PRIVACY POLICY
“ORDA Wealth” LLC (together with its affiliated entities, collectively “ORDA”) operates a mobile application called ORDA. ORDA (may be referred to as we, our, us) offers investment in alternative and other assets either with a fractionalized or full ownership structure (“Services”) through the ORDA Platform. This privacy policy (“Policy”) describes our data policies regarding users’ “Personal information” defined below, collected through our website located at www.orda.mn (“Website”) and mobile app “ORDA” (“App” hereinafter, and collectively, website and app are referred to as “Platform”). In accordance with the Personal Data Protection Law of Mongolia, ORDA and its Platform is considered a data controller that collects, uses and processes the data. As such ORDA has certain liabilities to the information providers. Thus, please read carefully and accept and agree to this Policy in order to proceed with using our Platform, in which case it shall be considered that you have given your consent to collect, use and process your data1 under the terms of this Policy. Upon agreeing to this Policy you accept and acknowledge that the information you provide is valid, current and accurate and that any misinformation will have its associated legal liability.
- Personal information you provide
For the purpose of this Policy personal information2 means personal data as described in the Mongolian laws and any information including but not limited to, your name, phone number, e-mail address, birth date, financial information, address or any combination of information that could be used to identify you in accordance with the general international standards. The data and information we collect from you depends on Services you choose to use and how you interact with the Platform:
Website Visitors. A casual site visitor can use the Website without registering to review selected information and learn about our products and Services. ORDA may collect data regarding the Website usage for monitoring traffic etc without prior consent from you, although we will not disclose such information unless otherwise required by laws. If you wish to become an investor, you will need to provide certain Personal information.
Investors. If you choose to access our Services as an Investor, we require that you complete a registration form and other necessary forms for compliance purposes. An Investor is an individual who is over the age of 18 and has completed the registration process on the Platform. Registration forms will specify the information which you must provide in order to enjoy the particular features to which you wish to subscribe that are designed to verify Investors’ identity, which may include such items as (i) name; (ii) email address; (iii) phone number(s); (iv) mailing address; (v) bank account number; (vi) birth date and (vii) official identification documents to authenticate and confirm your identity or to otherwise comply with applicable law. Registration forms may additionally request information that you may, at your option, choose to provide or withhold. To the extent this additional information constitutes Personal Information, we will treat it in the manner specified in this Policy. When you register with our Platform, we may also collect metadata associated with these media files including date, time, location and device information.
Location Data. We may collect your location information through our Platform by capturing the location (e.g. latitude/longitude) of your device. If you have given the app permission to access your location, we may collect your device’s location even if you are not using the Service and store your location history. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to restrict the app’s access to your location data. Geolocation data may be used to enhance the Services, for example to offer additional functionality and information regarding your location in connection with the location of assets listed on ORDA.
Automatically-Collected Information. Even if you do not register for an account on the Platform, we may collect certain information automatically. For example, we may automatically receive and record in our system the following information:
your internet protocol (IP) address and location;
referrer URL;
the type and version of your web browser;
device identifiers including mobile advertising identifiers; and
your operating system.
We also record page views and other general statistical and tracking information. We use this data to help us administer and operate our Platform, to better understand how our users access and interact with the Platform, and for security and monitoring purposes.
2. How we use your Personal information
We use the information we collect to deliver and improve the Services and your overall user experience; protect against, investigate and deter fraudulent, unauthorized and/or illegal activity; link or combine user information with other Personal Information;compare and verify information for accuracy and update our records; validate information for identity verification, including verification for anti-money laundering and “Know Your Customer” protocols; to email, text message, message or otherwise contact you with information and updates about us and the Services, and respond to your comments and questions if you’ve provided us with the means to do so; on a de-identified, aggregated basis, analyze how you use the Services with tools like Google Analytics to help us understand traffic patterns and know if there are problems with the Services; and/or to create targeted advertising to promote the Services and engage our users. ORDA shall not disclose Personal Information to third parties unless otherwise required or specified by law and this Policy.
3. How we share Personal information
We do no not sell or share any Personal information with third parties without your consent except to complete necessary transactions or provide any service that is requested or authorized by you. In these cases, we may share your Personal information to the following third parties:
Partners. We may collaborate with others to deliver our Services and may share Personal information as requested by our partners.
