PRIVACY POLICY

Effective date: 1 November 2023

At Oriole Insights (“Oriole”, “we”, “us”, “our”), we understand the importance of safeguarding your privacy and ensuring the security of your personal data. This Privacy Policy is designed to inform you about how we collect, use, disclose, and protect your information when you interact with our website, products, and services (collectively referred to as “Services”).

Our commitment to your privacy is rooted in our dedication to transparency and compliance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) with all amendments. This Privacy Policy outlines our practices and principles to help you make informed decisions about sharing your data with us.

We encourage you to CAREFULLY READ AND UNDERSTAND THIS PRIVACY POLICY TO GAIN INSIGHT INTO HOW WE HANDLE YOUR PERSONAL INFORMATION. By accessing or continuing to use our Services, you agree with this Privacy Policy and Terms and Conditions of Use.

You hereby authorize us to collect and/or receive such information to provide the Services.

If you have any questions or concerns about your privacy or this policy, please do not hesitate to contact us. Your trust is important to us, and we are committed to protecting your privacy every step of the way.

  1. DATA CONTROLLER

Oriole Insights is the data controller and is responsible for your personal data. Our contact details are:

Address: Ukraine, Kyiv, Skovorody 3, 02141 Email: info@orioleinsights.io

  1. PERSONAL DATA

Personal data means any information that identifies or can be used to identify an individual or is related to an identifiable person. This information can be either directly linked to a person or used in combination with other data to identify them. This information can be collected directly or indirectly and typically includes personal identifiers such as name, email address, postal address, phone number and identification numbers, demographic information, financial information, location information, online identifiers and other.

  1. WHAT PERSONAL DATA DO WE COLLECT

We collect your personal data through various methods and sources as part of our operations and Services. Typically, you provide us with your personal information by taking actions on our website (https://orioleinsights.io/) (referred to as “Platform”), or by otherwise contacting us. Some information we collect in automatic mode when you visit our Platform, such as your IP address, standard web log information, such as your browser type and pages you accessed on our Platform and certain geolocation information that we collect through Cookies and other tracking technologies.

We collect your personal information only on the basis of your consent, for contract performance, legitimate interests and compliance with legal obligations.

If you create an account on the Platform and start using our Services, we may collect the following information:

1) Personal identifiers: This includes information such as your name, email address, Twitter account, Discord account, Google account, other social media accounts.

2) Financial information: MetaMask wallet public address.

3) Location information: Data indicating your current or past geographic location, by using certain longitude and latitude coordinated obtained through GPS, Wi-Fi, cell-site triangulation, or other locational data. We may collect this data for fraud prevention and risk management purposes, among other reasons.

4) Online identifiers: Information related to your online presence, including IP addresses, usernames, browser type and version, access times, and pages you viewed directly before and after accessing the Platform.

5) Device information: Your device’s screen resolution, operating system and its version.

  1. USE OF PERSONAL DATA

We use your personal information to provide, improve, and administer our Services, to deliver our Services to you, to communicate with you, for security and fraud prevention, and to comply with applicable law. We may also use your personal information for other purposes with your consent. Specifically, we use your information to:

  • to provide, maintain and improve Services on our Platform, to provide customer support to you and address your inquiries, complaints, or technical issues effectively;

  • to keep the security of the Platform and personal data, to save or protect an individual’s vital interest and prevent harm;

  • to detect and prevent fraud and abuse of our Platform and systems;

  • to create and manage your account, including a personal profile about you to make future visits to our Platform and your use of Services more personalized;

  • to enable user-to-user communications;

  • to contact you by email, or other equivalent forms of electronic communication, in relation to the Services, including the security updates, when necessary or reasonable for their implementation;

  • to understand and analyse how you use our Platform and Services and what products and services are most relevant to you;

  • to comply with our legal obligations, including court orders and other legal or regulatory requirements.

