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OrangeX.com Privacy Notice

Last updated: December 4, 2024

1. Introduction

This Privacy Policy (this "Policy") applies to the trading platform (including any applicable mobile applications and websites used to access the same) (collectively the "Platform") provided by OrangeX.com (the "the Company", "we", "us", or "our"). It describes how the Company collects, uses, and discloses Personal Information that we obtain from users of the platform and any account services provided through the platform, and how we use and disclose that information. For purposes of this Policy,"Personal Information" refers to information supplied by a user from which the identity of such User may be directly orindirectly determined.
We prioritize the security and privacy of your Personal Information. We are committed to ensuring that all Personal information is processed in accordance with the highest standards of data protection and privacy regulations, and that technical and organizational measures are put in place. Our robust data management practices are designed to safeguard your information and maintain your trust.
It is important that you familiarize yourself with the provisions of this Policy together with terms and conditions and any other privacy notices we may provide on specific occasions when we are collecting or processing personal information so that you are fully aware of how and why we are using your Personal Information.
By registering for and using the Platform, you agree that your Personal Information will be handled as described in this Policy and the Terms and Conditions applicable to the Platform (the "Serviice Agreement"); capitalized terms used herein shall have the same meaning as set forth in the Service Agreement
We are committed to transparency in our data practices and aim to provide users with clear information regarding the processing of their personal data.

2. Scope and Applicability

As part of the Company’s daily operations, we collect personal data to provide users with our products and services. This Policy outlines how we process your personal data across our Website and related services.
The personal data collected by OrangeX.com will only be used for the purposes for which it was originally collected or as permitted under applicable legislation. It will be processed to fulfill our contractual obligations to users, comply with legal obligations (such as AML/KYC regulations), and pursue legitimate business interests.
This Policy applies to the processing of personal data regardless of the method or environment in which the personal data is provided (e.g., online, paper forms, by phone, etc.) and whether processed manually or through automated means.
We are committed to ensuring the security, confidentiality, and integrity of your personal data while providing a seamless user experience across multiple cryptocurrencies and services offered by the Company.

3. Our Commitment to You

OrangeX.com fully understands the importance of maintaining the confidentiality and privacy of your personal data. We respect your privacy and are committed to taking all reasonable measures to protect and safeguard your personal data in accordance with the highest standards of data protection and security.
We employ various technical and organizational measures (TOMs) to protect personal data, including but not limited to:
  • Encryption of personal data both in transit and at rest,
  • Access controls and authentication mechanisms to ensure that only authorized personnel can access personal data,
  • Employee training on data privacy and security best practices to mitigate risks of accidental or unlawful data breaches.
In addition, we are committed to:
  • Regularly reviewing and updating our data protection practices,
  • Ensuring the security of processing in line with GDPR Article 32,
  • Informing users about how their personal data is processed and their rights under the GDPR,
  • Addressing any concerns users may have regarding their data processing rights, security, or privacy.

4. How do we collect your Personal Data?

We use different methods to collect information from and about you, including through:
Direct interactions:
You may provide us with your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data and Marketing and Communications Data by directly interacting with us, including by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal data you provide when you:
  • Visit our Site or App;
  • Apply for our Services;
  • Create an account;
  • Make use of any of our Services;
  • Request marketing to be sent to you, for example by subscribing to our newsletters;
  • Enter a competition, promotion or survey, including through social media channels; or
  • Give us feedback or contact us.
Legal Basis: We process this data based on contractual necessity (for account creation and service provision), consent (for marketing communications), and legitimate interests (for improving services and fraud prevention).
Automated Technologies or Interactions:
As you interact with us via our Site or App, we automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other online identifiers. We will also collect Transactional Data and Usage Data. You may find more information about how we use cookies through the Cookie Preferences link.
Legal Basis: Data collected via cookies and tracking technologies is processed based on consent (for cookies and marketing preferences), and legitimate interest (for analytics and improving services).
You have the right to manage or withdraw your consent for the use of cookies at any time via the Cookie Preferences link available on our Site.
Social Media Widgets and Similar Links:
Our Site may contain links, social media plug-ins, "widgets", "tweet", "share" and "like" buttons linked to social media platforms such as Facebook, X (Twitter), Instagram, Threads, Discord, LinkedIn, Reddit and Telegram. Please note that when you interact with these social media plug-ins, your data may be collected by these third-party platforms. For more information on how these platforms process your data, please refer to their respective privacy policies.

