole discretion without prior notice to you. We may inform you of the modifications made to the Policy by updating and publishing the modified version on the Sites. We may issue a notice to inform you of the modifications made to the Policy, which, however, is not an obligation for us. You shall regularly review the Policy, and if you do not agree to such updates, you shall immediately stop accessing the Sites. Your continued access to or use of the Sites and/or the Services constitutes your acknowledgment and acceptance of such changes to this Policy.

COMMUNICATION WITH US

a. If you have any questions regarding this Policy or your Personal Data, please contact us at dpo@gate.com, which is the only valid and official email through which we communicate with you.

b. All announcements and information regarding our Policy shall be made and published on the Sites. We shall not be held liable for any losses arising from your trust in information that has not been obtained through our designated email and the Sites.

LANGUAGES

a. This Privacy Policy may be published in different languages. If there are any discrepancies between different languages, the English version shall prevail.