Privacy Policy

This Privacy Policy ("Privacy Policy" or this "Policy") sets out the basis on which XTransfer Inc. a company incorporated in Delaware, the United States, together with our holding company, and affiliates of XT Group from time to time, collectively "XT", "our", "us" or "we") collect, use, process, store, share and protect your personal information as you use our website (https://us.xtransfer.com) or any other Uniform Resource Locators ("URL"), applications and tools (collectively, the "Platform") through or on which we provide services to you (the "Services"). When you share your personal information with us, for example by registering for an XT account, we can make that service experience even better. By using our Services, you accept and consent to the practices set out below and at the same time we want you to be clear how we’re using your personal information and the ways in which you can protect your privacy. If you have any questions with regard to this Policy, please contact us via email at: [email protected].

When we provide the Services to you, we may collect, use, process, store, and share your personal and business information, as well as transactional information. This Policy only applies to your personal information, which means information that can be linked directly or indirectly to identified or identifiable individuals, as defined in the applicable data protection regulations.

This Policy will help you understand the following content:

• Your Rights
• Our Purposes
• Who Is the Data Controller?
• When and How Does XT Collect Your Information?
• What Information Does XT Collect?
• How Does XT Use Your Information?
• When Does XT Share Your Information?
• How Does XT Store and Protect Your Information?
• Information of Minors
• California Related Rights
• Marketing
• International Data Transfer
• How Long Does XT Store Your Data?
• Changes to Our Privacy Policy
• How to Contact Us?

Your Rights

You have rights and choices regarding our collection, use and disclosure of your personal information, including:

i. Right to access: You can ask details of your personal information we hold about you at any time. We will use commercially reasonable efforts to respond to your query, and generally within 5 business days after receiving your request;

ii. Right to review: You can ask us to review any of your personal information we have retained, how we have used it, and to whom we have disclosed it (except where restricted by law) at any time by contacting us via email at [email protected];

iii. Right to update: If you find out any inaccuracy or incompleteness for your personal information that we hold, you may update that information online through your account access. In case of problems accessing your account or changing online, please inform us and we will update our records accordingly;

iv. Right to stop marketing: You have the right to ask us not to use your personal information for marketing purposes or expressly let us know that you do not wish to receive any further communication from us by contacting at [email protected];

v. Right to data portability: You have the right to ask us to provide your personal information to another data controller, for example, a third-party service provider;

vi. Right to delete your information: You have the right to ask us to delete your personal information when it is no longer necessary, or XT is no longer subject to a legal obligation to retain it, or to have any obsolete information removed; and

vii. Right to withdraw consent: Certain functions of our Platform will be performed based on the information you have agreed to provide or the device permissions you have authorized, you can withdraw such consent by turning off the corresponding functions. After you withdraw your consent, we will not be able to continue to provide you with the corresponding functions, and we will no longer process your corresponding personal information. However, your decision to withdraw your consent will not affect our previous processing activities of personal information based on your previous authorization.

Our Purposes

We collect and/or process your personal information for the following purposes:

(a) to carry out our obligations relating to your contract with us and to take steps at your request prior to entering into such contract;

(b) to comply with any applicable legal and/or regulatory requirements; and

(c) to pursue our legitimate interests, as detailed in "How Does XT Use Your Information?" below.

Who Is the Data Controller?

Depending on your location and how you may interact with us, a different XT entity may be the "data controller." For example, if you use our money transfer services in the United States, you will be interacting with XTransfer Inc. In such instances, XTransfer Inc. will be the "data controller" of your personal information collected in the United States.

When and How Does XT Collect Your Information?

We may collect and store any personal information you provide us when you use our Platform and Services, including when you add information on a web form, add or update your account information, participate in dispute resolutions, or when you otherwise correspond with us regarding our Platform and Services.

You voluntarily provide, and we collect personal information directly from you, and we may also receive personal information about you from third parties (e.g., our partner banks for the Services, marketing agencies, market research companies, our suppliers, contractors and consultants at our group companies, your colleagues and business contacts, public websites and public agencies) automatically, when you use our Platform and the Services.

We, and our third-party service providers, automatically collect your personal information about your use of our Platform and our Services through cookies, web beacons, and other technologies.