5.What Personal Data do we collect?

Personal data
Personal data, or personal information means any information that relates to an identified or identifiable living individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.
Category of personal dataExamples of specific pieces of personal data
Identity Data
  • full name
  • maiden name
  • username or similar identifier
  • date of birth
  • biometric information, including a visual image of your face
  • national identity card, passport, driving licence or other form of an identification document.
Contact Data
  • country of residence
  • email address or telephone numbers
  • proof of address documentation (if applicable))
Financial Data
  • bank account
  • payment card details
  • virtual currency accounts
  • stored value accounts
Transactional Data
  • details about transaction to and from you
  • other details of any transactions you enter into using the Services, Site or App.
Technical Data
  • internet connectivity data
  • internet protocol (IP) address
  • operator and carrier data
  • login data
  • browser type and version
  • device type, category and model
  • time zone setting and location data
  • language data
  • application version and SDK version
  • browser plug-in types and versions
  • operating system and platform
  • diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and
  • other information stored on or available regarding the devices you allow us access to when you visit the Site, or use the Services or the App.
Profile Data
  • username and password
  • identification number as our user
  • information on whether you have Orangex.com App account and the email associated with your accounts
  • requests by you for products or services
  • your interests, preferences and feedback
  • other information generated by you when you communicate with us, for example when you address a request to our customer support.
Usage Data
  • information about how you use the Site, the Services, mobile applications and other offerings made available by us, including:
  • device download time
  • install time
  • interaction type and time
  • event time, name and source.
Marketing and Communications Data
  • your preferences in receiving marketing from us or third parties
  • your communication preferences
  • your survey responses.

