Last revised: May 08, 2024
Orox Lab Limited, a company registered in the British Virgin Islands, and its subsidiaries, affiliates, and transferees, successors, and their officers, directors, employees, and agents, including orox.app (“Company”, “Orox”, or “we”) respect your privacy and are committed to protecting your personal data. To that end, we have prepared this Privacy Policy to explain what information we collect about you, how we use it, when we share it, and what rights you have with respect to your personal data. We encourage you to read this Privacy Policy carefully, as it can help you make informed decisions when you visit the Orox Platform and/or use our Products or Services.
We review our Privacy Policy regularly to ensure that it reflects any changes to our operation, privacy practices, Products, Services, or the Orox Platform as well as that we remain compliant with the changing regulatory landscape. And we may amend this Privacy Policy at any time and without prior notice by posting the updated version, along with the “Last revised” date, on this page. Please revisit this page regularly to stay informed of any changes. If we make a revision that materially changes our privacy practices, we will make reasonable efforts to notify you in a timely manner and, if required under applicable laws, obtain your consent before implementing such revision. You hereby acknowledge and agree that your continued use of the Orox Platform, our Products, and/or our Services shall constitute your acceptance of our current Privacy Policy and any future amendments thereto. This Privacy Policy and any future amendments thereto supplement, and form part of, our Terms of Service, available at https://orox.app/terms-use, as amended, supplemented, or modified from time to time. Accordingly, capitalized terms used, but not defined in this Privacy Policy, have the meanings set out in the Terms of Service.
Orox Lab Limited, a company registered in the British Virgin Islands, is the data controller for personal data collected in connection with provision of our Products, Services, and Orox Platform. Each relevant data controller determines why and how we process the personal data we collect while you visit the Orox Platform or use our Products or Services. As we operate globally, other Orox companies and third-party service providers may be involved in processing your personal data, and they do so under the direction of the relevant data controller.
The Orox Platform may display links to third-party websites, applications, or plug-ins. If you follow such links, please note that those third parties may collect or share your personal data and have their own privacy and/or cookie policies. We do not control those third parties or your privacy settings on their services, and you hereby acknowledge and agree that we shall not have any responsibility or liability in connection with your visits to those third-party websites, applications, or plug-ins via links displayed on the Orox Platform.
By the term “personal data,” we refer to information that relates to an identified or identifiable individual. Your name, national identification number, internet protocol (IP) address, or other pieces of information from which you can be directly or indirectly identified are typically considered personal data.
The personal data we collect can be grouped into the following categories:
Types of personal data |
Examples of personal data |
|---|---|
Identification data |
First, last, middle, maiden names, date of birth, personal identity code, any other unique sequence of symbols granted to you, intended for personal identification, gender, nationality, citizenship, copy of government-issued identity document (e.g., passport, national identity card, residence permit, driver’s license) and its details (e.g., type, number, place and date of issuance, expiry date, MRZ code, signature), country of birth, residential address, copy of proof of address document (e.g., utility bill, identification document bearing your address), photographed image or video recording of your face that you provide through a mobile or desktop camera while going through our identity verification process. |
Transaction data |
Account balance, transactional activity, external wallet address, transaction information such as timestamp, virtual asset service provider (VASP) that is a counterparty to the transaction, transaction ID (TXID). |
Account data |
ID number, login password, mobile app PIN number, nickname, profile image, referral information (if you use a Referral Code of someone else when you create an account with us or if someone else uses your Referral Code when creating an account with us), push and email notification preferences, history of the actions performed in your account on the Orox Platform. |
Activities data |
Technical information, including device type, model, operating system and version, carrier, IP address, browser type and version, location, time zone setting, unique device identifier (e.g., IMEI), unique advertising or vendor identifier (e.g., ADID, IDFA, IDFV), authentication data, crash logs and other diagnostics data, links you interact with across our Products, Services, and the Orox Platform (including links in our emails sent to you), clickstream to, through, and from our Products, Services, or the Orox Platform, access dates and times, pages visited, page response times, download errors, length of visits, types of page interaction (e.g., scrolling, clicks, mouse-overs), external webpage that referred you to our Products, Services, or the Orox Platform |
