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OrangeX.com Terms of Service and Conditions

Last revised: July 15, 2026

These Terms of Service were prepared in the English language. The English version shall prevail in the event of any conflict, discrepancy or ambiguity between translations.

These Terms of Service apply to the Website and all of your use of the services offered by OrangeX.com. Please read the contents carefully before you use the Website or any of our services. If you have any questions, please contact us by sending an email to support@orangex.com.

Article 1. Definitions

1.1. Capitalized terms in these terms & conditions shall have the following meaning:

Account:Your personal environment on our Platform, where you can manage your funds and trade Products;

API:An Application Programming Interface with the Platform that enables you to externally manage your Account and trade Products;

Cryptocurrency: Bitcoin, Ethereum, and all other digital currencies that can be used to trade Products on our Platform;

Intellectual Property Rights: All intellectual property rights and related rights such as copyright, trademark rights, patent rights, (un)registered design rights, trade name rights, logos, database rights and neighboring rights, as well as rights to know-how and sui generis intellectual property rights;

Order:An offer to trade a specific number of Products against a specific value, which offer is added to the Order book until it is accepted (matched to another order) or cancelled;

Platform:The application and underlying infrastructure made available by us which you can access remotely and where you can access your Account and trade Products;

Position:The outstanding Products you have traded on our Platform;

Products:All Cryptocurrency derivative contracts, such as futures, options and perpetual swaps, that can be traded on our Platform;

Terms of Service:These terms and conditions, which apply to (the use of) our Website and all agreements concluded between you and us;

Trade:When an order is (partly) matched to another order (accepted);

Wallet:The digital storage vault managed and made available by us where you can store Cryptocurrency to be used to trade Products;

Website:www.OrangeX.com and all underlying pages.

Article 2. General

2.1. Operating Entity / Your Contracting Party
The OrangeX.com platform is operated by the OrangeX Group, comprising a number of affiliated legal entities.

Default contracting party.

Unless we have expressly notified you, in accordance with the notice provisions of these Terms of Service, that another OrangeX Group entity is your contracting party, and provided that you are eligible to receive the Services and are not located in a Restricted Jurisdiction as set out in Section 2.5, the Services will be provided to you by, and your contracting party under these Terms of Service will be:
— OrangeX Fintech s.r.o. (identification no. 198 92 853), with its registered office at Sokola Tůmy 743/16, Mariánské Hory, 709 00 Ostrava, Czech Republic, registered with the Commercial Register maintained by the Regional Court in Ostrava, Section C, Insert 94162.

Other OrangeX Group entities.

One or more of the following OrangeX Group entities may be designated as your contracting party in respect of specific Services, pursuant to applicable product-specific terms or by notice from us in accordance with these Terms of Service:
— EE Legend Pty Ltd (ACN 692 323 283), with its registered office at 4 Monteith Street, Turramurra NSW 2074, Australia, registered with the Australian Transaction Reports and Analysis Centre (AUSTRAC) under registration no. DCE100906401-001;
— OrangeX Limited (BVI company no. 2153535), incorporated in the British Virgin Islands as a BVI Business Company under the BVI Business Companies Act, 2004 on 17 July 2024;
— OrangeX LLC (company no. 3687 LLC 2024), with its registered office at Euro House, Richmond Hill Road, Kingstown, St. Vincent and the Grenadines, formed in Saint Vincent and the Grenadines on 27 June 2024.

Where an OrangeX Group entity is designated as your contracting party, it will be your contracting party solely in respect of the Services covered by the relevant product-specific terms or notice. The default contracting party identified above will continue to apply to all other Services you use.

Changes to your contracting party.

Subject to Section 2.7, and notwithstanding the general timing provisions in Section 2.6, where another OrangeX Group entity is designated as your contracting party, such designation and any related assignment or transfer of rights and obligations will take effect on the effective date specified in the applicable product-specific terms or notice issued to you. Until that effective date, your existing contracting party will remain your contracting party in respect of, and remain responsible for, the relevant Services.

References in these Terms of Service, and in any other OrangeX.com policy or notice, to “OrangeX.com”, “the Company”, “we”, “us” or “our” mean the OrangeX Group entity that is your contracting party as determined in accordance with this Section 2.1. Each OrangeX Group entity is responsible only for the Services it provides to you and does not assume the obligations of any other OrangeX Group entity.

2.2. Risks: With our Platform, we offer you a tool to sell or buy Products for your own account and at your own risk. You acknowledge, agree and accept that trading products entails a high financial risk and that there is additional counterparty risk because our Products are derivative contracts. You have the necessary experience and knowledge to understand the risks involved in our products. You should carefully assess whether your financial situation and tolerance for risk is suitable for buying, selling or trading cryptocurrency. You may lose all of your funds in your account.

2.3. No advice: At no time should any information provided in these Terms of Service or on our Website be construed as financial advice. We do not provide any opinion on the merits of any particular investment. Any information provided is for educational purposes to keep the investor informed of prices, ranges, and volatility of Cryptocurrency. In addition, we do not act as your broker, intermediary, agent or advisor in any fiduciary capacity.

2.4. None of the services of http://OrangeX.com amount to any marketing, or promotion or offer to any product or investment to you or any third party. You are solely responsible for any losses, damages or costs resulting from your reliance on any data or information that http://OrangeX.com may provide. You will make your own independent decision to access or use our Website and/or Platform.

2.5. Restricted areas: The access or use of our Platform and the services we offer is not available if you are located, incorporated or otherwise established in, or a citizen or resident of (i) the United States; (ii) Panama; (iii) any other country or area designated as a restricted area on our Website; (iv) a jurisdiction where it would be illegal for you to access or use of our Platform. If you are a resident of or are operating from a restricted area as defined in this article, we reserve our right to terminate your Account with immediate effect.

If you are a resident of or are operating from a restricted area as defined in this article, including but not limited to Australia,Belarus,Burundi,Cuba,China Mainland,Democratic People's Republic of Korea(DPRK),Hong Kong,Iran,Myanmar,Panama,Russia,Russian-controlled regions of Ukraine (currently including the Crimea, Donetsk, and Luhansk regions),Singapore,Syria,South Sudan,Sudan,United States of America,United Kingdom,Venezuela, Israel, Slovakia, India, Ukraine or any other jurisdictions in which we may determine from time to time to terminate the services at our sole discretion (the "Excluded Jurisdictions"), we reserve our right to terminate your Account with immediate effect.

Subject to applicable laws and regulations and the restrictions set out above in this Article, we may provide Services to eligible customers outside the Excluded Jurisdictions. Customers from, located in, or otherwise associated with higher-risk countries or regions may be subject to enhanced identity verification, additional due diligence, service restrictions or other risk-control measures.

2.6. Updates: These Terms of Service may be updated from time to time. We will notify you about any amendments to our Terms of Service in advance on our Platform and/or per email. The amended Terms of Service will apply to our legal relationship at the earliest of the following moments: when you accept the amended Terms of Service, when you keep using our Platform after you have been informed about our updated Terms of Service or one month after our notification of the amended Terms of Service. If you do not agree with the amended Terms of Service, your sole remedy is to terminate the use of our services.

2.7. Assignment: We may assign or transfer our rights and obligations under these Terms of Service, in whole or in part, to any OrangeX Group entity, upon notice to you on our Platform and/or by email in accordance with Article 2.6. You may not assign or transfer any of your rights or obligations under these Terms of Service without our prior written consent.

Article 3. Our Platform

3.1. Availability: We will do our utmost to ensure that the Platform is available at all times, but we may not always be able to prevent downtime or limited functionality of the Platform. You agree and accept that i) we do not guarantee the continuous availability of the Platform and ii) the Platform has the functionality as available during your use ( ‘as is’). We will remedy any bugs and other defects and make available updates of the Platform at our sole discretion and on a best efforts basis.

3.2. Unavailability errors: As the use of our Platform is at your own risk, you acknowledge that we are not responsible for any errors, delays, communication failures and other malfunctions of the Platform, and that the consequences of such malfunctions shall be for your own account.

