Orvium OÜ - Privacy Policy

This Privacy Policy covers any of your Personal Information obtained by Orvium or its Affiliates.

By using Orvium Website which include https://orvium.io/ and other names under which we do business or submitting information to us through or in connection with our Website or by any other means, you are asked to provide your consent to our collection, use, processing and disclosure of your Personal Information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you must not use this Website, Purchasing Area or submit information to us.

If you want to withdraw your consent, you will find some information about how to unsubscribe at the end of any email sent, or you have any questions regarding this Privacy Policy, please send an email to info@orvium.io.

The Privacy Policy will be binding on all persons who register or access the Website from any jurisdiction the Website is legally available for access or use.

If you are based in the EEA you may only use Website if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of Website has been provided to us.

You have the right to submit a complaint to the Estonian Data Protection Inspectorate if you find that we have processed your Personal Information in a way which infringes the applicable legislation.

Please note that we may update this Privacy Policy from time to time. We will provide you with notice of the modification by e-mail at least 30 days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel the use of the Website and Purchasing Area. Your use of the Website and Purchasing Area following these changes indicates your consent to the practices described in the revised Privacy Policy.

DEFINITIONS

“Orvium” means Orvium OÜ, a company incorporated under the laws of Estonia with registry code 14439892.

“Affiliates” means, in relation to Orvium, its past, present and future employees, members of management bodies, officers, directors, parent companies, subsidiaries, shareholders, agents, representatives, service providers, legal successors and assigns.

“Business Relationship” means the relationship between you and Orvium.

“ORV Token” means an ERC20 blockchain token created by Orvium in connection with the Project.

“Personal Information” means data about an individual who can be identified from that data, or from that data and other information to which we have access. Personal Information is usually your name in combination with another identifier, such as date of birth, address.

“Privacy Policy” means this privacy policy.

“Project” means the Orvium blockchain based ecosystem, described in more detail in the White Paper.

“Purchasing Area” means the online platform where ORV Tokens can be purchased. Purchasing Area can be used only by registered users.

“Terms” means Terms and Conditions published on the Website.

“TGE” means Token Generation Event as described in White Paper and in Terms.

“Website” means https://orvium.io/

“White Paper” means the description of the Project as currently envisaged and as may be amended by Orvium from time to time. White Paper shall be made available on the Website.

YOUR CONSENT

Before using our Website and submitting any Personal Information to us, we require opt-in consent to use and process Personal Information as set out in this Privacy Policy. You can withdraw your consent at any time by following the details provided at the end of every email sent.

Your withdrawal of your consent is not affecting the lawfulness of previous processing of Personal Information which was based on your consent before its withdrawal.

We reserve the right to amend or modify this Privacy Policy and if we do so we will post the changes on the Website. It is your responsibility to check the Privacy Policy every time you submit information to us or place an order. Use will signify that you agree to any such changes.

PERSONAL INFORMATION COLLECTED

We will ask, use, store or otherwise process any Personal Information that relates to and identifies you, including but not limited to your name, date of birth, postal address, e-mail address, telephone number, digital wallet information and any other information reasonably necessary for you to register or participate in the website.

We may also obtain and collect your Personal Information through the means of requesting identification verification by prompting you to provide us with a photo ID to ensure compliance with KYC and AML regulations. We may be required under applicable laws and regulations to verify government issued photo ID and to record certain information, including name, date of birth, address, principal occupation, type of ID, and ID reference number, before conducting certain types of transactions that may be considered suspicious or stand out of ordinary types of transactions performed by user or a token holder.

We may also collect information from third parties, brokers, traders, funds, agencies or other companies and Affiliates, to fulfill any special offers or customer requests, manage credit or other business risks; collect outstanding debt; or detect, prevent, manage, suppress, or investigate financial abuse, fraud or other unauthorized or illegal activity. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your Personal Information to us should be directed to such third parties.

USE OF PERSONAL INFORMATION BY ORVIUM

We use, store, and process information, including Personal Information, about you to provide, understand, improve, and develop the Website and Purchasing Area, create and maintain a trusted and safer environment and comply with our legal obligations.

We use the Personal Information obtained:

to transact business with you in connection with the Orvium Website and related transactions (e.g. requests for information about our ORV Token or services) and otherwise deal with your inquiries and requests;

to assess your interests, preferences and degree of satisfaction with the Orvium platform and/or related services;

to keep you posted on new or updated ORV Token offerings or related services and/or upcoming events and market and promote otherwise Orvium;

to improve the effectiveness of the Website, services, operations, mobile experience or marketing efforts;

to verify your identity and eligibility for the TGE and/or related services;

to enable us to comply with applicable law or regulatory process (e.g. AML and KYC regulations while processing your payments);

to conduct auditing, data analysis, and research to improve Orvium’s services and customer support;

to prevent, deter and investigate violation of this Privacy Policy and our Terms or any fraud and other illegal activities; and

to send you important notices regarding your purchases and changes to our business policies.

We may provide your Personal Information to our Affiliates and business partners or others who process it on Orvium’s behalf in order to ensure the adequate performance of Business Relationship.

We are not using your Personal Information for profiling.

We share your Personal Information with third party services who facilitate the TGE, manage and enhance our systems or customer data, provide customer service, assess your interest in our products and services, and conduct customer research or satisfaction surveys. The companies have agreed to protect your information as a condition of receiving or processing it.