Content data |
Content you create or submit to the Orox Platform (e.g., posts and comments you upload to our Orox Community Service) including but not limited to texts, links, images, gifs, audio, or video. |
Data related to AML/CFT/sanctions requirements |
Information that enables us to perform anti-money laundering (AML) and combating the financing of terrorism (CFT) requirements and ensure the compliance with international sanctions, including the purpose of the business relationship and whether you are a politically exposed person and other data that are required to be processed by us in order to comply with the legal obligation to “know your client” (KYC) (information collected will differ depending on each client’s risk score). |
Data obtained and/or created in order to fulfill the requirements of applicable legislations |
Information that Orox is required to provide to public authorities (e.g., tax administrators, courts), including information on income, payments, and other information held by us. |
Contact data |
Phone number, e-mail address, residential address. |
Communications data |
Information you provide during communication with us (e.g., via emails, chats, or calls with our Support Team). |
Promotional data |
Survey responses, participation in promotional events, promotion communication preferences. |
Special category data |
Biometric data (collected for identity verification required during our KYC process). |
We do not process special category data related to your health, ethnicity, or religious or political beliefs unless required by law or in specific circumstances where, for example, you reveal such data while you visit the Orox Platform or use our Products or Services (e.g., in payments details).
If you provide us personal data about other people (such as your spouse or family) or you ask us to share their personal data with third parties, you confirm that you have brought this Privacy Policy to their attention beforehand.
We may collect your personal data in three ways: 1) receive directly from you; 2) generate or collect while you visit the Orox Platform or use our Products or Services; and 3) receive from third parties.
Information received directly from you
To create an account such as a Orox Account with us and use our Products and/or Services, you need to provide us with certain information. We collect such information because it is necessary to provide the requested Products or Services (e.g., when you make a withdrawal request, we will ask for a withdrawal address), required by law (e.g., we collect your selfie and government-issued photo ID to verify your identity and comply with relevant AML/CFT regulations), or for certain other specific purposes that we will describe in further detail below.
You have a choice regarding whether to provide us with your personal data. Please note that if you choose not to provide us with certain information that is required by law or under the terms of a contract we have with you or are in the process of entering into, we may not be able to offer you our Products or Services (e.g., if you do not want to provide information necessary to create a Orox Account) or our Products or Services may not be best tailored to your interests or preferences.
Information we generate or collect while you visit the Orox Platform or use our Products or Services
When you create a Orox Account, we assign you a unique ID number. This allows us to recognize you when you sign in on a new device or through a different platform (e.g., say you usually access your account via our website orox.app, but now want to sign in via our Orox mobile app). Once we verify your identity through our Know Your Customer (KYC) process, we also assign you a unique Referral Code which you may use to invite your friends to create a Orox Account and use our Products or Services and be eligible for rewards if you meet certain criteria under our Referral Program Terms, available prior to program launch.
In addition, we also collect information about your devices, and your interactions with and activities across our Products, Services, and/or the Orox Platform (including, without limitation, your transactions). We use this information to provide the requested Products, Services, or Orox Platform; detect any suspicious activity and prevent fraud; offer you more personalized services and features; improve the performances of our Products, Services, or the Orox Platform, and develop new Products or Services; and address customer support issues. For example, collecting your device type allows us to show you the best version of the Orox Platform. We may use cookies and other similar technologies to collect some of this information.
If you have any questions, comments, complaints, or requests regarding this Privacy Policy or our privacy practices, or if you wish to exercise your rights regarding your personal data, please contact us by email at info@orox.app.
This Privacy Policy is global in scope yet is not intended to override any legal rights or prohibitions in any jurisdiction where such rights or prohibitions prevail. In such event, the rights and obligations set out in this Privacy Policy will apply, subject only to amendment under any applicable local laws or regulations having precedence.
