Privacy Policy ORTHRUS AM Version 1.0 Date 12.3.2021 About Us ORTHRUS AM LTD (Company Number 13191669) 20-22 Wenlock Road, London, England, N1 7GU Email: service@oets.pro
I. INTRODUCTION Welcome! Thank you for visiting OETS.ONLINE, OETS.PRO, OETS.CLUB, (“ORTHRUS AM”), a digital asset trading website, which is provided by ORTHRUS AM. By visiting, accessing, or using ORTHRUS AM WEBPAGE and associated application program interface or mobile applications (“Site”), you consent to the policies and practices of our privacy policy (the “Privacy Policy”), so please read them carefully. This Privacy Policy explains how ORTHRUS AM uses your Personal Data (defined below) as we provide you with access and utility through our digital asset trading platform via software, API (application program interface), technologies, products and/or functionalities (“Service”). In the course of providing you our Service, to abide by the laws in the jurisdictions that we operate, and to improve our services, we need to collect and maintain personal information about you. As a rule, we never disclose any personal information about our customers to any non-affiliated third parties, except as described below. We may update this Privacy Policy at any time by posting the amended version on this site including the effective date of the amended version. We will communicate any material changes to this Privacy Policy via email. II. DEFINITIONS Digital Asset As used herein, “Digital Asset” means a digital asset, such as bitcoin or ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value. Personal Data As used herein, “Personal Data” means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person. When you access or use the ORTHRUS AM Platform or any part thereof, or communicate with ORTHRUS AM or any of its officers, employees, or agents, whether through written, published or electronic means, the telephone or otherwise, ORTHRUS AM may collect or receive personal or non-personal information or data about, in connection with, or from you, including, without limitation, through cookies, pixel tags, website and data analytics, and other technologies, in accordance with the Personal Data Protection Act 2012 (“PDPA”). Personal information or data may include, without limitation, your name, contact information, user profile, national identity information, and information about your financial status. Non-personal information or data may include, without limitation, your browser information, internet protocol address, how you use the ORTHRUS AM Platform or any part thereof, and aggregated information. ORTHRUS AM will, as far as possible, inform you at each collection point as to what information is required and what information is optional. III. WHAT PERSONAL DATA WE COLLECT ORTHRUS AM collects, processes, and stores Personal Data collected from you via your use of the Service or where you have given your consent. This Personal Data may include contact details, copies of identification documentation provided by you or derived from publicly accessible databases, your government identification number as well as information relating to your device or internet service (such as an IP address and a MAC number). We collect information you provide during the ORTHRUS AM onboarding process, which may be a completed, incomplete, or abandoned process. We collect, use, store, and transfer your Personal Data, which may include the following: Operating within the European Economic Area (“EEA”), we collect, store, and process your personal information in accordance with the provisions of the General Data Protection Regulation (GDPR) and Data Protection Act. To understand more about how we protect the data collected from individuals and entities located within the EEA, please see the details below. Individual customers: Email address Mobile phone number Full legal name (including former name, and names in local language) Nationality Passport number, or any government issued ID number Date of birth (“DOB”) Proof of identity (e.g. passport, driver’s license, or government-issued ID) Residential address Proof of residency Additional Personal Data or documentation at the discretion of our Compliance Team Corporate customers: Corporate legal name (including the legal name in local language) Incorporation/registration Information Full legal name of all beneficial owners, directors, and legal representatives Address (principal place of business and/or other physical locations) Proof of legal existence Description of the business Percentage of ownership for Individual/corporate owners Contact information of owners, principals, and executive management (as applicable) Proof of identity (e.g., passport, driver’s license, or government-issued ID) for significant individual beneficial owner of the institutional customer entity Personal Data for each entity’s significant beneficial owner of the institutional customer entity (see the “Individual Customer” section above for details on what Personal Data we collect for individuals) Source of wealth Amount of bitcoin or other digital assets projected to be injected IV. COLLECTION AND TRANSFER OF DATA OUTSIDE OF THE EEA As outlined above, we may collect Personal Data from customers located in the EEA. To facilitate the services we provide to customers located in the EEA, we request explicit consent for the transfer of Personal Data from the EEA to outside of the area. 