Privacy Policy

Our Company

Orokii, Inc. (“Orokii”, “us”, “we”, “our”) is responsible for the collection, use, and disclosure of your personal information. If you have any questions about how we protect or use your data, please email us at privacy@orokii.com
1. Electronic Fund Transfers (“EFTs”) and Account Balances. Orokii partners with financial services software company Circle Internet Financial, Inc. to offer you electronic fund transfers (EFTs). When you create an Orokii Account, link a bank account, or initiate an ETF, you are authorizing us to share your identity and banking information with Circle to support your account. You are also agreeing to the terms of Circle’s USDC terms and privacy policy (the “Partner Terms”). It is your responsibility to make sure the data you provide us is accurate and complete, which is necessary for our partners to process EFTs on your behalf. The Partner Terms may be modified from time to time, and the governing versions are incorporated by reference into this Privacy Policy. Any term not defined in this section but defined in the Partner Terms assumes the meaning as defined in the Partner Terms. IT IS YOUR RESPONSIBILITY TO READ AND UNDERSTAND THE PARTNER TERMS BECAUSE THEY CONTAIN TERMS AND CONDITIONS CONCERNING YOUR OROKII ACCOUNT, INCLUDING BUT NOT LIMITED TO USE OF YOUR PERSONAL INFORMATION.
Data We Collect About You

We will collect the following data about you:
1. Information You Provided to Us.
  - You may give us information, including personal information, about yourself when you sign up to use our Services, e.g., your name and email address. It also includes information you provide through your continued use of our Services, participates in discussion boards or other social media functions on our Website or App, enters a competition, promotion, or survey, and when you report a problem with our Services. The information you give us may include your name, address, email address, phone number, financial information. Additionally, it may include credit card, debit card, or bank account information, payment reason, geographical location, social security number, personal description, and photograph.
  - We may also need additional commercial and/or identification information from you, e.g., if you send or receive certain high-value or high-volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.
  - In providing the personal data of any individual (other than yourself) that, for example, may receive payments from us as part of your use of our Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use, and disclosure of such personal data, for the purposes set out in this Privacy Policy.
2. Information We Collect About You. You. Regarding your use of our Services, we may automatically collect the following information, some of which may be or include personal information:
  - details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;
  - technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type, and version, time zone setting, browser plug-in types and versions, operating system, and platform;
  - information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through, and from our Website or App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.
3. Information We Receive from Other Sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties and may receive information about you from them. For example:
  - the banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;
  - business partners may provide us with your name and address, as well as financial information, such as card payment information;
  - advertising networks, analytics providers, and search information providers may provide us with pseudonymized information about you, such as confirming how you found our website;
  - credit reference agencies do not provide us with any personal information about yourself but may be used to corroborate the information you have provided to us.
4. Information from Social Media Networks. Suppose you log in to our Services using your social media account (for example, Facebook or Google). In that case, we will receive relevant information necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information you have provided to them, including your name, profile image, and email address. We use such information, together with any other information you directly provide to us when you register or use our Services, to create your account and communicate with you about the information, products, and services you request from us. You may also be able to specifically request that we have access to the contacts in your social media account so that you can send a referral link to your family and friends. We will use, disclose, and store all this information following this Privacy Policy.
5. Children’s Data. Our products and services are directed at adults 18 years old or older and not intended for children. We do not knowingly collect information from this age group. Part of the verification process prevents Orokii from collecting such data. If any information is collected from a child without verification of parental consent, it will be removed.
How We Protect Your Personal Information
1. We use a secure server to store your personal information. All information you provide to us is stored on our secure servers. Any payment transaction information will be encrypted using Transport Layer Security (TLS) technology.
2. It is important to note that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information during transmission, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorized access. We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your personal information.
How We Use Your Information
1. We Use Your Information in the Following Ways:
  - to carry out our obligations relating to your contract with us and to provide you with the information, products, and services;
  - to comply with any applicable legal and/or regulatory requirements including laws outside of your country of residence or to comply with any legal process;
  - to notify you about changes to our Services;
  - to customize our Services and the information we provide to you and address your needs – such as your country of address and transaction history. For example, if you frequently send funds from one specific currency to another, we may use this information to inform you of new product updates or features that may be useful for you;
  - as part of our efforts to keep our Services safe and secure;
  - to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  - to improve our Services and to ensure that they are presented most effectively;
  - to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
  - to allow you to participate in interactive features of our Services when you choose to do so;
  - to allow us to pursue available remedies or limit the damages that we may sustain and to enforce our terms and conditions
  - so that we can provide you with information regarding our public policy advocacy efforts.
  - to provide you with information about other similar goods and services we offer;
  - to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
  - to combine information we receive from other sources with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of Your Information
1. We May Share Your Information with Selected Third Parties Including:
  - affiliates, business partners, suppliers, and subcontractors for the performance and execution of any contract we enter with them or you;
  - advertisers and advertising networks solely to select and serve relevant adverts to you and others;
  - analytics and search engine providers that assist us in improving and optimizing our site.
  - If you are based in the US, Orokii may use Plaid, Inc. (“Plaid”) to connect your Orokii account with your bank account, verify your bank account and confirm your bank account balance prior to approving a transaction. Information shared with Plaid is treated by Plaid following its Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy.
2. We May Disclose Your Personal Information to Third Parties:
  - affiliates, business partners, suppliers, and subcontractors for the performance and execution of any contract we enter with them or you;
  - if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  - if we are under a duty to disclose or share your personal data to comply with any legal obligation, enforce or apply our Customer Agreement and other applicable agreements, or protect the rights, property, or safety of Orokii, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction;
  - to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
  - to prevent and detect fraud or crime;
  - in response to a subpoena, warrant, court order, or as otherwise required by law;
  - to assess financial and insurance risks, and to protect our operations and those of any of our affiliates;
  - to allow us to pursue available remedies or limit the damages that we may sustain
  - to recover a debt, or in relation to your insolvency; and
  - to develop customer relationships, services, and systems.
3. We do not have a published list of all the third parties we share your data with, as this would be heavily dependent on your specific use of our Services. However, if you would like further information about whom we have shared your data with or to be provided with a list specific to You, you can request this by writing to privacy@orokii.com
Sharing and Storing Your Personal Data
1. The data we collect from you may be transferred to and stored at a destination outside the United States. It may also be used by staff outside the US who work for one of our suppliers or us. Such staff may be engaged in, among other things, the fulfillment of your payment order, the processing of your payment details, and the provision of support services. By submitting your personal information, you agree to the transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and following this Privacy Policy.
Cookies
1. We use small files (known as cookies) to distinguish you from other users, see how you use our site and products while providing you with the best experience. It also enables us to improve our services; for detailed information on cookies and other technologies we use and the purposes for which we use them, see our Cookie Policy.
Retention of Your Information
1. Orokii is a regulated financial institution and therefore required by law to store some of your personal and transactional data beyond the closure of your account with us. See your rights below. Your data is only accessed internally on a need-to-know basis, and it will only be accessed or processed if necessary.
2. We will permanently delete data that is no longer required by relevant law or jurisdiction in which we operate.
3. Retention periods defined for the storage of your data can be found by clicking here.
California Privacy Rights