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes and to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. You can edit your browser options to block cookies. Visitors to our Platform who disable their web browsers’ ability to accept cookies will still be able to browse our Platform. However, most website features will not function correctly if you disable all cookies (including essential cookies) and you may not even be able to login to use our Services. More information can be found in our Cookie Policy.

What Information Does XT Collect?

1) Realize the necessary functions of our products or Services

When you use our products or Services, you may need to provide or authorize us to collect your personal information required for the corresponding products or Services in the following conditions. If you refuse to provide information required for some functions or services, you may not be able to access these functions or services, but it will not affect your normal use of our other functions or Services.

Registration and certification

When you register for an XT account, you need to provide us with your mobile phone number/email information and set a password to create an XT account. We will verify whether your information is valid by sending an SMS verification code/verification email.

After logging in to your XT account, you can independently complete and enter your phone number, contact address and other personal information. After completing the registration and before using our Services, you also need to complete the corporate certification. When performing corporate certification, you need to provide us with basic corporate information, corporate license which may include personal information, and the identity information as well as the photocopy or photo of the corporate-related natural person(s) (including legal representative, director, control person, the ultimate beneficial owner and/or the authorized representative).

Sending/Money Transfer

In order to realize the function of sending/money transfer, you need to provide your own bank account information to upload money, the bank account information of the recipient/beneficiary, and the related business information, which may include personal information.

Payment Collection

In order to receive our collection agent services, you need to provide trade-related materials (including contracts, purchase orders, and/or invoices, etc.) to credit the payment. If required for risk compliance review, we may request you to provide more transaction-related information based on specific circumstances. The above transactional information may include personal information.

Settlement of Exchange and/or Payment Withdrawal

In order to realize the function of settlement of exchange and/or payment withdrawal, you must first bind your settlement and withdrawal account, which requires your financial information (including debit card or bank account information). In addition to your financial information and trade-related materials provided at the time of your service request, you need to provide transaction-related logistics documents or logistics-related supporting materials based on the delivery situation, which may include personal information. If required for risk compliance review, we will request you to provide more transaction-related information based on specific circumstances.

2) Optimize Service Experience, Customer Service, Protection of User Rights

Optimize Service Experience

For the purpose of optimizing your service experience on our Platform, we and our third-party service providers may collect the following personal information from you: your domain name, your browser type and operating system, your Internet Protocol (IP) address, the duration of your visit to our website or use of our Services, your activities on our Platform, and the referring URLs or pages that lead you to our Platform.

If you do not provide or agree with our retention of the aforementioned information, we may not be able to provide you with certain services related to the optimization of service experience, customer service and user rights protection, but it will not affect your use of our other Services.

Communications of Customer Service

When you contact our customer service, you need to provide your XT account information and related transaction information to verify your identity. Meanwhile, in order to ensure the quality of service, protect the rights and interests of our users, prevent fraud, and check the accuracy of the information you provide in the process of our customer service, we will record the calls you receive from and make to our customer service hotline. The chat history information between you and our online customer service will also be collected. The aforesaid call recordings and chat history information will be automatically deleted after being retained for a certain period of time, unless preserved due to the needs of compliance requirements or legitimate interest needs. Any personal information included during the customer service process shall be subject to this Policy.

Protection of User Rights and Interests

From time to time, we may collect feedback/recommendations information or the information you provide during your complaint or reporting. Any personal information included during this process shall be subject to this Policy.

(3) Device Permissions invoked to Provide Additional Functions

In order to provide you with convenient and high-quality services, we may need to invoke some permissions on your device. When you use the corresponding function, you will see a pop-up reminder asking you whether to authorize it. You can choose to turn off some or all permissions in the setting of your mobile/computer device. Based on different operating systems, the opening and closing methods of the above permissions may be different. For details, please refer to the instructions or guidelines of the device and system developers.

Besides, we may need additional commercial and/or identification information from you. For example, if you send or receive certain high-value or high-volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.

Any personal information included during these processes shall be subject to this Policy.

4) Other Important Rules

In providing the personal data of any individual (other than yourself) to us during your use of our Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Policy.

We do not, however, collect and process any types of personal sensitive data without your prior consent or unless we are required to by law, such as details about your race or ethnic origin, religious beliefs, personal health information, etc.

How Does XT Use Your Information?