3.3. Changes and restrictions: We are at any time entitled to i) make functional, procedural or technical changes or improvements to the Platform, and to ii) (temporarily or permanently) limit or remove functionalities of the Platform, terminate the Platform entirely or to restrict the use of the Platform, without becoming liable to you.

3.4. Accuracy of information: We do our utmost to offer correct and up to date information on our Platform, including market information. However, you acknowledge and accept that such market data may not be accurate and that the use of the market data when trading Products shall be at your own risk.

Article 4. Your Use of our Platform

4.1. Account: To be eligible to use our Platform, you need to create an Account by submitting the details requested in our Account creation form. You warrant that the information you provide is correct and up to date.

4.2. Verification: You acknowledge and accept that we may be required to perform additional checks from time to time to verify your identity and the business relationship, including, but not limited to, by means of a copy of a valid identification document and/or proof of residential address. You warrant that the information you disclose in this respect is at all times correct, authentic and up to date. We reserve the right to suspend, terminate or limit your right to use the Platform (which may include imposing trading limits) until we have verified your identity or if the results of our identity verification process give rise to such measures.

4.3. Credentials: The login credentials to access your Account are strictly personal. You are solely responsible for keeping your login credentials, 2FA-tokens, and other Account login details confidential. It is your responsibility to contact us immediately when you suspect unauthorized use of your login credentials or your Account.

4.4. Use of your Account: You are at all times responsible and liable for any use of your Account, including (unauthorized) trading activity by a third party. You acknowledge and accept that we may not be able to undo transactions executed bya third party through your Account.

4.5. Using the Wallet on our Platform is at all times at your own risk. We are not liable for loss of Cryptocurrency stored in your Wallet or transferred to or from your Wallet, including, but not limited to unauthorized access by a third party, loss or violation of your private key or transferring Bitcoin to an Ethereum address.

Article 5. Products

5.1. Products: You can only trade the Products that are available for trading on our Platform at the time you use the Platform. We reserve our rights to add and remove Products to and from our Platform at our sole discretion. Although we will do our best to inform you timely before removing a Product from our Platform, we reserve our right to do so without prior notice.

5.2. Cryptocurrency: The Cryptocurrency we support for the Products we offer for may change from time to time. We reserve our right to terminate support of aCryptocurrency on our Platform at our sole discretion. Although we will do our best to inform you timely before removing a supported Cryptocurrency from our Platform, we reserve our right to do so without prior notice.

5.3. Consequence of removal: If we remove a Product or Cryptocurrency from our Platform, any outstanding Order will be cancelled. You will be given the opportunity to withdraw the Cryptocurrency from your account.

5.4. Product terms & policies: Additional terms and contract specifications per Product apply, which terms and policies are available in the Knowledge Base on our Website. By placing an Order, you accept the terms and contract specifications that apply to the relevant Product.

5.5. Funds: You can only place an Order if you have sufficient funds in your Wallet or have sufficient margin balance available for trading. From time to time, at our sole discretion, we are entitled to adjust margin requirements that may result in a different available margin balance.

Article 6. Trading

6.1. No refunds: Placing Orders and making Trades is at your own risk. Any Trade you make, whether on purpose or by mistake, is final and can not be reversed. No refund of any Trade shall take place.

6.2. Reversing/adjusting Trades: We reserve our right to reverse a Trade or adjust the price of a Trade that we regard as being abnormal in respect of the price level to be expected from an orderly market.

6.3. Trading pause: We reserve our right to halt or limit the possibility to place Order sor make Trades on the Platform, without becoming liable to you for any alleged damages resulting from halting or limiting trading.

6.4. Trading restriction: We reserve our rights to limit your right to place Orders, cancel Orders and/or close your Positions without becoming liable for any alleged damages you may have incurred due to such measures.

6.5. Liquidation: If your available funds are insufficient for your Position(s), then your Positions will be incrementally closed against the then-available prices in the market until your funds are sufficient for the remaining of your Positions, in accordance with the applicable terms and policies for the relevant Product.

6.6. Bankruptcy: If your Positions have been liquidated and the amount of Cryptocurrency in your Wallet is insufficient to cover your (additional) losses, your Account is bankrupt. We will reset the balance of the relevant Cryptocurrency in your Account to zero by transferring funds from the Insurance Fund to your account.

6.7. Insurance Fund: The fund that will be used to cover for losses of bankruptcies. The balance of the Insurance Fund and terms that apply are available on our Website. If bankruptcies in a session deplete the Insurance Fund, any further losses will be covered by profits made by traders on the Platform on a pro rate basis. In such a case, all winning traders of a session would get taxed a percentage on their profits to cover for bankruptcies.

Article 7. API

7.1. Use & Availability: you acknowledge and accept that the API may not be available at all times. We are not responsible for any wrong Orders or other incorrect actions on our Platform when using our API.

7.2. Costs: Upon notifying you in advance, we are entitled to amend the fees that apply to the use of our API.

7.3. Discontinuation: We reserve our rights to, without prior notice, terminate the support of the API and to limit or suspend the functionality thereof.

Article 8. Fees & Withdrawals

8.1. Fees: You acknowledge and agree that fees will apply when you use our Platform. Depending on the type of Trade you conclude on our Platform, we will charge a transaction fee or grant a transaction rebate, which will be deducted from or added to the value of the Trade. The applicable fees and rebates per Product and per type of Trade may be amended from time to time and are available on our Website.

8.1.1 Referring users who already have OrangeX accounts, or engaging in fraudulent activities, will result in a revoked affiliate status and a reduction of your rebate percentage to 0%.

8.1.2 Referrals from the same IP address or device will be considered self-referrals, leading to the forfeiture of all associated benefits. OrangeX reserves the right to confiscate the offending accounts and any assets within them.

8.1.3 Attempting to deceive users with phishing sites or pages impersonating the official OrangeX website will result in the revocation of your affiliate status and a reduction of your rebate ratio to 0%.

8.2. Withdrawal: You may withdraw your available Cryptocurrency from your Wallet, provided that i) your withdrawal request exceeds the minimum withdrawal requirement as communicated on the Platform, and ii) your available margin balance remains sufficient to uphold your Positions. The fee for a withdrawal depends on the current state of the network of the Cryptocurrency. We are not responsible, nor liable, for any fees that may apply to your withdrawal request.

8.3. Delay: You acknowledge and accept that we may not be able to immediately execute any withdrawal request (for instance due to offline storage of your Cryptocurrency). We use our best efforts to execute a withdrawal request within48hours. We are not liable for any alleged damages you claim to have incurred due to a delay in executing your withdrawal request.

8.4. Withdrawal freeze: We may suspend a withdrawal request and/or limit your right to withdraw Cryptocurrency for a period of time, for instance if we are required to investigate a request or suspect a violation of these Terms of Service, applicable law or other applicable terms.

Article 9. Liability

9.1. Limitation of liability: If we are liable as a result of an attributable breach of our obligations, an unlawful act or otherwise, our liability will be limited to compensation of only your direct damages to a maximum of the fees paid by you to us during the six(6) month period prior to the cause of action.

9.2. Indirect damages: Any liability for damage other than direct damage ("indirect damages"), including – but not limited to – consequential damages, loss and/or damage of data, loss of profits, business opportunity, revenue or goodwill as well as lost Trades or sales, is excluded.

9.3. Unavailability: We shall not be liable for any damages you may incur due to(parts of) the Platform or the API being (temporarily) unavailable.

9.4. No limitation: The limitations and exclusions of liability mentioned in the preceding paragraphs of this article will lapse if and in so far as the damage is the result of our intentional or willful recklessness.

9.5. Notice of liability: We shall not become liable for the compensation of your damages before you have reported the damages to us in detail. Any claim for compensation will lapse if you have failed to report such claim within three months after your damages arose.

Article 10. Force Majeure

10.1. Force Majeure: any event beyond our reasonable control, such as – but not limited to – flood, extraordinary weather conditions, earthquake, or any other Act of God, fire, war, insurrection, riot, labor dispute, accident, action of government, failure of our suppliers to comply with their obligations, a communications failure (including internet), power failure, or equipment or software malfunction shall qualify as a"Force Majeure Event".

