1. About this Policy
   1. We appreciate your interest in our products and services. Your privacy is important to us and we want you to feel comfortable with how we use and share your personal information.
   2. This policy sets out how Orderbook Global Inc. (hereinafter referred as the "Orderbook", “we”, “our” or “us”) handles your personal information, including when and why it is collected, used and disclosed and how it is kept secure (each and all referred to as "processing"). Orderbook is a data controller for cryptocurrency transactions. As a data controller, we determine the means and purposes of processing data in relation to e-wallet and cryptocurrency transactions.
   3. You will find our contact details at the end of this policy which you can use if you have any questions, including how to update or access your personal information or to make a complaint.
   4. This Policy only applies to information we process. It does not apply to the practices of companies that we don't own or control, or employees that we don't manage. Information on our services may contain links to third party websites, and any information you provide to those sites will be covered by any privacy policies they may have. Please be sure to read the privacy policies of any third-party sites you visit. It is those sites' responsibility to protect any information you give them, so we can't be held liable for their wrongful use of your personally identifying information.
   5. This policy may change, so please check this page from time to time to ensure that you’re happy with any changes.
   6. This policy was last updated on 26 Jan 2024.
2. Your Personal Data and How We Use It
   1. If you choose to create an account (“account”) with us, we require that you provide us certain Personal Information: your name (Last and First), country of residence, company name, date of birth, hash of the password. We will use your Personal Information to:
      • Administer your Account;
      • Process your payments and transactions;
      • Provide you with the Site, the Services, and customer support;
      • Tailor the features, performance and support of the Site and/or Services to you;
      • Market products and services to you that we believe may be of interest to you;
      • Respond to your requests, resolve disputes and/or troubleshoot problems;
      • Improve the quality of the Site and the Services; and
      • Communicate with you about the Site and the Services.
   2. We receive and store certain types of information automatically, such as whenever you interact with the Site or use the Services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software (such as Chrome, Safari, or Internet Explorer) and your Internet Protocol (IP) address/device identifier. We may also collect information about how your device has interacted with our website, including pages accessed and links clicked. We may use identifiers to recognize you when you arrive at the Site via an external link, such as a link appearing on a third party site.
3. Providing Your Personal Data to Others
   1. We may disclose your information to our third party service providers and other organizations for the purposes of providing services to us or directly to you on our behalf. We will never sell or rent your personal information. When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
   2. We may also transfer your personal information if we are under a duty to disclose or share it in order to comply with any legal obligation to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
4. Information We Receive from Others
   1. We obtain information about you from public databases and ID verification partners, Thomson Reuters, and Onfido, for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws.
5. How we Protect and Store Personal Information
   1. We store your information on our servers as well as on servers provided by Amazon Web Services ("AWS"). All services are maintained in the United States of America and all servers, which store your Identifiable Information, are secured and located in the United States of America. We use computer safeguards, such as firewalls and data encryption. We authorize access to your information only for those employees who require it to fulfill their job responsibilities and these employees are required to treat this information as confidential.
6. Transfers of Your Information outside the European Economic Area
   1. The information you provide to us is transmitted to, and stored at, servers in the United States. The information transfer is in compliance with the EU-U.S. Privacy Shield which is available at https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation.
7. Retaining and Deleting Personal Data
   1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
   2. Users may request the deletion of their account by contacting us at the address provided below.
   3. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the period we need to access the data for the provision of services, receiving payment, resolving your customer support issue or other issues or for any other auditing or legal reasons.
   4. Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Your Rights
   1. In this section we have summarized the principal rights that you have under the data protection law. Some of the rights are complex, might contain restrictions depending on the legal basis for processing the data and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
   2. Right to access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can ask for your personal data by contacting our customer support.
   3. Right to rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
   4. Right to erasure: You have the right to the erasure of your personal data. We have described our policy for retaining and deleting personal data above in Section 7.
   5. Right to object to processing: You have the right to object to our processing of your personal data on grounds relating to your particular situation
   6. Right to withdraw consent: to the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
   7. Without prejudice to the aforementioned, if we have reasonable doubts concerning the identity of a user exercising his/her rights referred to in Sections 8.2 to 8.8 or if we otherwise due to security reasons deem it necessary, we may request the provision of additional information and otherwise use all reasonable measures necessary to confirm the identity of the user.
   8. You may exercise any of your rights in relation to your personal data by contacting our customer support. Concerning "Right to erasure" users are also able to request the deletion of their account through our site.
9. Cookie Policy
   1. As is common practice with almost all professional websites, our website uses cookies, which are tiny files that are saved to your web browser, to improve your experience and to enable certain features, such as authentication. This section describes what information they gather, how we use it and why we sometimes need to store these cookies.
   2. We run an affiliate program and as a part of it affiliates advertise our site and services. With the affiliate program we use tracking cookies to track users who visit our site through one of our affiliate partner sites in order to credit them appropriately, and where applicable, allow our affiliate partners to provide you any bonus for making a purchase.
   3. You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Disabling cookies will result in disabling all functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
10. Automated Decision-Making and Information Collected Automatically
    1. Automated decision making means the ability to make decisions using technology, without human involvement. We may use automated decision making in processing your IP address and unique user, or session, ID for load balancing to determine which backend server will process the request.
    2. We automatically receive and record information on our server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.
    3. You have the right to object to our use of automatically collected information described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described above.
11. Children’s Privacy
    1. Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 16.
    2. It is possible that we could receive information pertaining to persons under the age of 16 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers.
12. How to Contact Us
    1. The data controller responsible for your personal data is Orderbook Global Inc, a British Virgin Islands company. If you have any questions about this Privacy Policy, your rights and/or our data collection practices, please email us at privacy@orderbook.io.