If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically:
- Exercising the Right to Know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
  - the categories and specific pieces of personal information we have collected about you;
  - the categories of sources from which we collected the personal information;
  - the business or commercial purpose for which we collected the personal information;
  - the categories of third parties with whom we shared the personal information; and
  - the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
- Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
- Exercising the right to opt-out from a sale. You may request to opt-out of any “sale” of your personal information that may take place.
- Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
  To submit a request to exercise any of the rights described above, you may contact Orokii either via email to privacy@orokii.com or contact us via postal mail, proper postage prepaid, at:
  Orokii
  Attn: Your California Privacy Rights
  56 Wellington Road
  East Brunswick, NJ 08816
Please indicate your preference for how you would like us to respond to your request (i.e., email or postal mail). All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. Please include your name, street address (if you would like a response via postal mail), city, state, and zip code for all requests. We may need to verify your identity before responding to your requests. The email address or contact information you send the request must match your email address or contact information on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly or incomplete information.
Third-party Links
1. From time to time, Our Services may contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that they have their own privacy policies and do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
Changes to Our Privacy Policy
1. To keep up with best practices, new legislation, and changes in how we collect and use personal information, we may modify this Privacy Policy from time to time. If we change this Privacy Policy, we will post the revised Privacy Policy on the website and update the “Last Updated” date. To stay up to date on any changes, please check back periodically. Following these changes, your use of our Services means that you accept the revised Privacy Policy. If you would like to review the version of the Privacy Policy that was effective immediately prior to this revision, please contact us at privacy@orokii.com
Contact
1. Questions, comments, and requests regarding this Privacy Policy are welcomed and should be addressed to our privacy team at the following email address: privacy@orokii.com or you can write to us at the following address:
  
  Orokii
  Attention: Legal and Compliance Team
  56 Wellington Road
  East Brunswick, NJ 08816