10.2. Excused Performance: Any non-performance from our side that is the result of aForce Majeure Event shall not be attributable to us.

10.3. No liability: We shall not be liable for any damages which we could not prevent due to a Force Majeure Event.

Article 11. Warranties & Indemnification

11.1. Your warranties: you represent and warrant that:

11.1.1. You have accepted our Terms of Service when you create an Account;

11.1.2.You are at least 18 years old and have the capacity to create an Account and use the Platform;

11.1.3. You are not a resident or representative of an entity in the sense of article 2.5 of these Terms of Service;

11.1.4. if you are using our Platform on behalf of your organization, you are authorized to do so. The relevant organization will be liable for your actions, including any breach of these Terms of Service;

11.1.5. You, or any party affiliated with you, are not in any way sanctioned by or under investigation in relation to anti-money laundering laws, counterterrorism financing laws, anti-corruption laws, economic sanctions laws or related regulations;

11.1.6. You must not use the Website in any way that causes, or may cause, damage to the Website or impairment of the availability or accessibility of the Website, or in any way which is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose of activity;

11.1.6.1 If you engage in any of the following behaviors, your rebates, self-rebates, commissions, etc., may be canceled or reduced to 0%.

Market Manipulation: Engaging in any form of market manipulation, including but not limited to wash trading, artificially inflating trading volumes, or participating in pump and dump schemes.
Fraudulent Activities: Involvement in any fraudulent activities such as identity theft or the use of unauthorized payment methods will lead to immediate cancellation of rebates.
Failure to Comply with Policies: Any violation of the exchange's terms and conditions will result in the cancellation or reduction of rebates. This includes, but is not limited to, failure to complete required identification verification.
High-Frequency Trading: Users exhibiting excessively high trading volumes within a short timeframe may be subject to a reduction of their rebates.
Account Misuse: Sharing of accounts or the opening of multiple accounts to bypass trading policies may lead to cancellation of rebates.
False Information: Providing misleading or false information during the registration process or trading will result in cancellation of rebates.

11.1.7. You must not use the Website to copy, store, host, transmit, send, use publish or distribute any material which consists of, or is linked to, any spyware, computer virus, Trojan horse, worm, keystroke, logger, rootkit or other malicious computer software;

11.1.8. You shall not perform any (distributed) denial of service or other malicious attacks, or conduct any systematic or automated data collection activities (including without limitation scraping, data mining, data extraction and data harvesting);

11.1.9. You only deposit, trade and withdraw Cryptocurrency that are your own and that have been legally obtained in your Account;

11.1.10. the Cryptocurrency deposit addresses and withdrawal addresses you have provided to us are your own and that you have full control over these addresses;

11.1.11. You are aware of the risks using our Platform, including, but not limited to, high volatility risk of Cryptocurrency and the fact that you may loss all your Cryptocurrency in your Account if the market moves against you;

11.1.12. You will at all times comply with applicable laws and regulations;

11.1.13. You have knowledge and experience in trading the Products we offer and are aware of the risks related to our Platform and services, including losing all the Cryptocurrency you deposit to your Wallet;

11.1.14. You will not be involved or initiate any form of market manipulation, including spoofing orders or otherwise; and

11.1.15. The information and documents you provide are correct, genuine and up to date.

11.2. Upon our first request, you will indemnify us from all third-party claims resulting from or related to your breach of these Terms of Service, applicable law, or any of the terms that apply to your use of our Platform, as made available on our Website.

Article 12. Privacy

12.1. Use of personal data: You warrant that the personal details you provide to us are at all times correct and up to date. We will at all times process your personal data in accordance with our Privacy Policy.

Article 13. Intellectual Property Rights

13.1. Ownership: The Intellectual Property Rights in relation to our Platform are held by the relevant OrangeX Group entity or its licensor(s). Nothing in these Terms of Service may be interpreted to constitute a transfer of Intellectual Property Rights from one party to the other.

13.2. License: Under the condition that you comply with these Terms of Service, you are granted a non-exclusive, non-sublicensable and non-transferable right to access and use the Platform, including our Website, your Account and all materials made available on our Platform for your own personal use and to the extent required for your use of our services.

Article 14. About Brand Authorization

14.1 The company ORNGX LIMITED is officially authorized by OrangeX (OrangeX.com) to use the OrangeX.com brand name and logo.
Operating as an independent entity from orangex.com, ORNGX LIMITED is permitted to use the OrangeX.com name and logo under separate products, terms and conditions.

14.2 Its associated platforms include, but are not limited to:

Website: http://www.orngx.com
Application Name: OrangeX Pro

Article 15. Suspension & Termination

15.1. Termination by you: You are entitled to terminate your agreement with us by sending an email to the address provided on our Website.

15.2. Suspension: if we suspect that you have breached these Terms of Service, applicable law and/or the trading terms provided on our Website, we may temporarily suspend your Account and limit your trading. We are entitled to limit your right to place Orders, cancel Orders and/or close your Positions during this investigation. Deposits or withdrawals of Cryptocurrency may be limited by us. We are not liable for any alleged damages you may have incurred due to such measures.

15.3. Termination by us: We reserve our rights to terminate your Account at any time and without stating reasons. Unless we are required otherwise by applicable law or a judicial order, we will provide a notice period of seven days before your Account is terminated. In this notice period you will be able to close your Positions and withdrawCryptocurrency from your Wallet. After the notice period has lapsed, we are entitled to immediately close any Positions that may still be open and return any remaining Cryptocurrency to you. We will not be liable for any damages you may incur due to us invoking our right to terminate your Account.

15.4. Survival: The terms of these Terms of Service that are constituted to survive termination of our agreement shall remain applicable in case of termination of such agreement, including, but not limited to the following articles: Article 2, Article 9, Article 11, Article 12, Article 14, Article 15, Article 16 and Article 17.

Article 16. Enforceability

16.1. Enforceability: If at any time any provision of these Terms of Service is or becomes illegal, void or invalid, such invalidity shall not affect the validity of the remainder of the Terms of Service. We will replace such invalid provision by such other provision which, being valid in all respects, shall have an effect as close as possible to that of the replaced provision.

Article 17. No Waiver

17.1. Any failure or delay by us to enforce any provision of these Terms of Service or to exercise any right under these Terms of Service will not be construed as a waiver to any extent of our rights.

OrangeX.com Privacy Notice

Last updated: December 4, 2024

1. Introduction

This Privacy Policy (this "Policy") applies to the trading platform (including any applicable mobile applications and websites used to access the same) (collectively the "Platform") provided by http://orangex.com (the "the Company", "we", "us", or "our"). The OrangeX Group entity that operates the Platform and that acts as "the Company", "we", "us" or "our" — and, for the purposes of data protection law, the data controller of your Personal Information — is the entity identified as your contracting party in our Terms of Service, available at https://www.orangex.com/terms?type=conditions. The relevant entity is determined by your country of residence; its full legal name, registered address and registration details are set out in that document. It describes how the Company collects, uses, and discloses Personal Information that we obtain from users of the platform and any account services provided through the platform, and how we use and disclose that information. For purposes of this Policy,"Personal Information" refers to information supplied by a user from which the identity of such User may be directly or indirectly determined.

We prioritize the security and privacy of your Personal Information. We are committed to ensuring that all Personal information is processed in accordance with the highest standards of data protection and privacy regulations, and that technical and organizational measures are put in place. Our robust data management practices are designed to safeguard your information and maintain your trust.

It is important that you familiarize yourself with the provisions of this Policy together with terms and conditions and any other privacy notices we may provide on specific occasions when we are collecting or processing personal information so that you are fully aware of how and why we are using your Personal Information.

By registering for and using the Platform, you agree that your Personal Information will be handled as described in this Policy and the Terms and Conditions applicable to the Platform (the "Serviice Agreement"); capitalized terms used herein shall have the same meaning as set forth in the Service Agreement

We are committed to transparency in our data practices and aim to provide users with clear information regarding the processing of their personal data.