6. How do we process your Personal Data?

Lawful Basis for Processing
We will only process your personal data when we have a lawful basis to do so, in accordance with applicable legislation. Most commonly, we will process your personal data in the following circumstances:
performance of a contract: We process your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract. We rely on this basis for the provision of our services, such as account creation, processing transactions, and fulfilling other contractual obligations.
legitimate interests: We process your data based on our legitimate interests (or those of a third party) as long as your interests and individual rights do not override those interests. For example, we may process your data for fraud prevention, to ensure the security of our platform, or for the improvement of our services. We conduct regular assessments to ensure that our legitimate interests are balanced against your rights.
compliance with a legal obligation: We process personal data where it is necessary to comply with a legal obligation to which we are subject. For example, we are required to collect and process personal data to comply with anti-money laundering (AML) and Know Your Customer (KYC) regulations.
consent: We process your personal data when you provide freely given, specific, informed, and unambiguous consent to us. This may include consent for marketing communications or other optional services. In cases where consent is required, we will request it in a clear and explicit manner. You have the right to withdraw your consent at any time by contacting us or updating your preferences in your account settings.
Purposes for which we use your personal data
We have set out below, in table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose and/or activityCategories of personal dataLegal basis for processing
To register you as a new customer
  • Identity Data
  • Contact Data
  • Financial Data
  • Performance of a contract
To carry out and comply with anti-money laundering requirements
  • Identity Data
  • Contact Data
  • Financial Data
  • Transactional Data
  • Technical Data
  • Profile Data
  • Compliance with a legal obligation
To process and deliver the Services (including products offered by third-party service providers with whom we work) and any App features to you, including to execute, manage and process any instructions or orders you make through the Services
  • Identity Data
  • Contact Data
  • Financial Data
  • Transactional Data
  • Technical Data
  • Performance of a contract
  • Consent, if required
To prevent abuse of our Services and promotions
  • Identity Data
  • Contact Data
  • Financial Data
  • Transactional Data
  • Technical Data
  • Marketing and Communications Data
  • Legitimate interests: safeguarding the security and integrity of our Services by detecting and preventing fraud and unauthorized activities, thereby protecting both our business and our customers
To manage our relationship with you which will include asking you to leave a review, take a survey or keeping you informed of our company's business and product development
  • Identity Data
  • Contact Data
  • Profile Data
  • Transactional Data
  • Marketing and Communications Data
  • Performance of a contract
  • Consent, if required
To keep our recordsupdated and to studyhow customers use ourproducts/services
  • Identity Data
  • Contact Data
  • Profile Data
  • Transactional Data
  • Technical Data
  • Marketing and Communications Data
  • Legitimate interests: to maintain accurate customer data for effective service and informed business decisions, and to enhance our offerings by understanding customer interactions
  • Consent, if required
To manage, process, collect and transfer payments, fees and charges
  • Identity Data
  • Contact Data
  • Financial Data
  • Transactional Data
  • Performance of a contract
To obey applicable legislation and handle complaints, including:
  • manage risk and crime prevention involving performance of anti-money laundering, counter terrorism, sanction screening, fraud and other background checks
  • detect, investigate, report and prevent financial crime in a broad sense and
  • ensure your account's security, in order to honor requests regarding information and/or changes to your account
  • Identity Data
  • Contact Data
  • Financial Data
  • Transactional Data
  • Technical Data
  • Profile Data
  • Usage Data
  • Sensitive Data (a.k.a. Special Categories Data*) data that you give us directly or that we receive from third parties and/or publicly available sources:
    - data which might be revealed by KYC or other background checks (for example, because it has been reported in the press or is available in public registers);
    - data collected via facial scan as part of identity verification processes;
    - data that is incidentally revealed by photographic ID although we do not intentionally process this personal data.
  • Compliance with a legal obligation
  • Performance of a contract
  • Legitimate interests: ensuring that we are not involved in dealing with the proceeds of criminal activities and do not assist in any other unlawful or fraudulent activities, as well as to develop and improve our internal systems for dealing with financial crime and to ensure effective dealing with complaints* Special Categories Data: where we process such data we rely on reasons of substantial public interest under the Seychelles AML CFT Act, the EU AML Directives, the UK AML framework and so forth.
To enable you to partake in a prize draw, competition or complete a survey
  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Performance of a contract
  • Consent, if required
To gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business
  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Legitimate interests: understanding our customers and improving our products and services
To administer and protect our business, our Site, App(s) and social media channels including bans, troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data
  • Identity Data
  • Contact Data
  • Financial Data
  • Technical Data
  • Transactional Data
  • Usage Data
  • Legitimate interests: to run our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Technical Data
  • Marketing and Communications Data
  • Legitimate interests: to study how customers use our products/services, to develop them, to grow our business and to form our marketing strategy
  • Consent, if required
To use data analytics to improve our website, products/services, marketing, customer/user relationships and experiences
  • Technical Data
  • Usage Data
  • Marketing and Communications Data
  • Legitimate interests: to study how customers use our products/services, to develop them, to grow our business and to form our marketing strategy
  • Consent, if required
To make suggestions and recommendations to you about goods or services that may be of interest to you
  • Identity Data
  • Contact Dat
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing and Communications Data
  • Legitimate interests: to develop our products/services and grow our business
  • Consent, if required
To use the services of social media platforms or advertising platforms some of which will use the personal data they receive for their own purposes, including marketing purposes
  • Technical Data
  • Usage Data
  • Consent
To use the services of and enter into partnerships with, financial institutions, third-party partners whose products form a part of the Services offered, crime and fraud prevention companies, risk measuring companies, which will use the personal data they receive for their own purposes in their capacity of independent controllers
  • Identity Data
  • Contact Dat
  • Financial Dat
  • Transactional Data
  • Technical Data
  • Usage Data
  • Legitimate interests: to conduct our business activities and provide the Services to you, and to participate actively in the prevention of crime and fraud

Automated Decision Making

What is an automated decision?
Automated decision is usually a decision that may impact you and is made automatically based on software algorithms, without human intervention. As an illustrative example, we use automated decisions to complete the onboarding process of a new customer or to perform anti-fraud monitoring.
Why is an automated decision important to you?
Depending on the particular case, using your personal data may lead to automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you.
How do we protect your interests regarding automated decisions?
The rights and interests of individuals whose personal data undergoes automated decision-making is safeguarded through appropriate measures. When an automated decision is made about you, you have the right to oppose the decision.. If you need more detailed information or wish to exercise this right, please contact us.