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 ORTHRUS AM and our services. You will have the ability to withdraw your digital assets; however, all other functionalities will be disabled. V. HOW WE USE YOUR PERSONAL DATA ORTHRUS AM uses Personal Data to communicate with you and to administer, deliver, improve, and personalize the Service. ORTHRUS AM might also generate generic data out of any Personal Data we collect and use it for our own purposes. We may also use such data to communicate with you in relation to other products or services offered by ORTHRUS AM and/or its partners. We do not share your Personal Data with third parties (other than partners in connection with their services to ORTHRUS AM) except where you have given your consent and further detailed below. We may share your Personal Data with third parties: (a) if we think that sharing it is necessary to enforce the Terms of Service; (b) to comply with government agencies, including regulators, law enforcement and/or justice departments; (c) to third parties who provide services to ORTHRUS AM (such as administration or technical services); (d) in connection with the sale or transfer of our business or any part thereof. Additionally, we have implemented international standards to prevent money laundering, terrorist financing and circumventing trade and economic sanctions and will implement final Virtual Financial Asset rules and regulations when effective, which will likely require us to undertake due diligence on our customers. This may include the use of third-party data and service providers which we will cross-reference with your personal information. VI. HOW WE STORE YOUR PERSONAL DATA The data that we collect from you may be transferred to, and stored at, a destination outside of your country. It may also be processed by staff operating outside of Europe who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing, except customers located in the EEA, as detailed above. All information you provide to us is stored on our and/or third party cloud servers. VII. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL DATA You have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold about you is accurate and up-to-date. If any of your Personal Data is inaccurate, you may request to update your information. You may also request to delete your Personal Data, with exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, please service@oets.pro with the subject “DATA INQUIRY”. In response to data access, correction, or deletion request, we will verify the requesting party’s identity to ensure that he or she is legally entitled to make such request. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee should your request be repetitive or onerous. VIII. MARKETING We may communicate company news, promotions, and information relating to our products and services provided by ORTHRUS AM. We may share Personal Data with third parties to help us with our marketing and promotional projects, or sending marketing communications. By using ORTHRUS AM, you accept this Privacy Policy and you agree to receive such marketing communications. Customers can opt out from these marketing communications at any moment. If you do not want to receive these communications, please send an email service@oets.pro For product related communications, such as policy/terms updates and operational notifications, you will not be able to opt out of receiving such information.
IX. COOKIE USAGE While you access GC, we may use the industry practice of placing a small amount of data that will be saved by your browser (Cookies). This information can be placed on your computer or other devices used to visit ORTHRUS AM. This information help us recognize you as a customer, collect information about your use of ORTHRUS AM to better customize our services and better your experience. We may also use the information collected to ensure compliance with our compliance program, and to ensure your account security has not been compromised by detecting irregular or suspicious account activities. Most browsers are setup to accept cookies automatically. Some Cookies expire when you finalize the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of ORTHRUS AM services or your user experience.
These cookies are all 'session cookies', which means that they will end when you close your website browser. X. INFORMATION SECURITY We endeavor to protect ORTHRUS AM and you from unauthorized access, alteration, disclosure, or destruction of Personal Data we collect and store. We take various measures to ensure information security, including encryption of the ORTHRUS AM communications with SSL; required two-factor authentication for all sessions; periodic review of our Personal Data collection, storage, and processing practices; and restricted access to your Personal Data on a need-to-know bases for our employees and vendors who are subject to strict contractual confidentiality obligations. XI. CONTACTING OKEX ABOUT PRIVACY QUESTIONS OR CONCERNS If you have any questions about this Privacy Policy or the use of your Personal Data, please contact us by sending an email to the following address service@oets.pro with the subject “PRIVACY REQUEST”. XII. CHANGES TO OUR PRIVACY POLICY Any changes we may make to our Privacy Policy in the future will be posted on this page and, when appropriate, we will notify you by email.
Data protection
What rights do you have regarding your data?