We may release your Personal Information to others (including law enforcement) if we believe such release is reasonably necessary to comply with the law or legal process; enforce or apply the Terms; detect, prevent, or otherwise address fraud, security or technical issues; or otherwise protect the rights, property or safety of others. Where appropriate, we may notify you about legal requests unless: i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Orvium’s property. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify you about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

We may sell, transfer and/or disclose your Personal Information as part of a business divestiture, sale, merger, or acquisition of all or a part of our business. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset.

If you stop using our Website or your permission to use our Website is terminated, we may continue to use and disclose your Personal Information in accordance with this Privacy Policy and as permitted by law. We are retaining your Personal Information necessary to comply with anti-money laundering regulations no less than five years after the termination of Business Relationship.

However, if you wish us to stop e-mailing you with information in connection with our Website or promotion of Orvium please click the "unsubscribe" link at the bottom of any email you receive from us or by changing the communication preferences on your online account or profile.

Once we no longer require your account or Personal Information it will be destroyed or de-identified.

RIGHT TO BE FORGOTTEN

You have the right to have your Personal Information erased and no longer processed by us if the Personal Information is no longer necessary for Business Relationship or you have withdrawn your consent.

PROTECTION OF PERSONAL INFORMATION

We maintain a variety of security measures, including physical, electronic and procedural safeguards. No system can be completely secure, so we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure.

We will process and protect your Personal Information in compliance with the data protection regulations implemented in Estonia.

All of our employees and data processors that have access to, and are associated with, the processing of your Personal Information are obliged to respect the confidentiality of Personal Information.

You can ask us for the Personal Information we possess to have any inaccuracies corrected. Where appropriate, you may have your Personal Information erased, rectified, amended or completed. We will require proof of your identity before providing you with details of any Personal Information we may hold about you. We will usually share this with you within 30 days of you asking us for it.

As provided by law, you have the right to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit such Personal Information to another controller, if it is technically feasible.

We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction or deletion requests can be made using the "Update profile" link at the bottom of any email you receive from us or by changing the communication preferences on your online account or profile.

OTHER INFORMATION COLLECTED

We automatically gather information when you browse or view our Website. This log data may include your browser type (e.g. Chrome, Safari, Firefox or Internet Explorer), your domain, the Internet Protocol (IP) address assigned to your computer (or the unique device ID of your mobile device, or other unique identifier), the date and time of your visits, the pages on our site you visit and other information related to your visit.

We collect data that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose such non-personal information for any purpose.

If we combine non-personal information with your Personal Information, we will maintain the combined information as Personal Information for as long as it remains combined.

We may collect information such as language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where you are located so that we can better understand your behavior and improve our products, services, and advertising.

We may collect aggregated information regarding your activities on our Website, mobile application, and from our other products and services we may offer.

USE OF COOKIES AND SIMILAR TECHNOLOGIES

We use technologies such as “cookies” and web beacons so we can remember certain information about you, remember your preferences or recognize you when you return (e.g. your language preferences or other settings so you do not have to set them up every time you visit the Website or Purchasing Area). They also help us compile aggregate data about Website traffic and Website interaction so that we can improve our Website and protect our Website from fraud.

A cookie is a text file that stored on your computer’s hard disk from a Website. As text files, cookies cannot read information on your hard drive, run programs or deliver viruses to your computer. Cookies let our Website remember your preferences or recognize you when you return, making our Website more useful to you.

Web beacons, also known as clear GIFs, are often used in combination with cookies. These often transparent images are part of web pages, and allow us to count users who have visited certain pages and to generate statistics about how our Website is used. They are not used to access Personal Information.

Pixel tags enable us to send e-mail messages in a format customers can read and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

As do many internet sites, we gather some information automatically, such Internet Protocol (IP) addresses, browser type and language, Internet service provider, referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

You may give consent for our Website to capture and record certain precise geo-location or global positioning data from your device in order to tailor information to your location. We may link such location data to other information that you provide to us or that may be accessed in connection with your use of our Website.

SOCIAL NETWORK SITES

You may be able to post content to social networking sites (such as Facebook, Google, Instagram, Snapchat or Twitter) on which we maintain a presence (hereinafter Social Networking Sites). If you choose to do this, we will provide information to the Social Networking Sites in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products or services of such Social Network Sites.

Where permissible according to applicable law we may use certain limited Personal Information about you, such as your e-mail address, to hash it and to share it with Social Network Sites, to generate leads, drive traffic to our websites or otherwise promote TGE. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your Personal Information are not controlled or supervised by Orvium. Therefore, any questions regarding how your Social Network Site service provider processes your Personal Information should be directed to such provider.

Please note that you may, at any time ask us to cease processing your Personal Information for these direct marketing purposes by following the process described at the end of every email sent.

LINKS TO THIRD PARTY WEBSITES

Our Website may have links or be linked to other sites we do not own, control or maintain. We are not responsible for and make no representations or warranties about the privacy practices of those sites. We recommend that you check the privacy policies of other sites and contact the operator if you have concerns or questions. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback about these third party sites.

OPTING OUT OF COMMUNICATIONS

You may opt-out of receiving marketing-related e-mails by clicking the "unsubscribe" link at the bottom of any e-mail you receive from us or by changing the communication preferences on your online account or profile. If you are having difficulty unsubscribing from our marketing communications using the above method, please contact us at info@orvium.io.

If you opt-out from receiving marketing e-mails or text messages, we may still need to send you communications about your orders, customer service inquiries, promotions participation and other matters.

If you agreed to receive future marketing communications directly from a third party through our Website, you will need to contact that party to opt-out of such communications. This process may be outlined on that party’s privacy policy.