ORNGX Privacy Notice

Last updated: December 4, 2024

1. Introduction

ORNGX is committed to protecting the privacy of our customers, and we take our data protection responsibilities with the utmost seriousness.

This privacy notice applies to the processing activities performed by ORNGX to the personal data of its clients, prospective clients, and website visitors.

ORNGX refers to the comprehensive cryptocurrency exchange platform with the legal entity ORNGX LIMITED (hereafter also referred to as “ORNGX”, "the Company", "We", "Us", or "Our").

OrangeX Pro is a product under ORNGX LIMITED, designed to provide secure and efficient cryptocurrency trading services while prioritizing user privacy.

The Company is incorporated under the laws of the Hong Kong Special Administrative Region. The Company owns and operates the domain https://www.orngx.com (hereafter the " Website).

ORNGX collects and processes personal data, including KYC (Know Your Customer) and transaction information, in compliance with applicable regulations.

This Notice should therefore be read together with our Cookie Notice, which provides further details on our use of cookies on the website.

2. Scope and Applicability

As the data controller, ORNGX is responsible for the personal data it collects, processes, and stores. All processing of personal data is carried out in accordance with this Privacy Policy (hereafter “the Policy”) and the requirements of the GDPR, Hong Kong Personal Data Protection Act, and other applicable data protection laws.

This Privacy Policy describes how we collect and use personal information when you explore, sign up for or access our services. ORNGX collects and processes personal data based on one or more of the following legal bases as outlined in GDPR Article 6:

Consent (e.g., when users provide explicit consent for marketing communications or the use of certain services);

Contractual necessity (e.g., to fulfill contractual obligations with users);

Compliance with legal obligations (e.g., anti-money laundering and tax compliance);

Legitimate interests pursued by the Company (e.g., fraud prevention, enhancing services, and ensuring platform security);

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. Protecting Your Information with Top Data Security Standards

Your privacy is of utmost importance to us, and it is our policy to safeguard and respect the confidentiality of information and the privacy of individuals.

We use various technical and organizational measures (TOMs) to protect your personal data, including:

Encrypting your data during transfer and storage.
Limiting access to only authorized staff with strict controls.
Training employees on data privacy and security to prevent breaches.

We are also committed to:

Regularly updating our data protection practices.
Meeting GDPR security standards (Article 32).
Clearly explain how we use your data and your rights under GDPR.
Addressing any concerns you have about your data, security, or privacy.

4.What personal information do we collect?

Personal Information

Personal information means any information that relates to an identified or identifiable living individual. We collect the following personal information and documentation:

Information Category	Description
Basic Customer Identity Data	Name, Date of birth, Nationality, Biographical information, including facial recognition images, Government-issued identity document, e.g. national identity card, passport, driving licence
Contact Information	Country of residence, Phone number, Email Address, Proof of Address (if applicable)
Financial Information	Bank Account Number, Payment Card Details, Digital Assets, Wallet Addresses
Trading Information	Information about the transactions made on our Services, such as the name of the sender, the name of the recipient, the amount, currency preferences, payment method, date, and/or timestamp
Technical Information	Your browser and login information, including 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
Diagnostic and Troubleshooting Information	About how our Services are performing when you use them, i.e. service-related diagnostic and performance information, including timestamps, crash data, website performance logs, and error messages or reports
Account Profile Information	This refers to your basic account information when you use our products and services, such as username, password, account identification number, information on whether you have ORNGX App, settings and preferences you select in our products, information collected when you interact with our support service channels, including online chat, phone call, email, direct message or other communication means.
Product Usage Information	Your activity 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 timestamp, event time, name and source.
Marketing and Communications Data	Communications information such as survey responses, your preferences in receiving marketing from us or third parties information.

5. How do we collect your personal information?

We gather your information in a few simple ways:

Direct Interactions

You share personal details like Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data and Marketing and Communications Data when you:

Visit our website or app.
Sign up for our services or create an account.
Use our services.
Subscribe to newsletters or marketing.
Enter contests, promotions, or surveys (including via social media).
Contact us or give feedback.

Legal Basis about why we collect this: We need this data to provide services, fulfill agreements (contractual necessity), send marketing (consent), or improve our offerings and prevent fraud(legitimate interests).

Automated Collection

When you use our website or app, we automatically collect technical details like your device type, browsing behavior, and usage patterns using cookies, server logs, or similar tools. This includes transaction and usage data. Learn more about cookies in our Cookie Preferences section.

Legal Basis about why we collect this: We use this data (with your consent for cookies/marketing) to analyze usage and improve our services (legitimate interests).

You can manage or withdraw cookie consent anytime via the Cookie Preferences link on our website.