Marketing

We may use your Identity Data, Contact Data, Technical Data, Transactional Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us and consented to receive marketing communications, or if you have purchased from us and you have not opted out of receiving such communications. We will use your Marketing and Communications Data for our respective activities.

Third-party marketing

We will obtain your opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

Youmay opt out of marketing communications at any time by following the opt-out links on any marketing message sent to you.
Further, you can login and cancel the marketing messages in Notifications.
Where you opt out of receiving marketing messages, this will not apply to service messages which are directly related to the use of our Services (e.g. maintenance, change in the terms and conditions and so forth).
Our Use of Cookies and Other Tracking Mechanisms
We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Platform. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).
Cookies.

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Platform, while others are used to enable a faster log-in process or to allow us to track your activities at our Platform. There are two types of cookies: session and persistent cookies.

Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Platform. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Platform.

Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

Please note that our systems do not currently respond to do-not-track signals.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The general settings on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Users of our Platform who disable cookies will not be able to browse certain areas of the Platform.
Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Platform. We also may use other analytic means to evaluate our Platform. We use these tools to help us improve our Platform, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your Personal Information with these third parties.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Sale or transfer of business
We may also need to process your data in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving all or a part of our shares, business or assets. This will be based on our legitimate interests in carrying out such transactions, or to meet our legal obligations.

7. Contacting You

The Company or its affiliates, business partners, associates or other agents may, from time to time, contact you by telephone, email, or otherwise, for the purposes of offering you further information about the Company’s products and services, or to inform you of promotional offerings, or for marketing purposes, or to conduct market research, with your prior consent.
In case you do not agree to receive these marketing messages or calls, this will not have any impact on the provision of our services to you.
If you wish to opt-out of any further contact at any time and for whatever reason, you are entitled to do so by contacting the Company’s back-office department via email dpo@orangex.com and requesting in writing that you wish no further contact in relation to the above reasons.

8. Disclosure and Transfer of your Personal Data

We may share your personal data with third-party service providers, agents, subcontractors, group companies, and affiliates (as described below) to carry out specific tasks, complete services, and provide the use of the App on our behalf. When using third-party service providers, we require them to respect the security of your personal data and to process it in accordance with applicable data protection laws, including GDPR.
We may disclose your personal data to the following entities:
  • Companies and organizations that assist us in processing, verifying, or refunding transactions/orders you make and in providing any services that you have requested;
  • Third-party service providers whose products, services, or applications are hosted/integrated on our Site and App;
  • Identity verification agencies for conducting necessary verification checks, such as AML/KYC (Anti-Money Laundering/Know Your Customer);
  • Fraud prevention and crime prevention agencies to help combat crimes, including fraud, money laundering, and terrorist financing;
  • Any entity to whom we may lawfully transfer or assign our rights and obligations under the relevant terms and conditions governing the use of our Services;
  • Any third party due to the restructure, sale, or acquisition of our group or affiliates, provided that the recipient uses your information for the same purposes for which it was originally collected;
  • Regulatory and law enforcement authorities inside or outside the Republic of Seychelles, when required or permitted by law.
Specifics Regarding the Use of Blockchain Technology
Certain services provided by OrangeX.com utilize blockchain technology, which operates on a decentralized network. Transactions are recorded in an immutable and transparent manner on the blockchain. This ensures the integrity and security of the data stored on the blockchain. However, it is important to note that once data is added to the blockchain, it becomes virtually impossible to remove or delete.
Transfer of Information Across Jurisdictions
We may store your Personal Information on servers located in countries where our main offices are based. If the jurisdiction in which your data is stored is outside your country of residence, you consent to the transfer of your personal information to such jurisdictions. This transfer is necessary for the purposes of providing you with our services, even if the destination jurisdiction may have less stringent data protection laws than your jurisdiction of residence.
We will take all reasonable steps to ensure that security measures are in place to protect your personal information in accordance with the applicable laws of your jurisdiction, and to ensure the security of your personal data during the transfer process.