2. Scope and Applicability

As part of the Company’s daily operations, we collect personal data to provide users with our products and services. This Policy outlines how we process your personal data across our Website and related services.

The personal data collected by OrangeX.com will only be used for the purposes for which it was originally collected or as permitted under applicable legislation. It will be processed to fulfill our contractual obligations to users, comply with legal obligations (such as AML/KYC regulations), and pursue legitimate business interests.

This Policy applies to the processing of personal data regardless of the method or environment in which the personal data is provided (e.g., online, paper forms, by phone, etc.) and whether processed manually or through automated means.

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. Our Commitment to You

OrangeX.com fully understands the importance of maintaining the confidentiality and privacy of your personal data. We respect your privacy and are committed to taking all reasonable measures to protect and safeguard your personal data in accordance with the highest standards of data protection and security.

We employ various technical and organizational measures (TOMs) to protect personal data, including but not limited to:

Encryption of personal data both in transit and at rest,
Access controls and authentication mechanisms to ensure that only authorized personnel can access personal data,
Employee training on data privacy and security best practices to mitigate risks of accidental or unlawful data breaches.

In addition, we are committed to:

Regularly reviewing and updating our data protection practices,
Ensuring the security of processing in line with GDPR Article 32,
Informing users about how their personal data is processed and their rights under the GDPR,
Addressing any concerns users may have regarding their data processing rights, security, or privacy.

4. How do we collect your Personal Data?

We use different methods to collect information from and about you, including through:

Direct interactions:

You may provide us with your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data and Marketing and Communications Data by directly interacting with us, including by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal data you provide when you:

Visit our Site or App;
Apply for our Services;
Create an account;
Make use of any of our Services;
Request marketing to be sent to you, for example by subscribing to our newsletters;
Enter a competition, promotion or survey, including through social media channels; or
Give us feedback or contact us.

Legal Basis: We process this data based on contractual necessity (for account creation and service provision), consent (for marketing communications), and legitimate interests (for improving services and fraud prevention).

Automated Technologies or Interactions:

As you interact with us via our Site or App, we automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other online identifiers. We will also collect Transactional Data and Usage Data. You may find more information about how we use cookies through the Cookie Preferences link.

Legal Basis: Data collected via cookies and tracking technologies is processed based on consent (for cookies and marketing preferences), and legitimate interest (for analytics and improving services).

You have the right to manage or withdraw your consent for the use of cookies at any time via the Cookie Preferences link available on our Site.

Social Media Widgets and Similar Links:

Our Site may contain links, social media plug-ins, "widgets", "tweet", "share" and "like" buttons linked to social media platforms such as Facebook, X (Twitter), Instagram, Threads, Discord, LinkedIn, Reddit and Telegram. Please note that when you interact with these social media plug-ins, your data may be collected by these third-party platforms. For more information on how these platforms process your data, please refer to their respective privacy policies.

5.What Personal Data do we collect?

Personal data

Personal data, or personal information means any information that relates to an identified or identifiable living individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.

Category of personal data	Examples of specific pieces of personal data
Identity Data	full name maiden name username or similar identifier date of birth biometric information, including a visual image of your face national identity card, passport, driving licence or other form of an identification document.
Contact Data	country of residence email address or telephone numbers proof of address documentation (if applicable))
Financial Data	bank account payment card details virtual currency accounts stored value accounts
Transactional Data	details about transaction to and from you other details of any transactions you enter into using the Services, Site or App.
Technical Data	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 diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and other information stored on or available regarding the devices you allow us access to when you visit the Site, or use the Services or the App.
Profile Data	username and password identification number as our user information on whether you have Orangex.com App account and the email associated with your accounts requests by you for products or services your interests, preferences and feedback other information generated by you when you communicate with us, for example when you address a request to our customer support.
Usage Data	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 time event time, name and source.
Marketing and Communications Data	your preferences in receiving marketing from us or third parties your communication preferences your survey responses.

6. How do we process your Personal Data?

Lawful Basis for Processing

We will only process your personal data when we have a lawful basis to do so, in accordance with applicable legislation. Most commonly, we will process your personal data in the following circumstances:

performance of a contract: We process your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract. We rely on this basis for the provision of our services, such as account creation, processing transactions, and fulfilling other contractual obligations.

legitimate interests: We process your data based on our legitimate interests (or those of a third party) as long as your interests and individual rights do not override those interests. For example, we may process your data for fraud prevention, to ensure the security of our platform, or for the improvement of our services. We conduct regular assessments to ensure that our legitimate interests are balanced against your rights.

compliance with a legal obligation: We process personal data where it is necessary to comply with a legal obligation to which we are subject. For example, we are required to collect and process personal data to comply with anti-money laundering (AML) and Know Your Customer (KYC) regulations.

consent: We process your personal data when you provide freely given, specific, informed, and unambiguous consent to us. This may include consent for marketing communications or other optional services. In cases where consent is required, we will request it in a clear and explicit manner. You have the right to withdraw your consent at any time by contacting us or updating your preferences in your account settings.

Purposes for which we use your personal data

We have set out below, in table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose and/or activity	Categories of personal data	Legal basis for processing
To register you as a new customer	Identity Data Contact Data Financial Data	Performance of a contract
To carry out and comply with anti-money laundering requirements	Identity Data Contact Data Financial Data Transactional Data Technical Data Profile Data	Compliance with a legal obligation
To process and deliver the Services (including products offered by third-party service providers with whom we work) and any App features to you, including to execute, manage and process any instructions or orders you make through the Services	Identity Data Contact Data Financial Data Transactional Data Technical Data	Performance of a contract Consent, if required
To prevent abuse of our Services and promotions	Identity Data Contact Data Financial Data Transactional Data Technical Data 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 which will include asking you to leave a review, take a survey or keeping you informed of our company's business and product development	Identity Data Contact Data Profile Data Transactional Data Marketing and Communications Data	Performance of a contract Consent, if required
To keep our recordsupdated and to studyhow customers use ourproducts/services	Identity Data Contact Data Profile Data Transactional Data Technical Data 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	Identity Data Contact Data Financial Data Transactional Data	Performance of a contract
To obey applicable legislation and handle complaints, including: manage risk and crime prevention involving performance of anti-money laundering, counter terrorism, sanction screening, fraud and other background checks detect, investigate, report and prevent financial crime in a broad sense and ensure your account's security, in order to honor requests regarding information and/or changes to your account	Identity Data Contact Data Financial Data Transactional Data Technical Data Profile Data Usage Data 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.
To enable you to partake in a prize draw, competition or complete a survey	Identity Data Contact Data Profile Data Usage Data Marketing and Communications Data	Performance of a contract Consent, if required
To gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business	Identity Data Contact Data Profile Data Usage Data Marketing and Communications Data	Legitimate interests: understanding our customers and improving our products and services
To administer and protect our business, our Site, App(s) and social media channels including bans, troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data	Identity Data Contact Data Financial Data Technical Data Transactional Data Usage Data	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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Data Contact Data Profile Data Usage Data Technical Data 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 improve our website, products/services, marketing, customer/user relationships and experiences	Technical Data Usage Data 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 make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Data Contact Dat Technical Data Usage Data Profile Data Marketing and Communications Data	Legitimate interests: to develop our products/services and grow our business Consent, if required
To use the services of social media platforms or advertising platforms some of which will use the personal data they receive for their own purposes, including marketing purposes	Technical Data Usage Data	Consent
To use the services of and enter into partnerships with, financial institutions, third-party partners whose products form a part of the Services offered, crime and fraud prevention companies, risk measuring companies, which will use the personal data they receive for their own purposes in their capacity of independent controllers	Identity Data Contact Dat Financial Dat Transactional Data Technical Data Usage Data	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 an automated decision?

Automated decision is usually a decision that may impact you and is made automatically based on software algorithms, without human intervention. As an illustrative example, we use automated decisions to complete the onboarding process of a new customer or to perform anti-fraud monitoring.

Why is an automated decision important to you?

Depending on the particular case, using your personal data may lead to automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you.