We will only use your personal information as permitted by applicable law. Our primary purpose of collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information:

• To validate your identity;

• To exercise our rights and perform our obligations relating to your contract with us, to communicate with you about our Services or any changes in the Services’ terms and conditions that apply to you;

• For the specific purposes you provide personal information to us, including to respond to your queries, to provide any information that you request, and to provide customer support;

• To tailor the content and information that we may send or display to you, and to otherwise personalize your experiences while using our Platform and our Services;

• To administer our Services for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• To protect our customers, employees or property — for instance, to investigate fraud, harassment or other types of unlawful activities involving us, our customers, or other companies that we do business with;

• To comply with any applicable legal and/or regulatory requirements in or outside of the United States;

• To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; and

• For purposes directly related or incidental to the above.

When Does XT Share Your Information?

We will only choose to share your information with third parties, including our service providers, agents and suppliers, financial institutions, affiliated entities, and other business partners (collectively, "Business Partners"), and regulatory agencies/law enforcement agencies for the following reasons:

• Signing of contract with our Business Partners or with you for the necessary purpose of performing and executing of any contract we entered into with you. Under this case, the recipients of data are determined by your particular business choice and we will not share data with recipients unrelated to your foregoing business. In addition, we will sign strict confidentiality agreements with our Business Partners that we share your personal information with, requiring them to process and use such data in accordance with our privacy policy and take strict data security measures;

• In response to legal process – to comply with the law, judicial proceedings, summons, court orders, or other legal proceedings;

• To fulfil the legal compliance requirements by regulatory and law enforcement agencies – in response to the request from regulatory and/or law enforcement agencies which have jurisdiction over us, you, the Services, or any contract we entered into with you;

• To protect us and others – we may disclose your personal information when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Services’ terms and conditions or this Privacy Policy, or as evidence in litigation in which we are involved;

• In connection with business transfers – to another entity if we are acquired by or merged with such other entity, or if substantially all of our assets are transferred to such other entity;

• Share with advertisers, media and other partners – we may cooperate with the aforementioned partners to use the processed desensitization data in various forms for commercial purposes including optimizing advertising and improving marketing effects. Unless authorized by you, we will not share your personal information with these partners. We will provide these partners with data on the population strategy of advertising or the effectiveness of advertising instead of any personal information, or we will aggregate this personal information to make it unrecognizable;

• For analytics and search engine providers that assist us with the improvement and optimization of our Platform; and

• To our affiliates of XT Group as needed.

You can learn more about our sharing of your personal information by sending email to [email protected].

California Related Rights

The California Consumer Privacy Act ("CCPA") grants California residents the following privacy rights with respect to their personal information:

• The right to know. If you are a California resident, you have the right to know (i) the personal information that we collect about you and the purposes for which it will be used; (ii) the categories of personal information that we collected about you in the preceding 12 months; and (iii) the categories of personal information that were sold or disclosed for business purposes in the preceding 12 months.

• The right to access. If you are a California resident, you have the right to access a copy of the personal information that we have collected about you. You may request this copy to be delivered either by mail or electronically.

• The right to deletion. If you are a California resident, you have the right to request that we delete the personal information that we or our applicable service providers maintain about you. There may be circumstances under which we will be unable to delete your personal information, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we are unable to comply with your request for deletion, we will let you know the reason why.

• The right to opt out of the sale of your personal information. If you are a California resident, you have the right to opt out of the sale of your personal information to third parties by completing the "Do Not Sell My Personal Information" form [insert hyperlink to form]. If you do not affirmatively opt out, and you are not a minor, your personal information may be sold as disclosed in this Policy.

• The right to equal service. If you choose to exercise any of your rights under the CCPA, we will not discriminate against you in any way. If you exercise certain rights, you may be unable to use or access certain features of our Platform or Services.

To exercise any of these California related rights, contact us at [email protected]. Please note: (a) if we maintain your personal information on behalf of a third party, we may need to refer you to that third party in order to respond to your request; and (b) certain information, such as nonpublic personal information ("NPI") (as defined under the Gramm-Leach-Bliley Act ("GLBA") and the California Financial Information Privacy Act ("CalFIPA")), may be exempted from the CCPA. This means that we and certain service providers or other recipients may not be required to honor the above rights and instead we comply with our obligations under other laws, such as GLBA and CalFIPA.