20-22 Wenlock Road, London, England, N1 7GU
3. Data Protection Officer DISCLAIMER Please carefully read this important information before entering this Website. It contains legal and regulatory notices relevant to the information contained on this Website. By accepting Our disclaimer you agree to be bound by Our terms and conditions set forth herein (“Terms and Conditions”). If you do not accept these Terms and Conditions, please do not continue to use or access any pages of this Website. QUESTO PARAGRAFO E' PER LA PAGINA WEB No Advice The information and material contained on this Website/Brochure (SEARCH AND REPLACE WEBSITE WITH BROCHURE FOR BROCHURE AND VICEVERSA...) is not financial advice or solicitation to the public saving. The material contained in this Website is directed only at persons or entities in any jurisdiction or country where such access to the information contained herein and use thereof is not contrary to local law or regulation. Accordingly, all persons who access this Website are required to inform themselves of and to comply with any such restrictions. No Offer Nothing on this Website constitutes or forms part of any offer to issue or sell, or any solicitation of any offer to subscribe or purchase, shares, units or other interests (“Shares”) in investments referred to herein. The information contained on this Website may not be treated as an offer of solicitation:
Nor shall this Website form the basis of, or be relied on in connection with, any contract for Shares. Applications to invest in any product referred to on this Website must only be made on the basis of the documentation relating to the specific investment and you should refer to your investment adviser. If you are in any doubt about the information contained on this Website, please contact us or consult a professional financial adviser. Risks of Investing Investing entails risks, including possible loss of principal. No representation is being made that any investment or transaction will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided. No assurances or guarantees are given regarding the performance of any investment. Past performance may not be repeated and should not be seen as a guide to future performance. The value of investments and the income from them may go down as well as up and investors may not get back the amount originally invested. Exchange rates may cause the value of overseas investments and the income arising from them to rise or fall. The levels and bases of and reliefs from taxation may change. Any tax reliefs referred to are those currently available and their value depends on the circumstances of the individual investor. Investors should consult their own tax adviser in order to understand any applicable tax consequences. Materials relating to the investments mentioned on this Website should be read in conjunction with a prospectus and key investor information document (available through this Website) that describes charges, expenses, and risks. Read it carefully before any investment. Marketing The distribution of the information on this Website may be restricted by law in certain countries. This Site and the information on it is not addressed to any person resident in the territory or country or jurisdiction where such distribution would be contrary to local law or regulation. The Manager disclaims all responsibility if you access or download any information from this Site in breach of any law or regulation in the country of which you are a citizen or in which you are residing or domiciled. Accuracy of Information The information contained on this Website (including any expression of opinion or forecast) has been obtained from, or is based on, sources believed by the Manager and its associated companies to be reliable, but are not guaranteed as to its accuracy or completeness. Such information is provided without obligation and on the understanding that any person who acts upon it or changes his investment position in reliance on it does so entirely at one’s own risk. The information contained on this Website does not constitute an offer to buy or sell or an invitation to make an offer to buy or sell shares in any investment fund referred to herein. The information posted on this Website is current only as at the date it is first posted and may no longer be true or complete when viewed by you. All information contained on this Website may be changed or amended without prior notice although neither the Manager nor any of its associated companies undertake to update this Website regularly. No Liability This information on this Website has been prepared, approved and issued by the Manager and the information and opinions contained in this Website have been compiled, or arrived at, in good faith and on the basis of publicly available information, internally developed data and sources believed to be reliable as at the date of publication. However, no representation, warranty or undertaking, express or implied, is made by the Manager, its associated companies or any other person as to the reliability, accuracy or completeness of the information contained on this Website and no liability is accepted by such persons for the reliability, accuracy, fairness, or completeness of such information. The information posted on this Website is current only as at the date it is posted and may no longer be true or complete when viewed by you. The Manager cannot guarantee that content will be accurate, complete and current at all times. To the extent that any information on this Website relates to a third party, such information has been provided by that third party and is the sole responsibility of such third party and the Manager accepts no liability for such information. All content on the Website is subject to modification from time to time without notice. Please contact the Manager for further information regarding the validity of any information contained on this Website. SUBJECT TO THE ABOVE PARAGRAPH, THE MANAGER HEREBY EXCLUDES ALL LIABILITY FOR ANY DIRECT, INDIRECT, SPECIAL, OR CONSEQUENTIAL LOSS OR DAMAGE (IN EACH CASE INCLUDING BUT NOT LIMITED TO: BUSINESS INTERRUPTION, LOSS OF PROFITS, LOSS OF REVENUE, LOSS OF ANTICIPATED SAVINGS AND/OR LOSS OF GOODWILL) ARISING FROM, OR IN CONNECTION