9. Safeguard Measures

While there is an inherent risk when data is shared over the internet, we have implemented appropriate security measures to safeguard your personal data from being accidentally lost, misused, damaged, unauthorized access, altered, or disclosed in an unlawful manner. Additionally, we limit access to personal data to employees, agents, contractors, and other third parties who have a legitimate business need to know the information. These parties will only process your personal data based on our instructions and are subject to a duty of confidentiality.
To mitigate risks associated with the processing of your personal data, we have put in place the following security measures:
  • Organizational measures, including but not limited to:
    • Staff training on data protection principles and secure data handling.
    • Development of internal policies to ensure secure processing of personal data.
  • Technical measures, including but not limited to:
    • Physical protection of data (e.g., secure access to server facilities).
    • Pseudonymization and encryption of personal data to ensure data confidentiality and integrity.
  • Measures to ensure ongoing availability, integrity, and accessibilityof personal data, including but not limited to:
    • Ensuring appropriate backups are held to prevent data loss and facilitate recovery in case of a system failure.
We also have procedures in place to address any suspected personal data breach. In the event of a breach, we will notify you and any relevant regulatory authorities as required by law. GDPR Article 33 mandates that a breach be reported within 72 hours if there is a risk to the rights and freedoms of individuals.

10. Our identification tools

To perform identity verification, OrangeX.com uses an in-house solution to collect and process necessary identification data. This process involves capturing photo images or video recordings of your face and ID document through a secure web or mobile interface. The collected data is used to comply with legal obligations, such as those under the Law on Prevention of Money Laundering and Terrorist Financing of the Saint Vincent, and for purposes of fraud and crime prevention, as well as risk management.
The face comparison results (match or mismatch) are retained only for as long as necessary to complete the verification process and comply with anti-money laundering (AML) regulations. We ensure that your facial data is used solely for one-time verification and is not stored as a facial template. It is also impossible to regenerate the raw data from the retained information.
By using this in-house solution, we verify that the individual in the ID document matches the person captured in the photo or video, providing a precise and efficient identity verification process.
If you prefer an alternative identification method, please contact us at dpo@orangex.com.

11. Automated decision making

In certain cases, the Company may implement automated decision-making processes, where decisions are made solely through automated data processing, without human intervention. This may include the use of software algorithms for tasks such as:
  • Verifying user identities;
  • Detecting fraudulent activities;
  • Assessing trading risks, and other necessary activities;
While automated decision-making helps us efficiently manage certain aspects of our services, we recognize the importance of fairness. If you believe that an automated decision has been inaccurate or unfair, you have the right to request a manual review of the decision. This right is in line with GDPR Article 22, which provides data subjects with the right to contest automated decisions that affect them.
For more information about your rights regarding your personal data, please refer to the section titled Your Rights Regarding Your Personal Data. Your Rights Regarding Your Personal Data.

12. Storage and Retention Period of your Personal Data

Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. When personal data is no longer necessary for the purpose for which it was collected, we will securely destroy the records. This means that we store your data for as long as it is necessary for provision of our services and as required by the retention requirements in laws and regulations. If the legislation of the Saint Vincent does not provide any applicable data retention period, it shall be determined by us, taking into account the legitimate purpose of the data retention, the legal basis and the principles of lawful processing of personal data.
The terms of data retention of the personal data for the purposes of the processing of the personal data as specified in this Policy are as follows:
  • as long as your consent remains in force, if there are no other legal requirements which shall be fulfilled with regard to the personal data processing. We reserve the right to retain records of any consent given and withdrawn for a period of time necessary to protect our rights;
  • in case of the conclusion and execution of contracts – until the contract concluded between you and us remains in force and up to 10 years after the relationship between you and us has ended;
  • the personal data collected for the implementation of the obligations under the Law on the Prevention of Money Laundering and Terrorist Financing shall be stored up to 10 (ten) years as provided in the Act No. 253/2008 Coll. on Certain Measures against Money Laundering and Terrorist Financing of the Saint Vincent. The retention period may be extended for a period not exceeding 2 (two) years, provided there is a reasoned request from a competent authority;
  • the personal data submitted by you through our website or via e-mail is kept for an extent necessary for the fulfilment of your request and to maintain further cooperation, but no longer than 6 months after the last day of the communication, if there are no legal requirements to keep them longer.
In the cases when the terms of data keeping are indicated in the legislative regulations, the legislative regulations are applied.
We may retain your personal data for a longer period when:
  • it is necessary in order for us to defend ourselves against existing or threatened claims, or to exercise our rights, or for the proper resolution of dispute, complaint or claim;
  • there is a reasonable suspicion of illegal activity;
  • it is required by applicable laws.
Upon expiration of the retention period, we will delete and/or reliably and irrevocably depersonalize your data as soon as possible, within a reasonable time required to perform such action.