How do we protect your interests regarding automated decisions?

The rights and interests of individuals whose personal data undergoes automated decision-making is safeguarded through appropriate measures. When an automated decision is made about you, you have the right to oppose the decision.. If you need more detailed information or wish to exercise this right, please contact us.

Marketing

We may use your Identity Data, Contact Data, Technical Data, Transactional Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us and consented to receive marketing communications, or if you have purchased from us and you have not opted out of receiving such communications. We will use your Marketing and Communications Data for our respective activities.

Third-party marketing

We will obtain your opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

Youmay opt out of marketing communications at any time by following the opt-out links on any marketing message sent to you.

Further, you can login and cancel the marketing messages in Notifications.

Where you opt out of receiving marketing messages, this will not apply to service messages which are directly related to the use of our Services (e.g. maintenance, change in the terms and conditions and so forth).

Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Platform. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).

Cookies.

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Platform, while others are used to enable a faster log-in process or to allow us to track your activities at our Platform. There are two types of cookies: session and persistent cookies.

Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Platform. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Platform.

Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

Please note that our systems do not currently respond to do-not-track signals.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The general settings on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Users of our Platform who disable cookies will not be able to browse certain areas of the Platform.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Platform. We also may use other analytic means to evaluate our Platform. We use these tools to help us improve our Platform, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your Personal Information with these third parties.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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

Sale or transfer of business

We may also need to process your data in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving all or a part of our shares, business or assets. This will be based on our legitimate interests in carrying out such transactions, or to meet our legal obligations.

7. Contacting You

The Company or its affiliates, business partners, associates or other agents may, from time to time, contact you by telephone, email, or otherwise, for the purposes of offering you further information about the Company’s products and services, or to inform you of promotional offerings, or for marketing purposes, or to conduct market research, with your prior consent.

In case you do not agree to receive these marketing messages or calls, this will not have any impact on the provision of our services to you.

If you wish to opt-out of any further contact at any time and for whatever reason, you are entitled to do so by contacting the Company’s back-office department via email dpo@orangex.com and requesting in writing that you wish no further contact in relation to the above reasons.

8. Disclosure and Transfer of your Personal Data

We may share your personal data with third-party service providers, agents, subcontractors, group companies, and affiliates (as described below) to carry out specific tasks, complete services, and provide the use of the App on our behalf. When using third-party service providers, we require them to respect the security of your personal data and to process it in accordance with applicable data protection laws, including GDPR.

We may disclose your personal data to the following entities:

Companies and organizations that assist us in processing, verifying, or refunding transactions/orders you make and in providing any services that you have requested;
Third-party service providers whose products, services, or applications are hosted/integrated on our Site and App;
Identity verification agencies for conducting necessary verification checks, such as AML/KYC (Anti-Money Laundering/Know Your Customer);
Fraud prevention and crime prevention agencies to help combat crimes, including fraud, money laundering, and terrorist financing;
Any entity to whom we may lawfully transfer or assign our rights and obligations under the relevant terms and conditions governing the use of our Services;
Any third party due to the restructure, sale, or acquisition of our group or affiliates, provided that the recipient uses your information for the same purposes for which it was originally collected;
Regulatory and law enforcement authorities inside or outside the Republic of Seychelles, when required or permitted by law.

Specifics Regarding the Use of Blockchain Technology

Certain services provided by OrangeX.com 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. However, it is important to note that once data is added to the blockchain, it becomes virtually impossible to remove or delete.

Transfer of Information Across Jurisdictions

We may store your Personal Information on servers located in countries where our main offices are based. If the jurisdiction in which your data is stored is outside your country of residence, you consent to the transfer of your personal information to such jurisdictions. This transfer is necessary for the purposes of providing you with our services, even if the destination jurisdiction may have less stringent data protection laws than your jurisdiction of residence.

We will take all reasonable steps to ensure that security measures are in place to protect your personal information in accordance with the applicable laws of your jurisdiction, and to ensure the security of your personal data during the transfer process.

9. Safeguard Measures

While there is an inherent risk when data is shared over the internet, we have implemented appropriate security measures to safeguard your personal data from being accidentally lost, misused, damaged, unauthorized access, altered, or disclosed in an unlawful manner. Additionally, we limit access to personal data to employees, agents, contractors, and other third parties who have a legitimate business need to know the information. These parties will only process your personal data based on our instructions and are subject to a duty of confidentiality.

To mitigate risks associated with the processing of your personal data, we have put in place the following security measures:

Organizational measures, including but not limited to:
- Staff training on data protection principles and secure data handling.
- Development of internal policies to ensure secure processing of personal data.
Technical measures, including but not limited to:
- Physical protection of data (e.g., secure access to server facilities).
- Pseudonymization and encryption of personal data to ensure data confidentiality and integrity.
Measures to ensure ongoing availability, integrity, and accessibilityof 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.

We also have procedures in place to address any suspected personal data breach. In the event of a breach, we will notify you and any relevant regulatory authorities as required by law. GDPR Article 33 mandates that a breach be reported within 72 hours if there is a risk to the rights and freedoms of individuals.

10. Our identification tools

To perform identity verification, OrangeX.com uses an in-house solution to collect and process necessary identification data. This process involves capturing photo images or video recordings of your face and ID document through a secure web or mobile interface. The collected data is used to comply with legal obligations, such as those under the Law on Prevention of Money Laundering and Terrorist Financing of the Saint Vincent, and for purposes of fraud and crime prevention, as well as risk management.

The face comparison results (match or mismatch) are retained only for as long as necessary to complete the verification process and comply with anti-money laundering (AML) regulations. We ensure that your facial data is used solely for one-time verification and is not stored as a facial template. It is also impossible to regenerate the raw data from the retained information.

By using this in-house solution, we verify that the individual in the ID document matches the person captured in the photo or video, providing a precise and efficient identity verification process.

If you prefer an alternative identification method, please contact us at dpo@orangex.com.

11. Automated decision making

In certain cases, the Company may implement automated decision-making processes, where decisions are made solely through automated data processing, without human intervention. This may include the use of software algorithms for tasks such as:

Verifying user identities;
Detecting fraudulent activities;
Assessing trading risks, and other necessary activities;

While automated decision-making helps us efficiently manage certain aspects of our services, we recognize the importance of fairness. If you believe that an automated decision has been inaccurate or unfair, you have the right to request a manual review of the decision. This right is in line with GDPR Article 22, which provides data subjects with the right to contest automated decisions that affect them.

For more information about your rights regarding your personal data, please refer to the section titled Your Rights Regarding Your Personal Data. 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 Saint Vincent 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:

as long as your consent remains in force, if there are no other legal requirements which shall be fulfilled with regard to the personal data processing. We reserve the right to retain records of any consent given and withdrawn for a period of time necessary to protect our rights;
in case of the conclusion and execution of 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;
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 Saint Vincent. The retention period may be extended for a period not exceeding 2 (two) years, provided there is a reasoned request from a competent authority;
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.

We may retain your personal data for a longer period when:

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.

Upon expiration of the retention period, we will delete and/or reliably and irrevocably depersonalize your data as soon as possible, within a reasonable time required to perform such action.

13. Transfer of Personal Data outside the EEA

European Union (EU) data protection rules apply to the European Economic Area (EEA) which includes all the EU countries and non-EU countries: Iceland, Liechtenstein and Norway. If necessary, the Company may transfer your personal data to a country outside the EEA, for storage and/or for processing by staff operating outside the EEA who work for the Company and/or to our suppliers, business partners, associates, affiliates, agents, business introducers or service providers who are engaged on our behalf to fulfil our contractual obligations under the Client Agreement. Moreover, personal data we collect from you may be stored or processed in a jurisdiction that is different to the country in which the specific entity of the group you are dealing with is registered and established. 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 Saint Vincent and European Union (EU) law. OrangeX.com 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 have provided explicit consent to the proposed transfer after being informed by OrangeX.com of the potential risks associated with such a transfer;
The transfer is necessary to fulfill a contract between you (the client) and OrangeX.com, 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 OrangeX.com 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 utilizes cookies to enhance user interaction on its Website. These small data files are sent from our Website and stored in your browser, allowing us to gather information about how you use our services. By collecting this data, we aim to tailor our offerings and provide a more personalized experience according to your preferences. Cookies contain a unique identifier but do not grant us access to your computer or any sensitive information beyond what you voluntarily share.