Social Media Widgets and Links

Our site includes social media features like “share” or “like” buttons for platforms like Facebook, X (Twitter), Instagram, LinkedIn, and others.Please note that when you interact with these social media plug-ins, your data may be collected by these third-party platforms. Check their privacy policies to understand how they handle your information.

6. How do we process your personal information?

Purpose and/or activity	Categories of Personal Information	Legal basis for processing
To create and main your ORNGX account	・Customer Identity Information ・Contact Information ・Financial Information	Performance of a contract
To comply with applicable laws and anti-money laundering requirements	・Customer Identity Information ・Contact Information ・Financial Information ・Trading Information ・Technical Information ・Account Profile Information	Compliance with a legal obligation
To provide and manage our Services, including products from third-party providers we work with, and to carry out any instructions or orders you place through our app or services.	・Customer Identity Information ・Contact Information ・Financial Information ・Trading Information ・Technical Information	Performance of a contract Consent, if required
To prevent abuse of our Services and promotions	・Customer Identity Information ・Contact Information ・Financial Information ・Trading Information ・Technical Information ・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 by asking for reviews or survey participation and keeping you updated on our company's business and product developments.	・Customer Identity Information ・Contact Information ・Account Profile Information ・Trading Information ・Marketing and Communications Data	Performance of a contract Consent, if required
To update our records and analyze how customers use our products and services to improve them.	・Customer Identity Information ・Contact Information ・Account Profile Information ・Trading Information ・Technical Information ・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	・Customer Identity Information ・Contact Information ・Financial Information ・Trading Information	Performance of a contract
To comply with laws and handle complaints by: ・Managing risks and preventing crimes like money laundering, terrorism, fraud, and other issues through background checks. ・Detecting, investigating, reporting, and preventing financial crimes. ・Keeping your account secure and responding to your requests for information or account changes.	・Customer Identity Information ・Contact Information ・Financial Information ・Trading Information ・Technical Information ・Account Profile Information ・Product Usage Information ・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.
Your participate in prize draws, competitions, or surveys on our platform.	・Customer Identity Information ・Contact Information ・Account Profile Information ・Product Usage Information ・Marketing and Communications Data	Performance of a contract Consent, if required
Collect data to understand customer preferences, interests, and how they use our products/services, to plan marketing campaigns and grow our business.	・Customer Identity Information ・Contact Information ・Account Profile Information ・Product Usage Information ・Marketing and Communications Data	Legitimate interests: understanding our customers and improving our products and services
To manage and protect our business, Website, App(s), and social media channels. This includes handling bans, troubleshooting, analyzing data, testing, maintaining systems, providing support, reporting, and hosting data.	・Customer Identity Information ・Contact Information ・Financial Information ・Technical Information ・Trading Information ・Product Usage Information	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 show you relevant website content and advertisements, and to check how effective our advertising is.	・Customer Identity Information ・Contact Information ・Account Profile Information ・Product Usage Information ・Technical Information ・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 enhance our website, products, services, marketing, and customer relationships, making your experience better.	・Technical Information ・Product Usage Information ・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 suggest and recommend products or services you might like.	・Customer Identity Information ・Contact Information ・Technical Information ・Product Usage Information ・Account Profile Information ・Marketing and Communications Data	Legitimate interests: to develop our products/services and grow our business Consent, if required
To use social media and advertising platforms to provide services, and these platforms may use your personal data for their own purposes, including marketing.	・Technical Information ・Product Usage Information	Consent
To partner with financial institutions, third-party service providers, and fraud or risk management companies, sharing your personal data with them. These partners may use your data for their own purposes as independent data controllers.	・Customer Identity Information ・Contact Information ・Financial Information ・Trading Information ・Technical Information ・Product Usage Information	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 it?

Automated decisions are made by software algorithms without human involvement. For example, we use automated decisions to onboard new customers or monitor for fraud.

Why does it matter?

These decisions, which may include profiling, can use your personal data and may have legal or significant effects on you.

How do we protect you?

We take steps to safeguard your rights during automated decision-making. You can challenge these decisions. For more details or to exercise this right, please contact us.

Marketing

We use your personal details, like Identity Data, Contact Data, Technical Data, Trading Data, Usage Data and Profile Data to understand what products, services, or offers might interest you.

You’ll receive marketing messages from us if you’ve asked for information and agreed to receive them, or if you’ve bought from us and haven’t opted out. We use your Marketing and Communications Data for these activities.

Third-Party Marketing

We’ll only share your personal data with third parties for marketing before your opt-in consent.

Opting Out

You can stop receiving marketing messages at any time by clicking the unsubscribe link in any marketing email we send you or by logging into your account and turning off marketing notifications.

Note that opting out of marketing messages won’t stop service-related messages, like updates about maintenance or changes to our terms.