We do not sell or disclose the following categories of personal information in the preceding 12 months:

• Identifiers;

• Protected classifications;

• Commercial information;

• Biometric information;

• Internet or other electronic network activity information;

• Geolocation data;

• Audio, electronic, visual, thermal, olfactory, or similar information;

• Professional or employment-related information;

• Education information;

• Information described in Cal. Civ. Code 1798.80; and

• Inferences drawn from the above information for the purpose of creating a profile.


We may use your personal information (including your contact numbers) for direct marketing to you, as permitted by applicable law. This includes sending you marketing communications about updates, and the latest offers and promotions about our products, services, or activities or, as appropriate, those of our affiliates or other companies with whom we have partnered. These communications may be sent by website, APP, or other types of Platform in accordance with applicable law.

You can opt out of receiving marketing or promotional communications from us by following the instructions included in those messages or by logging into your XT account and changing your preferences. Please note that if you opt out of marketing-related emails from us, we will continue to send you non-promotional messages that are required to provide our Services.

International Data Transfer

We operate a global business. Personal information may be collected, stored and processed in any country where we do business or our service providers do business. We may transfer your personal information to countries other than your own country. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

In addition, your data may be transferred to and stored at a destination outside the United States. It may also be processed by our Business Partners, who may operate outside the United States, provided that such transfer/processing is based upon your explicit authorization or the explicit requirements of applicable laws or relevant regulatory agencies..

We comply with applicable laws to provide an adequate level of data protection for the transfer of your personal information to other countries.

How Does XT Store and Protect Your Information?

Protection of your personal information

We will strictly abide by relevant laws and regulations to respect and protect users’ privacy rights. Unless in accordance with our User Agreement, Terms and Conditions, Privacy Policy, Cookie Policy, and other published guidelines on our Platform, we will not disclose and reveal your personal information without your authorization/consent.

Technical measures and data security measures

We take physical and electronic security measures that comply with industry standards to protect your personal information. We manage the storage and use of standardized information by establishing data hierarchical management, system security management, and data security development specifications. We conduct comprehensive security control of data by signing confidentiality agreements with information receivers, completing monitoring and internal management systems.

We will take reasonable and feasible measures to protect your personal information. For example, the data exchange between your browser and our Platform is protected by SSL encryption; encryption technology is used to ensure the confidentiality of data; two-factor authentication is used to protect account security; a trusted protection mechanism is used to prevent malicious attacks on accounts; network information security training and assessment are conducted regularly for relevant personnel to make them fully realize the importance of network security and strictly abide by applicable rules and regulations.

If you accidentally disclose your login account and password, you shall contact our customer service at [email protected] as soon as possible for us to lock the user’s operating authority timely to prevent any third-party from illegal operation. Besides, you can reset your password and resume to normal use after providing valid identification and relevant credentials which have been reviewed and verified by us.

Information of Minors

The Services are not directed to minors, including children under the age of 13, and we request that you do not provide their personal information through our Platform or Services.

How Long Does XT Store Your Data?

As a regulated financial institution, XT is required by law to store some of your personal and transaction data beyond the closure of your account with us. Your personal information is only accessed internally on a need-to-know basis, and it will only be accessed or processed if absolutely necessary. Your personal information shall be kept for seven years from the year when the business relationship is terminated or the year when the one-off service is ended. Where you or your transaction(s) are involved with investigation (such as anti-money laundering and counter-terrorist financing) or other legal actions, and if such investigation or legal action is still on-going upon the expiration of seven years, the related information will be kept until such investigation/legal action is closed.

We always delete information that we no longer need. And everything we need to keep is subject to the highest levels of security.

Changes to Our Privacy Policy

We may amend this Privacy Policy at any time by posting a revised version on our Platform and, where appropriate, by notifying you in the forms of email, text messages or pages pop up. The revised version will be effective as of the published effective date. You can find the relevant content of this Policy at any time through "About Us-Privacy Policy" on our Platform.

How to Contact Us?

If you have any questions, comments or suggestions about this Policy or our collection, processing, or use of your personal information, you can contact us via email at: [email protected].

You have the right to cancel your XT account by sending us a cancellation application 30 days in advance through your registered email address with the reason of cancellation to [email protected]. We will process your cancellation request accordingly.