Affiliates. We may provide your Personal information with our affiliates and/or subsidiaries.
Service providers. We may share requested information with a wide range of third party service providers in connection with the performance of the applicable Services, such as database administrators, cloud computing services, advertising services, data analysts, application service providers, identity verification services and other non-governmental organizations.
Payment providers. We work with payment providers such as local banks, and other financial entities both domestic and foreign. They may store certain information about you.
Authorities. We may share your Personal information when we reasonably believe it is required to do so by law or to comply with legal or regulatory requirements, or to protect against fraud, illegal activity, or to protect ORDA against liability to the extent required by compliance requirements.
For safety and security. We may reveal your Personal information to third parties, including law enforcement agencies in order to protect the safety and security of our users or any third party if we have reasonable basis to do so..
The manner in which partners, service providers and payment processors use, store and/or disclose your information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with our Services. However, certain parties may provide services anonymously, and, in this case, we will only share Personal information that is directly related to the applicable service(s).
4. Tracking technologies
A “Cookie” is a small amount of data including a unique identifier that is sent to your browser by a website and stored on your hard drive. ORDA, or any third party we collaborate with may use cookies to help us analyze our web page flow, customize and measure our Services and advertising effectiveness.
You can prevent or limit the usage of cookies collected from your device by changing the settings in your browser. Unless you have adjusted your browser settings to refuse cookies, our system will send cookies as soon as you access our Services. By agreeing to this Policy, you consent to this use.
We may also use “Pixel tags”, small graphic images also known as “web beacons” to tell us what parts of our website have been visited or to measure the effectiveness of marketing campaigns on our Site. We may tie the information gathered by pixel tags to our users’ Personal Information, in which case it will be subject to the terms of this Privacy Policy.
5. Data security
Your account is protected by a password for your privacy and security. We take legally required and reasonable steps to secure and safeguard your Personal information against loss, theft, unauthorized use or modification. But no network, server or database can be guaranteed to have 100% security. Therefore, please be aware of the inherent risks associated with data security before submitting any Personal information on our Platform, and please understand that you are doing it at your own risk unless the Personal Data Protection Law is violated/breached by ORDA. .
6. Data retention
We keep your Personal information for as long as we have a business need to do so in connection with your account, or as required by the law (for tax, accounting or other purposes), whichever is longer.
7. Your choices:
Download or access Personal information. You can request a copy of your Personal information by e-mailing us at contact@orda.mn.
Opting out of e-mail communications. We may use some of your Personal information for marketing purposes, including sending you promotional communications about new features, products, events or other opportunities. If you wish to not receive these communications, please follow the opt-out instructions, such as clicking “unsubscribe”. Or you can contact us at contact@orda.mn to opt out. But despite your communications preferences, we may still send you important service related communications, such as notice of update to our Terms of Service or this Policy.
Update or delete information. You may be able to delete or update certain parts of your Personal information on the platform if allowed by current regulations and this Policy. Accordingly, at your request, we will take reasonable steps to remove your Personal information from our database. However, please note that we may not be able to delete some information, and we may not be permitted to delete your Personal information completely due to regulatory requirements and by any applicable law. Any deletion request may be sent to contact@orda.mn.
Children. Our platform is not directed to children under the age of 18. We do not knowingly seek to collect or retain any Personal information from children under the age of 18, and we will make reasonable steps to delete any Personal information determined to be provided by a child under the age of 18.
8.Changes to this Privacy policy
We reserve the right to alter, modify, update, add to, subtract from or make any other change to this Privacy policy at any time. New updates to this policy will become effective as of posting on our Platform. We encourage you to periodically review this privacy policy to stay informed about how we collect, use and share your Personal information.
9. Contact us
If you have any questions about this Policy, your Personal Information, or the Services, you can contact contact@orda.mn, or reach us via phone call at +976 7577 9444, or visit us in person at Galaxy Tower, 6th floor, 602 Stadion Orgil Mahatma Gandhi St. Khan-Uul District, 15th Khoroo, Ulaanbaatar, Mongolia.
Notes
1: 8.2 of the Personal Data Protection Law of Mongolia
2: 4.1.11 of the Personal Data Protection Law of Mongolia