13. Transfer of Personal Data outside the EEA

European Union (EU) data protection rules apply to the European Economic Area (EEA) which includes all the EU countries and non-EU countries: Iceland, Liechtenstein and Norway. If necessary, the Company may transfer your personal data to a country outside the EEA, for storage and/or for processing by staff operating outside the EEA who work for the Company and/or to our suppliers, business partners, associates, affiliates, agents, business introducers or service providers who are engaged on our behalf to fulfil our contractual obligations under the Client Agreement. Moreover, personal data we collect from you may be stored or processed in a jurisdiction that is different to the country in which the specific entity of the group you are dealing with is registered and established. Therefore, by entering into the Client Agreement with the Company and submitting your personal data, you agree to the transmittal, storing and processing of your personal data outside the EEA.
Nonetheless, when your personal data is transferred outside the EEA, the Company will take all steps reasonably necessary to ensure that the transfer is lawful, that the organization to whom your data are send provides data protection at an adequate level, or provided that receiving Company undertakes sufficient guarantees in accordance with the provisions of the GDPR to ensure that your personal data are treated securely.
Where it is not possible to avoid disclosing your personal data, and we are legally required to do so (e.g., by law or court order), we will comply with the applicable legal and regulatory obligations under Saint Vincent and European Union (EU) law. OrangeX.com will only transfer personal data outside the EU/EEA to a country that has not been recognized by the European Commission as having an adequate level of data protection, and which does not provide corresponding guarantees, if:
  • You have provided explicit consent to the proposed transfer after being informed by OrangeX.com of the potential risks associated with such a transfer;
  • The transfer is necessary to fulfill a contract between you (the client) and OrangeX.com, or to implement measures required by you before entering into a contract;
  • The transfer is necessary for the conclusion or execution of a contract between OrangeX.com and another individual or legal entity in your interest;
  • The transfer is required for important public interest reasons;
  • The transfer is necessary for the establishment, exercise, or defense of legal claims; or
  • The transfer is necessary to protect your vital interests when you are physically or legally incapable of giving consent.

14. Cookies and Links

The Company utilizes cookies to enhance user interaction on its Website. These small data files are sent from our Website and stored in your browser, allowing us to gather information about how you use our services. By collecting this data, we aim to tailor our offerings and provide a more personalized experience according to your preferences. Cookies contain a unique identifier but do not grant us access to your computer or any sensitive information beyond what you voluntarily share.
While cookies are employed across our Website, none of the data stored in them is linked to personal information you provide. You have the ability to manage cookie acceptance via your browser’s settings. Please note, however, that disabling cookies may limit your access to certain parts of the Website or affect the functionality of your customer account. We recommend reviewing our Cookies Policy to better understand how we use these files and other web tracking technologies.
Additionally, some of the Company’s partners, associates, and affiliates may also utilize cookies on the Website. As we do not have control over these third-party cookies, we cannot be held responsible for any loss or misuse of personal data that may occur as a result. If you visit external sites linked through our Website, this Policy does not cover them, so we advise reviewing their respective privacy policies to understand how your data is handled.

