Privacy Policy of Orpheus Trade

Privacy Policy

Privacy Policy for Orpheus Trade

This Privacy Policy describes how Orpheus Trade (“Orpheus Trade”), a company incorporated under the laws of the United State of America Company House, processes your personal data whenever you use orpheustrade.com, a Orpheus Trade mobile app, any Orpheus Trade API or third party applications relying on such an API, or any other Orpheus Trade services (collectively, the “Services”). We may periodically post changes to this Privacy Policy on this page, and it is your responsibility to review this Privacy Policy from time to time to ensure you have reviewed the most recent version thereof. When required by law, we will notify you of any changes to this Privacy Policy.

Last updated: November 24, 2018

A. HOW ORPHEUS TRADE COLLECTS INFORMATION ABOUT YOU

When you use the Services, we collect information sent to us through your computer, mobile phone, or other access device for the purposes as set forth hereunder. In addition to personal data listed in this Privacy Policy, we also collect certain Cookies information which you may find in a separate Cookies Policy on Orpheus Trade website. Orpheus Trade does not target its websites, mobile app, API, or any of the Services at children. Orpheus Trade does not intentionally collect information from children. If we become aware that we have inadvertently received personal data from a user under the age of 21 (or any lower age pursuant to applicable law), we will delete such information from our records. If you create an account or use the Services, we, or our affiliates or Vendors (as defined hereunder) acting on our behalf may collect the following types of information for the purpose as set forth hereunder:

Account Information – your email address and password;
Contact Information – your name, birth of date, address, phone number;
Identity Verification Information – our ID number, image of your government issued ID, passport, national ID card, driving license, your selfie along with the above mentioned ID documents, and FATCA (Foreign Account Tax Compliance Act) related information;
Financial Information – withdrawal address, source of fund, the number of bank account linked with your Orpheus Trade account, and image of bank statement or similar information;
Nationality/Residence Verification Information – your address, nationality, country of residence, and utility bill or similar information; and/or
Survey Information – certain personally identifiable information you provide in response to our survey. This may include details about your education history, income and your employment;
Technical information – IP, login information, browser information, time zone setting , operating system and platform;
Information about your visit – full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We also use (or may use) cookies and web beacons when you visit our Site. For more information on our use of cookies and web beacons, please refer to our Cookie Policy;
Information about geo-location – real-time location based information from your device at any time while you download or use our services We may use this information to optimize your experience;
Information we receive from other sources – We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. As of the time of this version of Privacy Policy, we have engaged certain vendors for the following services that may collect your personal information (the “Vendors” or “Service Providers”)

Internet infrastructure – cloud storage and cloud computing;
Communication tools and platforms – SMS services, email services, and push notification, and customer support tool;
Error collection tools – web page error message collection, APP crash tracking, web and APP experiment (A/B testing), and APP statistics;
User behavior analysis – user behavior tracking tool and bot prevention tool; and
Anti-money laundering tool – such as AML database.

If you seek permissions to raise digital currency buy and sell limits associated with your Orpheus Trade account, we may require you to provide additional information to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal data. We may also obtain information about you from third parties such as credit bureaus and identity verification services. When you use the Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect name and type of your computer, mobile device, or other access device, such as the name and device of your operating system, for fraud prevention purposes, to monitor for possible breach of your Orpheus Trade account, and to identify any malicious software or other activity that may harm Orpheus Trade or its users. You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook, Google, Twitter and any other Third Party). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. If you associate an account managed by a third party with your Orpheus Trade account and authorizing Orpheus Trade to have access to this information, we may request your consent that may collect, store, and use this information in accordance with this Privacy Policy. Finally, we collect additional information that you provide voluntarily to our customer success team.

B. HOW Orpheus Trade PROTECTS AND STORES PERSONAL DATA

Throughout this Privacy Policy, we use the term “personal data” to describe information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This Privacy Policy does not apply to personal data that has been anonymized so that it does not and cannot be used to identify a specific individual or be identified. We store and process your personal and transactional data, including certain payment information, where Orpheus Trade facilities or our service providers are located, including in EU and in the United States. We store your personal data securely throughout the life of the your Orpheus Trade account, unless otherwise for a shorter period required by this Privacy Policy. Orpheus Trade will retain your personal data for a maximum of ten years or as necessary to comply with our legal obligations or to resolve disputes.