How We Use Cookies and Tracking Tools

We and our third-party partners use cookies and other tracking tools to monitor how you use our platform. We may combine this data with other personal information we collect from you.

What Are Cookies?

Cookies are small data files we place on your computer through your browser to keep track of your activity. They help make navigating our platform easier, speed up logins, or track how you use our services. There are two types:

Session cookies: These last only while you’re online and disappear when you close your browser or turn off your computer. They help us identify you during a session to process transactions and verify your identity.

Persistent cookies: These stay on your computer after you log off. We use them to collect general data about user activity.Note: Our systems don’t currently respond to “do-not-track” signals from browsers.

Turning Off Cookies

Most browsers accept cookies automatically, but you can change your browser settings to block them, get notified about new cookies, or disable them completely. Be aware that disabling cookies may prevent you from accessing certain parts of our platform.

Third-Party Analytics

We use tools like Google Analytics to track how people use our platform. These tools help us improve our services, performance, and user experience by analyzing usage data. They may use cookies or other tracking methods, but we don’t share your Personal Information with these third parties.

Change of Purpose

We’ll only use your personal data for the reasons we collected it, unless we believe it’s needed for a related purpose that aligns with the original one. If you want to know how a new purpose connects to the original, just contact us.

If we need to use your data for a completely different purpose, we will notify you and explain the legal basis which allows us to do so.

Sale or Transfer of Business

We may process your data during business deals like mergers, financing, acquisitions, bankruptcy, dissolution, transaction or proceeding involving all or a part of our shares, business or assets to support our legitimate interests in these transactions or to meet legal requirements.

7. Contacting You

With your consent, the Company or its affiliates and partners may reach out via phone, email, or other methods to share details about our products, services, promotions, or to conduct market research.

Opting out of these marketing messages won’t affect your access to our services.

If you want to stop receiving them, you can contact the Company’s back-office department via email dpo@orngx.com with a written request to opt out.

8. Disclosure and Transfer of Your Personal Data

We may share your personal data with third-party service providers, agents, subcontractors, group companies, or affiliates (as described below) to perform tasks, deliver services, or support our app on our behalf. These third-party service providers are required to respect the security of your data and follow data protection laws, like GDPR.

Who we may share your data with:

Companies and organizations helping us process and verify transactions, refunds, or services you request.
Third-party service providers whose products or services are hosted/integrated on our Website and App.
Identity verification agencies verifying your identity for anti-money laundering (AML) or know-your-customer (KYC) checks.
Fraud and crime prevention agencies to combat fraud, money laundering, or terrorist financing.
Any entity we legally transfer our rights or obligations to under the relevant terms and conditions governing the use of our Services
Any 3rd Party involved in a business restructure, sale, or acquisition, as long as they use your data for the same purposes we collected it for.
Regulatory or law enforcement authorities, when required or allowed by law, inside or outside the Hong Kong Special Administrative Region.

Using Blockchain Technology

Some ORNGX services 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. Please note that once data is added to the blockchain, it becomes virtually impossible to remove or delete.

Transferring Data Across Countries

We may store your Personal Information on servers in countries where our main offices are located. If these are outside your resident country, you consent to the transfer, which is needed to provide our services, even if the destination jurisdiction may have less stringent data protection laws than your jurisdiction of residence.

We take all reasonable steps to protect your data during transfers and ensure it complies with your local laws.

9. Safeguard Measures

Sharing data online has some risks, but we take steps to protect your personal information from loss, misuse, damage, unauthorized access, or illegal disclosure. We only allow employees, agents, contractors, or third parties with a legitimate business need to access your data, All these parties will only process your personal data based on our instructions and are subject to a duty of confidentiality.

Our Security Measures Include:

Organizational Steps:

Training staff on data protection and secure handling.
Creating internal policies for safe data processing.

Technical Steps:

Physical protection of data (e.g., secure access to server facilities).
Using pseudonymization and encryption to ensure your personnal data confidentiality and integrity.
Measures to ensure ongoing availability, integrity, and accessibility of 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.

Handling Data Breaches:

We have procedures in place to address any suspected personal data breach. We’ll notify you and relevant authorities within 72 hours if the breach risks your rights, as required by GDPR Article 33.

10. Our Identification Tools

To verify your identity, ORNGX LIMITED uses an in-house system to collect and process identification data. This involves taking a photo or video of your face and ID document through a secure web or mobile platform.

We use this data to meet legal requirements, like preventing money laundering and terrorist financing under Hong Kong law, and to manage fraud, crime, and risks.under the Law on Prevention of Money Laundering and Terrorist Financing of the Hong Kong Special Administrative Region.

