Version 1.0 Date 12.3.2021
ORTHRUS AM LTD (Company Number 13191669)
20-22 Wenlock Road,
London, England, N1 7GU
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.
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.
Mobile phone number
Full legal name (including former name, and names in local language)
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)
Proof of residency
Additional Personal Data or documentation at the discretion of our Compliance Team
Corporate legal name (including the legal name in local language)
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 firstname.lastname@example.org 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.
Customers can opt out from these marketing communications at any moment. If you do not want to receive these communications, please send an email email@example.com
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
What rights do you have regarding your data?
20-22 Wenlock Road,
London, England, N1 7GU
3. Data Protection Officer
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