While cookies are employed across our Website, none of the data stored in them is linked to personal information you provide. You have the ability to manage cookie acceptance via your browser’s settings. Please note, however, that disabling cookies may limit your access to certain parts of the Website or affect the functionality of your customer account. We recommend reviewing our Cookies Policy to better understand how we use these files and other web tracking technologies.

Additionally, some of the Company’s partners, associates, and affiliates may also utilize cookies on the Website. As we do not have control over these third-party cookies, we cannot be held responsible for any loss or misuse of personal data that may occur as a result. If you visit external sites linked through our Website, this Policy does not cover them, so we advise reviewing their respective privacy policies to understand how your data is handled.

15. Your Rights regarding your Personal Data

In accordance with GDPR and Saint Vincent regulatory requirements, you have the following rights regarding the personal data we collect and process:

Right to Access
You have the right to request access to the personal data we hold about you. This includes the right to know what personal data we process, the purposes of processing, and how long we retain your data. Upon request, we will provide a copy of your personal data free of charge, unless the request is excessive or unjustified.
Right to Rectification
If you believe that the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update your data. 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@orangex.com. We will update your data accordingly. Please note that we may require evidence to support these updates.
Right to Erasure (Right to be Forgotten)
You may request the deletion of your personal data when it is no longer necessary for us to process it. 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). Deleting your personal data will result in the closure of your account.
Right to Information on Use and Processing
You have the right to know how your data is being used and for what purposes it is being processed. You can request a copy of your personal data and further details regarding how and why we process it.
Right to Restrict Processing
You have the right to request the restriction of processing in certain situations, such as:
- Disputing the accuracy of the data (processing restriction applies while we verify the accuracy).
- If the processing is unlawful, but you prefer restriction over deletion.
- If we no longer require the data, but you need it to establish, exercise, or defend legal claims.
- If you object to processing based on our legitimate interests, while we assess whether our interests override yours.
Right to Data Portability
You have the right to request that we transfer your personal data to you or to another data controller in a structured, commonly used, and machine-readable format. After the transfer, we are no longer responsible for the use of your data by the third party.
Right to Withdraw Consent
You may withdraw your consent to data processing at any time by contacting our Data Protection Officer (DPO) at dpo@orangex.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 File a Complaint
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 Saint Vincent 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 responsible for the use, misuse, or loss of personal data that may occur on external websites linked from the Company’s Website. Please note that the Company does not have control over, nor access to, the information provided to or collected by such third-party websites. 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 unauthorized access to your account or personal data due to actions or omissions on your part or those of individuals you have authorized.

17. Consent

The collection, use, and storage of your personal data by the Company are carried out based on your explicit consent. By entering into an agreement with the Company, creating a customer account, and using the Website, trading platforms, or payment gateways, you acknowledge and consent to the collection, use, and processing of your personal data as outlined in this Privacy Policy.

In addition, by downloading the Company’s platforms or accepting cookie settings in your web browser, you further consent to the terms of this Policy, including the use of cookies for relevant purposes. You can manage your cookie preferences through your browser settings or the provided cookie management tools on the Website.

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@orangex.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@orangex.com

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.

Earning User Agreement

Last updated: July 7, 2025

1. Overview

1.1 The OrangeX.com Earning Service (“OrangeX.com Earning” or the “Service”) is provided to you (“You” or the “Customer”) by the OrangeX.com entity applicable to you (“OrangeX.com” or “We”) in accordance with the OrangeX.com Terms of Service, the entirety of which is incorporated herein by reference. This Service is offered as a value-added service to OrangeX.com users, enabling them to earn returns by depositing digital assets on the OrangeX.com platform for either fixed or flexible terms.

1.2 This OrangeX.com Earning User Agreement (“this Agreement” or these “Terms”) governs your use of the Service and the related services entered into between you and OrangeX.com. To use the Service, you must carefully read and comply with this Agreement. By using the Service, you acknowledge that you have read and accepted all the terms herein. Your use of the Service constitutes your reading, understanding, and agreement to this Agreement, which is legally binding upon you.

1.3 In the event of any conflict or inconsistency between the terms or provisions set forth in this Agreement and the OrangeX.com Terms of Service, such conflict or inconsistency shall be resolved in favor of this Agreement. All provisions (including definitions) of the OrangeX.com Terms of Service not modified by this Agreement shall remain in full force and effect. Any terms not defined herein shall have the meanings ascribed to them in the OrangeX.com Terms of Service.

2. General Provisions

2.1 This Service allows OrangeX.com users to deposit their digital assets on the OrangeX.com platform for either fixed or flexible terms, enabling them to earn returns. Subject to the terms and conditions of this Agreement, the OrangeX.com platform supports subscriptions and redemptions 24/7.

2.2 Definitions related to this Service include:

API: OrangeX.com’s risk reserve primarily consists of funds provided by OrangeX.com and liquidation surpluses from settled orders, aimed at protecting users from losses in the event of significant and sudden market fluctuations.
Principal: A certain amount of digital assets deposited from a user’s spot account for the use of this Service.
Redemption: The (full or partial) withdrawal of assets from this Service.
Returns:The interest, earnings, and/or rewards that users may receive by depositing their digital assets into the Service.
Subscription: The act of subscribing to this Service, thereby depositing digital assets into the Service. Users may subscribe manually via the OrangeX.com Earning product page on the OrangeX.com platform.
T Hour: The time (based on UTC+0) at which a user’s subscription order is placed during a normal trading day, used for calculating daily returns.
Flexible Term Product: A non-fixed duration earning product where users can subscribe and redeem at any time, with returns calculated hourly based on a floating Annual Percentage Rate (APR).

3. Eligibility to Use the Service

3.1 You agree that OrangeX.com may hold your digital assets during the term of the Service to fulfill its obligations under this Service.

3.2 You further acknowledge and confirm that:

You have agreed to comply with the OrangeX.com Terms of Service and are eligible and permitted to use the services provided therein;
This Agreement is binding on you if you use the Service;
You possess the necessary experience and risk tolerance to use the Service, as well as the expertise and knowledge required to trade non-principal-guaranteed digital asset products;
You are capable of conducting operations on the internet;
This Agreement and your use of the Service do not conflict with the laws of your country or region, and you agree to comply with all applicable laws in your jurisdiction;
You are the legal and beneficial owner of all digital assets in your OrangeX.com account, and the source of your digital assets and fiat currency is not derived from illegal activities.

3.3 You further agree that:

You will not use the Service for any Prohibited Business (as defined in the OrangeX.com Terms of Service), including but not limited to illegal purposes such as money laundering, terrorist financing, fraud, or any other activity or business prohibited by law;
You will not use the Service for any form of price manipulation, insider trading, market manipulation, market distortion, or any other malicious market misconduct.

3.4 You understand and accept the risks associated with using the Service, as outlined in the OrangeX.com Terms of Service, as well as any related losses you may incur. Such risks and losses include, but are not limited to:

Any losses you may suffer due to the inability to immediately sell or exchange digital assets deposited into the Service for alternative assets, or losses incurred during such exchanges;
Your willingness to bear the risks and potential financial losses arising from depositing digital assets into the Service;
Historical returns do not guarantee future performance. The projected returns displayed on the OrangeX.com platform are estimates of theoretical gains and do not represent actual or guaranteed returns promised by OrangeX.com. OrangeX.com does not guarantee or promise any returns. Actual returns may differ from estimated or projected returns. For Flexible Term products, the APR is floating and may fluctuate hourly based on market conditions.
Returns shall be calculated and distributed at OrangeX.com’s sole discretion. OrangeX.com may deduct costs, fees, and expenses related to the operation of the Service from your actual returns to determine the final amount payable to you;
The volatile nature of digital assets and their derivatives may lead to significant or total losses within short periods;
The inherent characteristics of digital assets mean that technical difficulties encountered by OrangeX.com may prevent users from accessing or using their digital assets;
Market risks may arise, potentially resulting in losses of your digital assets;
OrangeX.com may, from time to time, add, remove, or modify its terms or policies, including the terms of this Agreement, during your use of the Service. Any such actions may affect users like you favorably or unfavorably.