C. HOW Orpheus Trade USES THE PERSONAL DATA WE COLLECT

Our primary purpose in collecting personal data is to provide you with a secure, smooth, efficient, and customized experience. We use your personal data to:

Provide the Services and requested customer support;
Process transactions and send notices about your transactions;
Resolve disputes, collect fees, and troubleshoot problems;
Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
Customize, measure, and improve Orpheus Trade Services and the content and layout of our website and applications;
Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and/or
Verify your identity by comparing your personal data against third-party databases.

We will not use your personal data for purposes other than those purposes we have disclosed to you, without your consent. From time to time we may request your consent to allow us to share your personal data with third parties for the purpose of provide the Services. You may refuse to provide or may withdraw your consent at any time without adverse consequence. Your refusal and withdrawal of consent will have no effect on the services we provide hereunder, provided that such consent is not necessary for our performance of the Services hereunder. We do not engage in individual automated decision-making. We will never sell or rent your personal data to any third parties. Any communications we send to you will either be related to your account or will be related to Orpheus Trade services or products. In the event Orpheus Trade sends any communication to you which is not related specifically to your account, Orpheus Trade will provide you with an “unsubscribe” mechanism through which you may opt out of receiving other similar messages in the future.

D. HOW Orpheus Trade SHARES PERSONAL INFORMATION WITH OTHER PARTIES

We may share your personal data with the following parties for the following reasons. Various service providers. The Venders or service providers, as set forth in this Privacy Policy, are those under contract to help with parts of our business operations, such as know-your-customer procedure, bill collection, marketing, and technology services. Our contracts require these service providers to only use your personal data in connection with the services they perform for us and prohibit them from selling your information to anyone else. Authorized Third Party Applications. If you authorize one or more third-party applications to access your Orpheus Trade account, then information you have provided to Orpheus Trade may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions made during you use of the Services. Prospective M&A Partners. Our business plans may entail discussions with companies or other entities that we plan to merge with or be acquired by, or companies intending to acquire certain portions of our business. Should such a merger or acquisition occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal data. You will receive prior notice of any change in the applicable policy. Law enforcement, government officials, or other third parties.

We may be required to disclose personal data if and when compelled to do so by a subpoena, court order, or similar legal procedure. Miscellaneous. We may also make disclosures of personal data if we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our terms and conditions of use. Before Orpheus Trade shares your personal data with any third party, Orpheus Trade will, to the extent permitted by applicable laws, rules, or regulations, enter into a written agreement or seek other safeguards requiring that the third party provide at least the same level of privacy and data protection as set out hereunder.

We may be required to disclose personal data if and when compelled to do so by a subpoena, court order, or similar legal procedure. Miscellaneous. We may also make disclosures of personal data if we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our terms and conditions of use. Before Orpheus Trade shares your personal data with any third party, Orpheus Trade will have to the extent permitted by applicable laws, rules, or regulations, enter into a written agreement or seek other safeguards requiring that the third party provide at least the same level of privacy and data protection as set out hereunder.

E. HOW YOU CAN CONTACT US ABOUT PRIVACY QUESTIONS AND EXERCISE YOUR DATA SUBJECT RIGHTS

If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us on our support page by email support@orpheustrade.com. If you are located in, or a resident of, EEA, you have the following rights under EU data protection law :

Right of access: you can request information about your Personal Data and request a copy of that data.
Right of rectification: you can request that we correct or update your Personal Data if they are incomplete or incorrect by Orpheus Trade at any time by submitting a request to: support@orpheustrade.com with the subject line “Revise Personal Information”.
Right to restriction: you can request that we restrict the processing of your Personal Data.
Right to erasure: you can request erasure of your Personal Data, if the data are inaccurate or processed in a way which is incompatible with the purpose(s) pursued by us.
Right to data portability: if we process your Personal Data on the basis of a contract with you or based on your consent, you can request to receive your Personal Data in a structured, commonly used and machine-readable format, and ask us to transfer such data to a third party, where technically feasible. Furthermore, if you wish to have a copy of your ledger in Orpheus Trade, you may download them by submitting a request to support@orpheustrade.com with the subject line “Download Ledger”.
Right to objection: you can object to the processing of your Personal Data for direct marketing purpose at any time.
Right to lodge a complaint: you can lodge a complaint with a competent supervisory authority in the EU situated at your habitual residence, place of work, or place of alleged infringement of the GDPR.
Right to refuse or withdraw your consent: you can refuse to give and withdraw your consent to data processing at any time. You can also oppose processing of your Personal Data, based on our legitimate interests, including profiling based on this provision, on compelling grounds relating to your particular situation at any time.
Right not to be subject to automated individual decision making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.