WHETHER OR NOT SUCH LOSS IS REASONABLY FORESEEABLE AS AT THE DATE YOU ACCESS THIS WEBSITE OR MANAGER HAS BEEN ADVISED OF THE POSSIBILITY OF YOU INCURRING SUCH LOSS OR DAMAGE, AND WHETHER OCCASIONED BY THE NEGLIGENCE OF MANAGER OR ITS EMPLOYEES, AGENTS, OR SUB-CONTRACTORS. You should be aware that the Internet is not a completely reliable transmission medium. Neither the Manager nor any of its associated companies accept any liability for any data transmission errors such as data loss or damage or alteration of any kind, including, but not limited to any direct, indirect or consequential damage, arising out of the use of the products or services referred to herein. In addition, neither the Manager nor any of its associated companies accept any responsibility for the security or confidentiality of information transmitted across the internet to or from the Manager or any of its associated companies and any such transmission of information is entirely at your own risk. Indemnity You agree to indemnify, defend, and hold harmless the Manager, its affiliates and licensors, and the officers, directors, employees, and agents of the Manager and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this Website. Material Interests The Manager, its associated companies and its and their members and/or directors, officers and/or employees may have holdings in the investment funds referred to on this Website and may otherwise be interested in transactions that you effect in those funds. Linked Websites This site may be linked to third-party websites or contain information provided by third parties. Neither the Manager nor any of its associated companies make any representation as to the accuracy or completeness of such websites or information, have not and will not review or update such websites or information, and caution browsers that any use made of such websites or information is at their own risk. Neither the Manager nor any of its associated companies accept any liability arising out of the information contained on any linked website or information on this Website provided by a third party and the use of such sites and information is at your own risk. Cookies A “cookie” is a piece of information that is saved to your PC’s hard disk by the webserver. Confirmation of reading and accepting these Terms and Conditions will place a cookie on your PC”s hard disk. This will ease your navigation around this Website by not popping up these Terms and Conditions again during this browser session. This cookie is temporary and will be removed when you close your browser. The cookie is not used for any other reason Telephone Recording The Manager (or any member of the Manager’s worldwide group of companies) may monitor and record telephone/Skype or other medium conversations to check and verify instructions, to maintain high-quality service standards, to comply with regulatory requirements and for the security of operational and business processes. Intellectual Property Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by the Manager and its associated companies, their licensors or relevant third party content providers. You may use the information on this Website and reproduce it in hard copy for your personal reference only. Such information may not otherwise be reproduced, distributed, stored in a data retrieval system or transmitted, in any form or by any means ” electronic, mechanical, photocopying, recording or otherwise ” without the prior written permission of the Manager. Nothing on this Website should be considered as granting any licence or right under any trademark of the Manager or its associated companies or any third party. Licence The Manager permits users of this Website to make transient copies of it as necessary incidental acts during the viewing of it. The Manager also permits users to download or print a hard copy of individual pages and/or sections of this Website for their own use, provided that users do not remove any copyright or other proprietary notices and that such copies are for the user”s own individual use. You may not modify, copy, distribute, transmit, post, display, perform, reproduce, publish, license, create derivative works from, transfer, or sell any pages, data, information, software, products, content, or services obtained from this Website unless you have obtained the prior written permission of the Manager. You may not link to this Website, nor frame it, without the express written permission of the Manager. Downloading Software and Files If you download software or files from this Website, the software ”including any files or images incorporated in or generated by the software and data accompanying the software” and files (collectively, the “Files”) are licensed to you by the Manager solely for your personal, non-commercial use. However, the Manager does not transfer title in the Files to you. You own the medium on which the Files are recorded, but the Manager and its licensors retain full and complete title in and to the Files, including all intellectual property rights therein. Save as otherwise permitted by applicable law, you may not redistribute, sell, decompile, reverse engineer, disassemble, or otherwise reduce the Files to any other form whatsoever. Termination The rights granted to you herein terminate immediately upon any violation by you of these terms of use. The Manager reserves the right to terminate your access to this Website at any time, without notice, for any reason whatsoever. You agree that the Manager shall not be liable to you or any third party for any termination of your access to this Website. Governing Law Your use of this Website and downloads from it and the operation of these Terms and Conditions shall be governed by and interpreted in accordance with the laws of UK. The UK Courts shall have exclusive jurisdiction over any dispute arising out of your use of this Website. If any provision in these Terms and Conditions is deemed unlawful, invalid, or for any reason unenforceable, then that provision will be deemed severed from, and will not affect the validity and enforceability of, the remaining provisions. These Terms and Conditions represent the entire agreement between the Manager and the user relating to the subject matter herein. Conditions of Use If you have read and understood these conditions of use you may click the “ACCEPT” button below to proceed. By doing so you acknowledge that you understand the conditions of use and agreed to abide by them. By clicking “ACCEPT” below this will certify that you have read the above Terms and Conditions and that you understand and agree that: Nothing contained on this Website is deemed to be an offer to sell; Investments are subject to risk and can gain or lose money; and Some or all investment services or products may not be available to you in your jurisdiction. |