4. Using the Service

4.1 Through the OrangeX.com platform, you may subscribe to and redeem products under this Service.

4.2 When you subscribe to the Service, your digital assets will be deposited into the Service. Once deposited, you will not be able to access, trade, sell, exchange, or otherwise use these assets.

4.3 Redemption Rules:

For Fixed Term Products: You may redeem your order at any time to withdraw your digital assets from the Service. For orders redeemed before maturity, no interest will be earned, and any accrued interest will be deducted—only the principal will be redeemed. The principal from early redemption will be unlocked immediately.
For Flexible Term Products: You may redeem Flexible Term products at any time. The redeemed principal and any yield accrued up to the time of redemption will be distributed immediately to your account. However, no yield is generated on the redeemed assets for the hour in which the redemption takes place. The remaining unredeemed assets will continue to accrue interest normally.

4.4 Upon maturity of a fixed-term product, the principal will be automatically redeemed, and interest will be distributed.

4.5 When manually placing a OrangeX.com Earning subscription order via the OrangeX.com platform, you must select:

(i) the type of digital asset;
(ii) the quantity of digital assets; and
(iii) the fixed term or flexible term and corresponding expected return rate (expressed as an annualized percentage rate or APR).

4.6 For financial products delisted by the platform in advance, we will automatically redeem your principal and distribute the interest accrued up to the delisting time.

4.7 Interest Calculation and Distribution:

For Fixed Term Products: The platform takes a daily snapshot at UTC+0 00:00. Interest begins accruing from the second snapshot point after the user’s subscription (calculated as: principal × estimated annual rate / 365). Upon maturity of the subscribed financial product, the system will automatically distribute the interest to your spot account.
For Flexible Term Products: Yield begins accruing from the next full hour after a successful subscription. The hourly yield is calculated based on the effective investment amount and the floating APR (including any applicable Tiered APR) at that specific hour. The total accrued yield for the previous day is distributed daily to your account at a specified time (e.g., UTC 00:30).

4.8 Users can view daily interest accrual records in the “My holdings” or “order history” on the Earning page.

4.9 Users may only participate in “Earning” subscriptions from their main account and must complete either individual KYC or corporate KYC verification.

4.10 OrangeX.com reserves the right, at its sole discretion, to introduce, impose, adjust, or remove any subscription and redemption restrictions while you use the Service.

5. Suspension/Cancellation/Termination

OrangeX.com may, at its sole discretion, suspend, cancel or terminate this Service or your use of the Service at any time.

The OrangeX.com Terms of Service specify circumstances under which OrangeX.com may suspend, cancel or terminate this Service. Without prejudice to the generality of the foregoing, such circumstances may include:

Your failure to provide additional information required by OrangeX.com to verify your identity or source of funds;
OrangeX.com’s compliance with court orders or applicable laws and regulations;
OrangeX.com’s adherence to directives or orders from government departments or agencies;
OrangeX.com reasonably determining that any information you provided is false, inaccurate, outdated or incomplete; or
Your failure to promptly provide additional information as requested or to provide such information to our reasonable satisfaction.

6. Liability

6.1 The OrangeX.com Terms of Service specify circumstances where you may incur losses or liabilities and where OrangeX.com shall not be held liable. Without limiting such provisions, these circumstances include:

Inability to use the Service, issue instructions or execute transactions due to malfunctions, delays, interruptions, system unresponsiveness, delayed system responses, lack or reduction of liquidity in the Service, or other abnormal conditions;
Service suspension due to maintenance;
Failure to transmit data;
Force majeure events or accidents such as typhoons, earthquakes, tsunamis, floods, plagues, power outages, wars, riots, government actions, terrorist attacks, epidemics, or similar occurrences;
Service interruption or delay caused by hacking, computer viruses, technical adjustments or failures, website upgrades, banking issues, temporary closures due to government regulations, or similar events;
Losses caused by technical problems unforeseeable or unsolvable with current technological capabilities;
Losses caused by third parties;

Losses resulting from changes in applicable laws and regulations or government, regulatory or law enforcement orders.

You agree and acknowledge that the above or any other reasons may lead to abnormal transactions, unusual market and price fluctuations, market disruptions, and other potential abnormal situations.

6.2 OrangeX.com reserves the right and discretion to refuse to execute or cancel your instructions.

6.3 You agree and acknowledge that OrangeX.com shall not be liable for any losses (including but not limited to direct or indirect losses, actual losses or loss of potential profits) arising from risks described in this Agreement or the OrangeX.com Terms of Service.

7. Technical Disclaimer

7.1 OrangeX.com may periodically suspend your access to the OrangeX.com account, OrangeX.com platform, this Service, and/or any other OrangeX.com services for scheduled or emergency maintenance. While OrangeX.com will make reasonable efforts to ensure timely processing of transactions on the OrangeX.com platform, no representations or warranties are made regarding the duration required to complete such maintenance.

7.2 Notwithstanding OrangeX.com’s reasonable efforts to update information on the OrangeX.com platform, no express or implied representations, warranties, or guarantees are made regarding the accuracy, completeness, or timeliness of content (including information related to the Service and any other OrangeX.com services) displayed on the OrangeX.com platform.

7.3 You shall be solely responsible for obtaining the necessary data network access to use this Service or any other OrangeX.com services. You are responsible for acquiring and maintaining compatible hardware or devices required to access the Service, any OrangeX.com services, the OrangeX.com platform, and any updates thereto. OrangeX.com does not guarantee that any OrangeX.com service or portion thereof will function on any specific hardware or device. Service interruptions and delays may occur due to internet and electronic communication factors.

7.4 While we implement measures to safeguard your data and transactions, we cannot completely eliminate risks of unauthorized access, hacking, data loss, or other security breaches. You acknowledge and agree to assume all risks associated with unauthorized access to your account information and any loss of digital assets resulting from such security incidents.

7.5 The digital asset sector is rapidly evolving, and technological advancements may necessitate adjustments to this Service or your interaction methods with the OrangeX.com platform. OrangeX.com reserves the right to modify the employed technologies, provided functionalities, or Service requirements in response to technological progress or regulatory changes without prior notice.

8. Enforcement Measures

You agree and acknowledge that OrangeX.com strictly prohibits unfair trading practices. Should you engage in any of the following activities, OrangeX.com reserves the right, at its sole discretion, to impose controls, restrict, suspend, or terminate your account:

Participation in market manipulation, price manipulation, insider trading, market distortion, or any other malicious unlawful or improper conduct;
Engagement in activities deemed harmful to market integrity by OrangeX.com;
Violation of any applicable laws or regulations.

To mitigate any adverse impact on overall market health, OrangeX.com retains the discretionary right to suspend/terminate your account or Service access, or reject/cancel your instructions. OrangeX.com shall bear no liability for any resultant losses (including but not limited to direct/indirect losses, actual damages, or lost profits) arising from such enforcement actions.

9. Compensation Liability

9.1 You shall take all possible measures to protect OrangeX.com from any damages arising from your use of this service or any other actions related to your OrangeX.com account.

9.2 You hereby acknowledge and agree that you shall indemnify, hold harmless, and defend OrangeX.com and its affiliates and partners (including us and their respective agents, if any, as well as the shareholders, directors, officers, and employees of OrangeX.com and its affiliates and partners) (collectively referred to as “Indemnified Parties”) from any claims, losses, liabilities, damages, judgments, penalties, fines, costs, and expenses (including but not limited to reasonable attorney fees and court costs) arising from or related to your breach of this Agreement, your use of the Service, or your violation of any applicable laws, regulations, or third-party rights.