  1. DISCLOSURE OF PERSONAL INFORMATION

Without limiting the foregoing Oriole may share your personal information with the third parties such as service providers which monitor and analyse the use of the Platform, information technologies, data storage, auditing, document management and litigation. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions. Before disclosing personal information, Oriole will seek the guarantees that these third parties undertake the proper technical and organisational measures to satisfy the security, confidentiality and integrity requirements to protect your personal data.

We may also make available the personal information that you provide to us to our agents, representatives and contractors for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law.

Oriole also reserves the right to disclose personal information that believes, in good faith, is appropriate or necessary to enforce the Terms and Conditions of Use, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers, investors or others, to respond to a court order or official requests, to protect, security or integrity of Oriole.

We may also share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another entity related to such an event.

YOUR AGREEMENT WITH THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS OF USE CONSTITUTES YOUR CONSENT TO THE COLLECTION AND USE OF PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO USE AND DISCLOSE PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT AS PERMITTED BY APPLICABLE LAW.

Transferring Information

Because Oriole’s Services are offered worldwide, your personal data might be transferred to and held on computers situated in regions outside of your state, province, country, or other governmental jurisdiction. These regions may have data protection laws that differ from those in your jurisdiction. By utilizing the Services, you agree to the transfer of your information to a location outside of your place of residence, which might have distinct data protection regulations. In certain situations, courts, law enforcement agencies, regulatory bodies, or security authorities in these foreign regions may have the right to access your personal data.

When providing information about you to entities outside your place of residence, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law.

You can ask us for more information about the steps we take to protect your personal information when transferring it to other jurisdiction.

  1. DATA STORAGE CONDITIONS AND PERIOD

Oriole strives to ensure security on our systems and use administrative, technical, and other physical security measures to help protect your personal information. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

  1. COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies are small text files that are used by our Platform to store information on your device, such as a computer, smartphone, or tablet. These files contain data that the Platform can access and use when you revisit the Platform or navigate between pages.

Cookies facilitate the work on the Platform. We use Identification and Authentication cookies to recognize and authenticate you when you return to the Platform.

Session cookies help maintain state information during your interaction with the Platform. Session cookies are temporary and are often used to manage your sessions on the Platform. They expire or are deleted when you close the web browser.

Personalization cookies are used to store your preferences and settings, such as language preferences or customized display options. This allows the Platform to provide you a more tailored and user-friendly experience.

Tracking and Analytics cookies helps us to understand how you interact with the Platform by providing information about the areas visited, the time spent on the Platform and any issues encountered, such as error messages. They help us improve the performance of our Platform, alert us of any concerns and more.

Security cookies are playing a role in enhancing Platform’s security. They are used to verify the authenticity of your requests and prevent certain types of attacks, such as Cross-Site Request Forgery (CSRF) attacks.

Performance Optimization cookies are used to improve Platform’s performance by caching data or settings locally on your device, reducing the need for repeated requests to the server.

We also use Advertising cookies that are used to track your behaviour across different websites. This data can be used to display targeted advertisements to you based on your interests and browsing history. They also help us measure the effectiveness of advertising campaigns on the Platform. We may use these cookies to remember websites you have visited and we may share this information with other parties, including advertisers and our agencies.

We might employ third-party analytics tools, like Google Analytics, Smartlook, Hotjar and Microsoft Clarity, to assess your usage of the Services. This includes generating reports on activities and events, gathering demographic information, evaluating performance metrics, and analyzing various data related to the Services, as well as mobile and Internet usage. These third-party providers utilize cookies, pixel tags, and similar tracking technologies to assist in the analysis and provision of data to us.

Cookies do not harm your processor and do not contain viruses. You can deactivate the use of cookies at any time in the configuration of your browser or directly on our Platform. You can customize your browser settings in order to either prevent cookies or receive notifications when cookies are being sent to your device. There are various methods available for managing cookies, and we recommend consulting your browser’s instructions or help screen for detailed guidance on how to modify these settings.

