PRIVACY POLICY

Last updated: 23 October 2023

1. Introduction

Orange Pill Ltd. (“we, “us” or “our”) take your privacy seriously. In this privacy policy (the “Privacy Policy”) we have compiled and described all essential information about our practices for handling the personal data that you provide us with in connection with the Merit Circle websites, applications or tools, and services available or accessible through the Merit Circle websites (collectively the “Services”) and the rights that you have in this regard. Your use of the Services is subject to this Privacy Policy and our Terms of Service.

We process your personal data for the purposes described in section 4 titled “How we use your personal data”. We are bound by data protection and privacy laws when processing your data, including the General Data Protection Regulations Act (“GDPR”) where applicable. See more on your data protection rights in section 7.

If you have any questions or enquiries relating to the Privacy Policy, please do not hesitate to contact us at privacy@meritcircle.io. This is also the address that you can contact if you wish to exercise any rights that you may have in connection with access or deletion of data or other rights you may have under data protection or privacy laws applicable to you.

2. Personal data we collect

We are committed to protecting your privacy and to remain transparent about the data that we do collect. We continue to explore solutions to further protect user’s privacy, such as opt-out prompts. In connection with our Services, we collect the following personal data:

• Public blockchain information: When you connect your non-custodial blockchain wallet in connection with the Services, we collect your blockchain address(es), which may be associated with your personal data. Such blockchain addresses are publicly available data that are not by themselves personally identifying.
• Personal data collected via technology: We may collect information about your web browser type, IP address, internet service provider and wallet type (provided by a third party wallet provider). This information is used to administer the Services and user friendliness. 
• Exchange of information and correspondence: If you contact us via email we will receive communications and information from you as included in the message.

Any material changes to the data we collect, or privacy will be reflected in an updated Privacy Policy.

3. Cookies

We do not use cookies in connection with our Service. We use Fathom Analytics who hashes the data collected.  

4. How we use your personal data

We utilize your data in accordance with the Terms of Service and as required by law for the following purposes:

• Provide you with our Services, including respond to your requests and inquiries.
• To enable us to investigate and address any activities or conduct that may be in violation of our Terms of Service, including to detect, prevent and address fraud or other unlawful or harmful activities.  
• We only collect information that you provide us and keep it to ourselves. We do not sell or transfer this information to third parties.
• Comply with applicable laws and to cooperate with any investigations or enforcements of authorities or regulators relating to any suspected violations of law or legal claims.
5. Sharing of data 

We may disclose or share your personal data as follows (in which case we will always seek to encrypt personal data as much as practicably possible prior to sharing):

• Legal obligations: Your personal data may be shared to comply with legal obligations, such as in connection with fraud and illegal activities, regulatory proceedings, court orders, compliance measures or otherwise where we may be obliged to do so pursuant to applicable law.
• Restructuring and business changes: Personal data may be transferred by us to another entity in the event of a restructuring, merger, demerger, bankruptcy or similar.
• With your consent: Your personal data may be shared if you provide us with your consent to do so. 
6. Third party websites and wallets

Our Services may contain links to third party websites. When you click on a link to any other website or location, you will leave our Services, and another entity may collect personal data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. This Privacy Policy does not apply to these third-party websites or their content, or to any collection of your personal data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. 

Your interaction with any third-party wallet is governed by the applicable terms and privacy policy of the third party providing you with such wallet. You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.

7. Your data protection rights

You may have certain data protection rights according to law applicable to you, including:

• Right of access: You have the right to ask us for copies of your personal data.
• Right to erase: You have the right to ask us to erase your personal information in certain circumstances in accordance with applicable law.
• Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data in certain circumstances in accordance with applicable law.
• Right to object to processing: You have the right to object to the processing of your personal information in certain circumstances in accordance with applicable law.
• Right to data portability: You have the right to ask that we transfer the personal data you gave us to another organization, or to you, in certain circumstances in accordance with applicable law.
• Right to withdraw consent: If we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time.
8. Data retention

We may retain your personal data as long as you continue to use the Service or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. Subject to applicable laws, we may continue to retain your personal data even after you cease to use the Services if such retention is necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms of Service or other agreements, or protect our legitimate interests. Where your personal data is no longer required for these purposes, we will delete it.

9. Changes to the Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at https://meritcircle.io/privacy-policy. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. You are responsible for periodically visiting our Services and this Privacy Policy to check for any changes.