10. Miscellaneous

10.1 The content of this agreement also includes any system specifications, guidelines, product documentation, or other related documents that OrangeX.com may publish from time to time. Such content shall become an integral part of this agreement upon publication, and you shall comply with the relevant provisions. In the event of any conflict between the above content and this agreement, this agreement shall prevail.

10.2 OrangeX.com reserves the right to unilaterally change this agreement or any terms applicable to the use of this service at its sole discretion. Such changes may occur at any time, and OrangeX.com is not required to provide prior notice, including during your use of this service. If OrangeX.com makes changes, the updated content shall be promptly published on the OrangeX.com website. Please refer to the latest information published on the website for any changes. Your continued use or access to this service after the changes are published indicates your acceptance of such changes. If you do not accept the revised content, you should stop using this service.

10.3 You should carefully read this agreement and any documents mentioned in Sections 10.1 and 10.2 that constitute the content of this agreement, as well as the OrangeX.com Terms of Service. In the event of any discrepancies between the English version of this agreement and any translated version, the English version shall prevail.

10.4 If any provision of this agreement is found to be invalid, illegal, or unenforceable, the validity, legality, and enforceability of the remaining provisions of this agreement shall not be affected or impaired in any way. However, if any provision of this agreement is invalid, illegal, or unenforceable under the applicable laws of any jurisdiction, such provision shall be deemed modified to the minimum extent necessary to comply with such laws, or if for any reason such provision is not deemed modified, it shall be invalid, illegal, or unenforceable only to the extent of such invalidity, illegality, or unenforceability, without affecting the validity, legality, or enforceability of the remaining provisions of this agreement or such provisions in any other jurisdiction.

10.5 The failure or delay of OrangeX.com to exercise any rights or provisions under this agreement shall not be construed as a waiver of such rights or provisions.

10.6 The final interpretation of this agreement shall be vested in OrangeX.com.

DEFINITIONS

We or the Company	OrangeX.com LLC
You	means the individual accessing or using the Website, or a company, or any legal entity on behalf of which such individual is accessing or using the Website, as applicable.
Cookies	refers to small data files that are placed on your computer or mobile device when you visit the Orangex.com Website.
Website	refers to https://www.orangex.com/.
Policy	means this cookie policy.

1. Purpose and Scope

This policy outlines our use of cookies and related technologies to identify visitors to our website, the types of information collected through these tools, and the purposes for which this information is utilized.

2. What are Cookies?

Cookies and similar technologies are small text files created by websites and stored by your browser as you browse the internet. Our website also employs cookies, along with other related technologies such as web beacons, tags, scripts, pixels, and local storage (collectively referred to as "cookies" for simplicity). These tools help the website identify your device during subsequent visits and analyze your online preferences and behavior.

3. What information do Cookies collect?

Cookies primarily gather data related to your preferences, interests, and online behaviors. This information may be collected in various contexts, including but not limited to: browsing and navigating our website, using our services or products, reaching out to us through the website, applying to become a customer or partner, or logging in through the customer portal.

4. What type of Cookies we use?

Cookies can be categorized based on their source and purpose. On our website, we utilize both first-party and third-party cookies:

First-party cookies are set directly by our website and can only be accessed by us.
Third-party cookies are implemented through external services integrated into our website, allowing third parties to store and manage cookies on our behalf.

Cookies can also differ based on their duration:

Session cookies are temporary and remain on your device only while you actively browse our website. These cookies are automatically deleted once you close your browser or leave the website.
Persistent cookies stay on your device for a predefined period, as determined by the specific cookie's lifespan or your browser settings. These remain active until they expire or are manually deleted by you.

We use the following categories of cookies to enhance your experience on our website:

Essential Cookies
These cookies are crucial for the basic functionality of our website. They enable core features such as security, network management, and accessibility. Without these cookies, the website cannot function properly. Although you can block or delete these cookies through your browser settings, doing so may impact the site's performance and access to essential features.
Functional Cookies
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Analytics Cookies
Analytics cookies help us monitor website performance, track visitor behavior, and analyze usage trends. This data allows us to improve our services, optimize the website's functionality, and ensure a seamless user experience. For instance, we use tools like Google Analytics to gather anonymized data on website traffic and visitor interactions.

Each type of cookie plays a distinct role in maintaining the usability and quality of our website while aligning with industry standards.

5. Cookies used on our Website

Below is a summary of the types of cookies currently utilized on our website. Please note that while we strive to keep this information up to date, the number, type, and specific names of cookies may vary over time as we enhance or modify our website.

Name	Provider	Category	Purpose	Duration	Type
setup_color	http://orangex.com	Functional cookie	Custom color configuration	Long-term	http
o_x_user_lang	http://orangex.com	Essential cookie	User-selected language	Long-term	http
o_x_token	http://orangex.com	essential cookie	Login credentials	Long-term	http
o_x_theme	http://orangex.com	Functional cookie	Default theme	Long-term	http
o_x_il	http://orangex.com	essential cookie	Is logged in	Long-term	http
g_state	http://orangex.com	essential cookie	Google One-Tap	Long-term	http
_ga, _ga_xxxxxxx	http://orangex.com	Analytics cookie	Google Analytics	Long-term	http
__zlcmid	http://orangex.com	Essential cookie	Zendesk	Long-term	http
o_x_wv	http://orangex.com	essential cookie	Enter the transit page	Long-term	http
o_x_d_t	http://orangex.com	essential cookie	Device type	Long-term	http
o_x_incorrect_symbol	http://orangex.com	essential cookie	Current trading pair	Long-term	http
_ho_xxxx__	http://orangex.com	functional cookie	Hide other trades on the page	Long-term	http
o_x_xxxxx_select	http://orangex.com	functional cookie	Last viewed trading pairs on each page	Long-term	http

6. Third party website Cookies

Our website may display links to sites used by external service providers such as 'X', 'Telegram', 'LinkedIn', 'Medium'. These third-party cookie policies will apply when you view the content by clicking the button or link provided. You can find more information about the cookie policies of these third parties here:

https://help.twitter.com/en/rules-and-policies/x-cookies

https://telegram.org/privacy?setln=en

https://www.linkedin.com/legal/privacy-policy

https://policy.medium.com/medium-privacy-policy-f03bf92035c9

Our Website may contain links to other third party websites. We do not control how cookies are placed on third party websites, even if you are directed to them from our Website. If clicking on a link from our Website takes you to other websites, it is advised to pay special attention to the cookies the third parties use.

The cookies used on our Website may transfer the collected data to third countries. To find out how we handle your data and on what basis we may transfer your data, we suggest you read our Privacy Policy.

7. Blocking and rejecting Cookies

There are several ways how you can manage cookies:

You can find "cookies" on the footer of our website. You can manage your preferences anytime you want.

8. Cookie settings in our Website.

In order to control the cookies we use, you can select the cookie settings in the notification line before browsing our Website.

In the notification line, you can manage all cookies stored on our Website, with the exception of necessary cookies.

9. Your browser settings

Majority of browsers allow users to change the used cookies settings. In order to help you understand how to use these settings, the following links may be helpful. you can use the help feature in your browser for more information:

1. Cookie settings in 'Microsoft Edge' browser -https://support.microsoft.com/en-us/microsoft-edge/view-cookies-in-microsoft-edge-a7d95376-f2cd-8e4a-25dc-1de753474879;

2. Cookie settings in 'Firefox' browser -https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectlocale=en-US&redirectslug=enable-and-disable-cookies-website-preferences;

3. Cookie settings in 'Chrome' browser -https://support.google.com/chrome/answer/95647?hl=en;

4. Cookie settings in 'Safari' browser -https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac;

If you delete your cookies, all settings controlled by these cookies will be deleted and you will need to re-create them when you visit our Website later. Without necessary cookies, our Website may not function properly.

10. How can you reach us?

If you have any questions, comments, or requests regarding the information outlined in this Policy, please feel free to reach out to us via email at support@orangex.com.

11. Policy Updates

We continuously strive to improve and refine our services, which may result in periodic updates to this Policy. The most recent and up-to-date version of the Policy will always be available on our website.