However, if you deactivate certain cookies this may stop some web services from working properly, partially or completely affecting the browsing on the Platform. Please be aware that disabling the cookies we employ may have an impact on your experience while using the Platform. For instance, you may encounter limitations in accessing specific areas of the Platform.

If you use multiple devices, such as your computer, smartphone, or tablet, to access the Platform, it’s important to ensure that the cookie preferences for each browser on every device are appropriately configured to align with your preferences.

  1. MINORS

The Services are not intended for users who are under the age of 18. We do not intentionally collect personal information from anyone under the age of 18. If we become aware that we have collected personal information from a person under the age of 18, we will delete it immediately, unless we are required to retain it by law.

  1. YOUR RIGHTS ON YOUR PERSONAL DATA

Your ability to assert specific rights regarding your personal information, as detailed below, may vary depending on the applicable laws in your place of residence. If any of the rights mentioned below are not mandated by the laws applicable to you, we retain the absolute discretion to decide whether to provide you with those rights.

Under this Privacy Policy you have the following rights in relation to your personal data:

  • Right to access to your personal information. You have the right to access to your personal information and also you are entitled to receive information about how your personal data is being processed. This information includes details such as the purposes for processing, the types of personal data involved, the individuals or categories of individuals to whom the data has been or will be disclosed. If applicable, it will also cover the expected duration for which your personal data will be retained, or if determining an exact duration is not possible, the criteria used for this determination. You also have the right to file a complaint with a regulatory authority. Additionally, when your personal data is transferred to a country outside of the European Union or to an international organization, you have the right to know about the appropriate measures taken to ensure the security of this transfer.

  • Right to rectify your personal information. You have the right to obtain the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  • Right to erase your personal information. You have the right to obtain the erasure of personal data concerning you where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) if you withdraw consent on which the processing is based or you object to the processing of your personal information on the grounds mentioned below; (c) the personal data have been unlawfully processed; (d) the personal data have to be erased for compliance with a legal obligation that Oriole is subject to; (e) the personal data have been collected in relation to the offer of information society services.

  • Right to restriction of processing of your personal information. You have the right to obtain restriction of processing where one of the following applies: (a) you contest the accuracy of the personal data for a period enabling us to verify the accuracy of the personal data; (b) the processing is unlawful but you oppose the erasure of the personal data and request the restriction of its use instead; (c) Oriole no longer needs the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims.

  • Right to personal data portability. You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where technically feasible and where: (a) the processing is based on consent or on a contract; (b) the processing is carried out by automated means.

  • Right to object. You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on: (a) its necessity for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; (b) is necessity for the purposes of the legitimate interests pursued by us or by a third party, including profiling based on those provisions. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of yours or for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where personal data are processed for scientific or historical research purposes or statistical purposes, you, on grounds relating to your particular situation, shall have the right to object to processing of personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

  • Right to withdraw consent. If we are relying on your consent to process your personal information, you have the right to withdraw that consent at any time. If you choose to do so, we will cease processing the specific data, unless there exist other valid reasons to continue the processing.

If you have questions or comments about your privacy rights, you may email us at info@orioleinsights.io

  1. THIRD-PARTIES LINKS

On our Platform you will find links to other websites. These websites have their own privacy practices, and we are not responsible or liable for them. Before providing any personal information, we encourage you to review the privacy policies of those websites.

  1. CHANGES AND UPDATES

We reserve the right to bring changes to this Policy at any time. If so, we will update the date in the top of the Policies and it will be effective from the date of posting. We will publish these modifications on our Platform and in any other locations we consider suitable to ensure your awareness. You recognize and accept that it is your duty to periodically examine this Privacy Policy and stay informed about any updates. Your ongoing use of the Platform after the changes we have made to this Privacy Policy will be considered your consent to those updates. If you do not consent to this Privacy Policy, we kindly ask that you refrain from using our Platform.

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