Privacy policy

1. INTRODUCTION

We recognize that the protection of Personal Data (defined below) is important to our users. This Privacy Policy details our data processing practices when users access our websites and services, including any content on our website and subdomains.

This Privacy Policy serves as an addendum to any previous consents you may have given us concerning your Personal Data. Additionally, any consent provided for this Privacy Policy is cumulative and complementary to our rights under applicable laws regarding Personal Data handling and processing.

We reserve the right to modify this Privacy Policy periodically. We recommend checking this Privacy Policy regularly and verifying the date of the last update. However, we may also inform you of any updates in any appropriate form or by providing notice in compliance with applicable laws.

2. ACCEPTANCE OF THIS PRIVACY POLICY

When you engage with us, provide us with information, or register for any of our services or products on our websites, you acknowledge and consent to the processing of your Personal Data in accordance with this Privacy Policy. Our authorized service providers may also be involved in this processing, which will be performed for any of our purposes as stated herein.

If you disagree with any aspect of this Privacy Policy or find it uncomfortable, we recommend that you discontinue accessing or using our websites and services immediately.

3. PURPOSES FOR PROCESSING OF YOUR PERSONAL DATA

Where permitted under applicable law, Orus processes your Personal Data for the following purposes (which may apply even if you do not maintain an account or have terminated your account with us):

3.1 providing you with products and/or services which you have purchased or requested to receive, and to personalise and customise your experience on our services, including to recommend features or content which may be relevant to you based on your usage of our services, your profile information and preferences, and other information that you submitted to us;

3.2 for the development and improvement of our products, services, processes and/or business, such as through the use of technical and usage data, as well as aggregated, de-identified, and/or anonymized data to understand user behaviour and market trends;

3.3 to communicate with you, such as notifying you of any service issues and account updates, handling and responding to your queries, requests, feedback and suggestions, or sending you direct marketing messages or interest-based advertising, when carried out in our legitimate interests or in accordance with applicable law;

3.4 managing our business operations and complying with internal policies and procedures, including but not limited to keeping records for tax purposes, managing and preparing reports on incidents and accidents, protecting and enforcing our contractual and legal rights and obligations, and facilitating business asset transactions;

3.5 complying with any applicable laws and regulations, rules, codes of practice or guidelines, or to assist in law enforcement and investigations by relevant authorities;

3.6 facilitating your account registration and transactions, whether through verifying your blockchain wallet address or otherwise;

3.7 matching any Personal Data held which relates to you for any of the purposes listed herein; and/or

3.8 any other purpose relating to or reasonably necessary for any of the above.

4. COLLECTION OF PERSONAL DATA

4.1 "Personal Data" means

4.1.1 - any data relating to an identified or identifiable natural person; or
4.1.2 - “personal data,” “personal information,” “personally identifiable information” or similar term as defined under applicable data protection laws.

4.2 The amount and types of Personal Data that we collect and process depends on the nature of your interaction with us. Generally, we may collect and process the following:

4.2.1 - Account and profile information, such as email addresses, passwords and/or blockchain wallet addresses,
4.2.2 - Payment and transaction information, such as the name of the credit/debit cardholder, credit/debit card number, country, city, state, address, and/or blockchain wallet transactions. We may use third-party vendors to collect and process payment information;
4.2.3 - Contact information, such as usernames in third party services such as Telegram or Discord, first and last names, email addresses, professional titles, company names, and/or phone numbers;
4.2.4 - Technical information and usage data, such as statistical and site-related information relating to how a visitor arrived at our websites or platforms, the IP address which may provide information about precise or approximate location, device information, clickstream information and time stamp, and information about how you use our websites and services. We may automatically receive and record such information from our server logs or cookies. For more information, please see the section on Cookies below;
4.2.5 - Marketing and communications data, such as your preferences in receiving marketing messages from us, your communication preferences and history of communications with us, our service providers or third parties; and/or
4.2.6 - Other information, which may include your participation in our contests, promotions, or surveys, and photographs, videos and/or audio recordings taken by us or our representatives

4.3 We may collect and process information from third-party sources, which may consist of publicly available records, social media platforms, and blockchain data about the records or transaction histories of blockchain wallet addresses.

4.4 We may also offer referral features that help users invite other users to use our services, and we may collect Personal Data (such as contact details) about these invitees or referrals. Please do not refer someone to us or share their contact details or Personal Data without their permission or consent to do so.

4.5 Although the labelling of blockchain wallet addresses is a vital aspect of our operations, we do not employ the Personal Data of our users (e.g., blockchain wallet addresses in their account or profile information) to append or disclose such labels or any other means of identifying any individual as the owner of any specific blockchain wallet address.

4.6 Furthermore, we undertake no other measures that may reveal the identity of any individual as the owner of a specific blockchain wallet address or otherwise make them identifiable, while taking into consideration the methods likely to be employed for identification. At Orus, we lack the technical capability to carry out such identification of blockchain wallet address owners ourselves. We have also implemented technical and organizational measures to ensure that no such identification occurs during the course of our regular operations. There may be exceptional cases to this policy, such as adding labels regarding a high-profile public figure who has publicly declared their blockchain wallet address; however, these instances account for a statistically insignificant portion of the blockchain wallet address-related information we use to furnish our websites and services.