15. Your Rights regarding your Personal Data

In accordance with GDPR and Saint Vincent regulatory requirements, you have the following rights regarding the personal data we collect and process:
  • Right to Access
    You have the right to request access to the personal data we hold about you. This includes the right to know what personal data we process, the purposes of processing, and how long we retain your data. Upon request, we will provide a copy of your personal data free of charge, unless the request is excessive or unjustified.
  • Right to Rectification
    If you believe that the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update your data. We may ask for supporting documentation to verify the changes you request.
  • Right to Notification of Changes
    You may notify us of any changes to your personal data by emailing dpo@orangex.com. We will update your data accordingly. Please note that we may require evidence to support these updates.
  • Right to Erasure (Right to be Forgotten)
    You may request the deletion of your personal data when it is no longer necessary for us to process it. However, this right does not apply if we are required to retain your data for legal or regulatory purposes (e.g., anti-money laundering obligations). Deleting your personal data will result in the closure of your account.
  • Right to Information on Use and Processing
    You have the right to know how your data is being used and for what purposes it is being processed. You can request a copy of your personal data and further details regarding how and why we process it.
  • Right to Restrict Processing
    You have the right to request the restriction of processing in certain situations, such as:
    • Disputing the accuracy of the data (processing restriction applies while we verify the accuracy).
    • If the processing is unlawful, but you prefer restriction over deletion.
    • If we no longer require the data, but you need it to establish, exercise, or defend legal claims.
    • If you object to processing based on our legitimate interests, while we assess whether our interests override yours.
  • Right to Data Portability
    You have the right to request that we transfer your personal data to you or to another data controller in a structured, commonly used, and machine-readable format. After the transfer, we are no longer responsible for the use of your data by the third party.
  • Right to Withdraw Consent
    You may withdraw your consent to data processing at any time by contacting our Data Protection Officer (DPO) at dpo@orangex.com. The withdrawal of consent will stop future processing, but it does not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to File a Complaint
    If you believe that your data protection rights have been violated, or if your data is being mishandled, you have the right to lodge a complaint with the Saint Vincent Office for Personal Data Protection (Úřad pro ochranu osobních údajů) . For more information on how to file a complaint, you can visit their website at https://www.uoou.cz/en/.

16. Legal Disclaimer

The Company is not responsible for the use, misuse, or loss of personal data that may occur on external websites linked from the Company’s Website. Please note that the Company does not have control over, nor access to, the information provided to or collected by such third-party websites. When you choose to access co-branded or linked websites, the collection and processing of your personal data will be governed by the third party’s privacy policy, which may differ from ours. We encourage you to review the privacy policies of any third-party websites you visit.
You are solely responsible for maintaining the security and confidentiality of your login credentials. If unauthorized access occurs due to your negligence or the unauthorized actions of someone you have authorized, the Company will not be liable for any resulting damages or unauthorized use of your account. Any misuse or loss of your login credentials, whether due to negligence or unauthorized actions by yourself or individuals you have authorized, remains your responsibility.
The Company is not responsible for unauthorized access to your account or personal data due to actions or omissions on your part or those of individuals you have authorized.

17. Consent

The collection, use, and storage of your personal data by the Company are carried out based on your explicit consent. By entering into an agreement with the Company, creating a customer account, and using the Website, trading platforms, or payment gateways, you acknowledge and consent to the collection, use, and processing of your personal data as outlined in this Privacy Policy.
In addition, by downloading the Company’s platforms or accepting cookie settings in your web browser, you further consent to the terms of this Policy, including the use of cookies for relevant purposes. You can manage your cookie preferences through your browser settings or the provided cookie management tools on the Website.
You have the right to withdraw your consent at any time. If you choose to withdraw your consent, the processing of your personal data will cease, but this will not affect the lawfulness of any data processing carried out before your withdrawal. To withdraw consent, please contact our Data Protection Officer (DPO) at dpo@orangex.com.

18. Data Protection Officer (DPO)

If you have any questions regarding this Policy, wish to make a complaint or exercise any of your rights in relation to your personal data you may contact our DPO as follows:
Via email at: dpo@orangex.com

19. Amendments to this Policy

The Company will review this Policy at least once a year or whenever there are significant changes in legal requirements, internal procedures, or as deemed necessary for any other reason. You will be notified of any updates by the posting of an updated Policy on the Company’s Website. In the event of substantial changes, we will notify you promptly through additional means of communication.
By continuing to use the Website after an updated Policy is posted, you acknowledge and accept that such posting serves as official notice from the Company. We encourage you to periodically check this Policy to stay informed about the data we collect, how it is used, and to whom it may be disclosed, in accordance with the latest version of this Policy.
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