We keep the face comparison results (match or no match) only as long as needed for verification and to follow anti-money laundering rules. Your facial data is used only for a one-time check and isn’t stored as a facial template or reusable raw data.

This in-house system ensures accurate and efficient identity verification by confirming the person in the ID matches the photo or video.

If you’d like a different verification method, email us at dpo@orngx.com.

11. Automated Decision Making

In certain cases, the Company may use automated systems to make decisions without human involvement, using software to:

your identity.
Detect fraud;
Assess trading risks or other tasks.

These automated processes help us manage our services efficiently, but we prioritize fairness. If you think an automated decision is incorrect or unfair, you can request a manual review, as allowed under GDPR Article 22.

For more details on your data rights, see the section "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 Hong Kong Special Administrative Region 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:

With your consent: As long as your consent is valid, unless laws require otherwise. We may keep records of your consent to protect our rights.
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;
Compliance Requirements: 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 Hong Kong Special Administrative Region. The retention period may be extended for a period not exceeding 2 (two) years, provided there is a reasoned request from a competent authority;
Website or email data storage: 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.

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.

After the retention period, we delete or permanently anonymize your data as soon as possible.

13. International Transfers of Personal Data

We might need to send your personal data to countries outside the EEA for storage or processing by our team, suppliers, or partners to fulfill our contract with you. 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 Czech and European Union (EU) law. ORNGX 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 give clear permission after we explain the risks.
You have provided explicit consent to the proposed transfer after being informed by ORNGX of the potential risks associated with such a transfer;
The transfer is necessary to fulfill a contract between you (the client) and ORNGX, 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 ORNGX 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 uses cookies—small data files stored in your browser—to improve your experience on our website. These cookie files help us understand how you use our services, letting us personalize your experience based on your preferences. Cookies have unique identifiers but don’t access your computer or sensitive information beyond what you choose to share. They aren’t linked to your personal details.

You can control cookies through your browser settings, but turning them off might limit access to parts of our website or affect your account’s functionality. Check our Cookies Policy for more details on how we use cookies and tracking tools.

Our partners or affiliates may also use cookies on our site, but we’re not responsible for any data loss or misuse from their cookies. If you visit linked external websites, our policy doesn’t apply, so please review their privacy policies to understand how they handle your data.

15. Your Rights regarding your Personal Data

The rights that are available to you in relation to the personal data we collect and process are outlined below. You may request to exercise these rights subject to GDPR and Czech regulatory requirements.

Right to Access

You can ask us to confirm what personal data we process, the purposes of processing, and how long we retain your data. Should you wish to obtain a copy of that information, we will provide it free to you unless the request is excessive or unjustified.

Right to Rectification

You can request the rectification of your personal data which are inaccurate, and also add to it. Note 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@orngx.com. We will update your data accordingly. Please note that we may require evidence to support these updates.

Right to Deletion/Erasure

You can ask us to delete, remove, block or anonymise your personal data in certain circumstances. To initiate an account deletion request, please submit your application via https://www.orngx.com/user/delete. We will respond within three (3) business days and process the deletion of your account, including any associated assets and personal data, in accordance with applicable laws. 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). Please note that deleting your personal data will result in the closure of your account.

Right to Confirmation on Use and Processing

You can request information on how and why your personal data is used and processed, including a copy of your data.

Right to Restrict Processing

You can restrict the processing of your personal data in these cases:

You dispute the data’s accuracy (restricted while we verify).
The processing is unlawful, but you prefer restriction over deletion.
We no longer need the data, but you require it for legal claims.
You object to processing based on our legitimate interests, pending our assessment.

Right to Data Portability

In certain circumstances you may have the right to obtain personal data you have provided to us in a structured, commonly used, and machine-readable format, or when this is possible, that we communicate your personal data on your behalf directly to another data controller;

Please note we are no longer responsible for the use of your data by the third party after the transfer,

Right to Withdraw Consent

You may withdraw your consent to data processing at any time by contacting our Data Protection Officer (DPO) at dpo@orngx.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 Lodge a Complaint with the relevant Data Protection Authority

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 Hong Kong 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 liable for the use, misuse, or loss of personal data on external websites linked from our site, as we do not control or access data collected by these third parties. 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 damages or unauthorized account use due to your negligence or actions by individuals you authorized.

17. Consent

By entering an agreement, creating an account, or using the Company’s website, trading platforms, or payment gateways, you consent to the collection, use, and storage of your personal data as described in this Privacy Policy.

Downloading our platforms or accepting cookie settings in your browser also indicates your consent to this Policy, including cookie use.

You can manage cookie preferences via your browser or our website’s cookie management tools.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@orngx.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@orngx.com

With registered post at: Sokola Tůmy 743/16, Mariánské Hory, 709 00 Ostrava

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.