5. DISCLOSURE OF PERSONAL DATA

Subject to applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties

5.1 vendors, agents, service providers and other organisations who we engage to provide goods and services either independently or on our behalf in connection with any of the purposes listed above in this Privacy Policy, such as payment processors, cloud service providers, analytics and search engine providers, marketing partners, and customer support;

5.2 any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale);

5.3 our professional advisers such as our board of directors, auditors, cybersecurity consultants and lawyers;

5.4 relevant government regulators, ministries, statutory boards or authorities and/or law enforcement agencies, to comply with any directions, laws, rules, guidelines, regulations or requests issued or administered by any of them; and/or

5.5 any other party to whom you authorise us to disclose your Personal Data to.

6. THIRD-PARTY SITES

Our websites and services may include hyperlinks to other websites or services that are owned or provided by third parties. We are not liable for the privacy practices of such websites or services owned or provided by third parties, regardless of whether they display our logo or trademark, even if we do not operate or maintain them.

Once you depart from our websites or services, you should review the relevant privacy policy of the third-party website or service to determine how they will manage any data they collect from you.

7. DATA SECURITY

We have instituted technical and organizational safeguards intended to safeguard your Personal Data against unlawful access, use, or disclosure. Nevertheless, please note that no mode of transmission over the internet or electronic storage mechanism can be impervious. Although we endeavour to employ commercially feasible methods to secure your Personal Data, we cannot guarantee its absolute security or prevent malicious attackers or destructive code from entering or targeting our websites or services.

8. COOKIES

8.1 Cookies are small text files stored in your browser's file directory when you visit our websites and platforms, so that the next time you visit our website or platform, your browser will use the cookie and relay the information back to us or third party companies which provide us with web analytics and intelligence about our websites and platforms.

8.2 Our websites and platforms may use cookies as follows:

8.2.1 - as necessary in order to enable our websites and platforms to operate, for example, to enable you to log onto secure parts of our websites and platforms;
8.2.2 - to collate information on your search and browsing history within our websites and platforms in order to better tailor our products and services to your interests and needs, such as to personalise the websites and platforms for you and deliver prompts which may be of particular interest to you;
8.2.3 - to track and compile statistics about visitors who interact with the websites, platforms and other content; and/or
8.2.4 - making our websites and platforms easier to use, for example, to help speed up your future interactions with our websites and platforms by storing your selected inputs so that you are not constantly asked for the same information.

9. YOUR CHOICES

9.1 Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you delete or disable the cookies associated with our websites and platforms by changing the settings on your browser, this may impact your user experience while on our websites or platforms, including but not limited to your ability to enter or use certain part(s) of our websites or platforms.

9.2 If you have registered for an account with us, you may review and update certain account information by logging into your account, or by contacting us in the manner specified below. You should ensure that all Personal Data submitted to us is accurate, true and correct, as failure on your part to do so may affect our ability to provide you with any products and/or services.

10. WE DO NOT TARGET OUR WEBSITES OR SERVICES AT EUROPEAN INDIVIDUALS

10.1 Please note that we do not take any deliberate steps to direct the offering of our websites or services at individuals located in the European Economic Area and/or the United Kingdom (together, “Europe”). For example, we do not accept payment for our services in the currency of any country(ies) in Europe, we do not take any steps to target sales of our services to individuals in Europe, we do not take any ‘search engine optimisation’ related steps intended to facilitate the use, promotion or availability of our websites or services by or to users in Europe etc.

10.2 In addition, we do not take any steps to monitor any behaviours of any individuals that we are aware (or have any reasonable means to be aware) occur in Europe. In particular, we do not use any Personal Data (including any such data collected through analytics technologies deployed on the website) in any way that has a specific purpose in mind, whether concerning its initial collection or any further use, that relates to any individual’s behaviour occurring within Europe.

11. CONTACTING US – QUESTIONS, FEEDBACK, AND EXERCISING YOUR RIGHTS

11.1 If you have any questions or feedback relating to your Personal Data or our Privacy Policy or would like to obtain access and make corrections to your Personal Data records, subject to applicable law, you can email us at contact@orus.info

11.2 Please note that if you have provided your Personal Data to a third party, you should contact such third party directly.

11.3 While we respect your decision to withdraw your consent to any processing of your Personal Data, please note that depending on the nature of your request, Orus may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may also result in the termination of any agreements you have with Orus, and your being in breach of your contractual obligations or undertakings. Orus's legal rights and remedies in such event are expressly reserved. Please also note that withdrawing consent does not affect our right to continue to process Personal Data where such processing without consent is permitted or required under applicable laws.

11.4 Upon receipt of your written request, we may require reasonable time to process your request and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.