Privacy Policy

Effective Date: 4th October 2023

Orblex Technologies and its affiliates (collectively, "Orblex") respect your privacy. At Orblex, we are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal data in accordance with global data regulations, including the GDPR and CCPA. This Privacy policy outlines our practices concerning collecting, utilizing, and protecting Personal data. We gather various types of Personal Data, and this notice elucidates the reasons behind such data collection, the entities we may share it with, and the stringent measures we implement to uphold data security. Additionally, it clarifies your rights and choices regarding your Personal data and how to reach out to us for inquiries concerning our privacy procedures.

We act as representatives for and adhere to the directives of financial institutions, merchants, and other partners who function as data controllers. For comprehensive information about how your Personal data is processed in these circumstances, we recommend referring to their respective privacy policies. Our approach to privacy may differ across the various countries in which we operate, aligning with local norms and legal obligations. Specific privacy notices may apply to certain products and services we offer. To better understand our privacy and information practices pertaining to a particular product or service, we encourage you to visit the dedicated webpage or associated digital asset.

Information of a Personal Nature That We Might Gather

Any data associated with an individual, whether identified or identifiable, is called "Personal Data." We could potentially gather the following categories of Personal Data:

• Product and Service Data: This covers registration information and program-specific data when you directly request our products or services or participate in marketing programs or any affiliated service programs.
• Data from Partners: We may receive data from trusted partners and service providers. This information may include, but is not limited to, your name, contact details, and demographic data.
• Online Activity Data: Information about your website, device, and mobile app usage is collected through automated means like cookies and similar technologies.
• Employment Application Data: If you apply for a job with us, we may collect information related to your job application and relevant details.
• Business Contact Data: If you represent one of our business partners, we may gather your business contact information.

Personal data that we receive from our Partners

In compliance with applicable data protection regulations, we may obtain specific personal data from our trusted partners, such as third-party service providers, advertisers, business affiliates, or publicly available records, which may include, but are not limited to, your name, contact details, and demographic data. This data is received to facilitate secure data exchange with customers, with utmost care and confidentiality, ensuring it is utilized to enhance services, provide targeted content, prevent fraud, verify identities, improve user experience, and for advertising purposes to improve overall user experience. Our partners and ourselves adhere to this Privacy Policy and comply with relevant data protection laws. The shared data is used exclusively for legitimate business purposes if the law requires us to act as data controllers/processors on behalf of our partners or customers to process your personal data.

Personal data we obtain from Advertisements, Websites, and Applications

When you interact with advertisements, websites, or applications affiliated with our services, we may collect personal data about you. This information can include your device type, IP address, browser settings, and the pages or content you view. We use various tracking technologies, such as cookies and web beacons, to gather this data. This information helps us understand how you engage with our online ecosystem and allows us to provide you with a more personalized experience. It also assists us in measuring the effectiveness of our advertising campaigns and improving the quality of our services. Rest assured, we handle this data in compliance with relevant privacy laws and regulations, and it is used solely for the purposes outlined in this Privacy Policy.

Additionally, when you interact with third-party websites, apps, or services that are integrated with ours or feature our content, those third parties may share your data with us. This shared information could include your interactions, preferences, and actions within their platforms. We treat this information with the same care and respect as any data we collect directly. It enables us to offer you a seamless and consistent experience across different digital environments while maintaining high privacy protection. We encourage you to review the privacy policies of these third-party platforms to understand how your data may be used beyond our services.

Personal data we obtain through Job applications

When you apply for a job with our organization, we may collect a range of personal data as part of the application and recruitment process. This information typically includes your name, contact details, resume or curriculum vitae, cover letter, employment history, educational background, and any other information you provide as part of your application. We may also collect information such as references, background checks, and assessment results during recruitment to evaluate your suitability for the position you applied for. This data is collected and processed solely to assess your qualifications, contact you about the job application, and facilitate recruitment.

Additionally, as part of our commitment to equal opportunity and diversity, we may request demographic information, such as gender, race, or ethnicity, voluntarily. Providing this information is optional and will not impact your job application. We use this data for internal reporting and to help us ensure that our recruitment practices are fair and inclusive. Your data collected during the application process is treated with the utmost confidentiality and is accessible only to those involved in the recruitment and hiring process. If your application is unsuccessful, we may retain your information for a limited period for potential future opportunities unless you request its deletion. We comply with all applicable data protection laws and regulations in handling your data throughout the application and hiring process.

How We May Use Your Personal Data

At Orblex, we are committed to protecting your privacy and ensuring the responsible use of your personal data. This section of our Privacy Policy outlines the various ways in which we may use the personal data we collect from you:

• Providing and Improving Services: We may use your data to deliver, maintain, and enhance our products and services. It includes processing transactions, offering customer support, and troubleshooting issues.
• Personalization: Your data helps us personalize your experience by tailoring content, recommendations, and offers to your preferences and interests.
• Communication: We may use your contact information to communicate with you about updates, promotions, news, and essential information related to our products and services. You can opt out of these communications at any time.
• Analytics and Research: We analyze your personal data to understand user behavior, trends, and preferences. This data helps us improve our services, develop new features, and make informed business decisions.
• Security: Your personal data is crucial for the safety and integrity of our systems. We use it to detect and prevent fraud, unauthorized access, and other security breaches.
• Customer Support: Your data assists us in providing you with effective customer support, resolving issues, and answering your inquiries.
• Recruitment: If you apply for a job with us, your personal data will be used for the recruitment and hiring process.
• Marketing: With your consent, we may use your personal email information for marketing purposes, such as sending promotional emails or showing you targeted advertisements.
• Aggregated and Anonymous Data: We may aggregate and anonymize your personal data to create statistical or research data that cannot be used to identify you. This data may be used for various purposes, including industry analysis and reporting.
• Data Licensing: We may license your personal data to our customers for use in their services, including preventing fraud and identity verification services. Your data will be used responsibly and in accordance with applicable laws and regulations.

Following relevant legal requirements, we will utilize your Personal data with your explicit consent when it is essential for delivering products and services to you, when we are obligated to comply with legal mandates, or when a legitimate and paramount interest makes it necessary to employ such information.

We utilize the information we collect for the following purposes. The specific legal basis for processing your information may vary depending on your location and under applicable law, as detailed below.

How We Disclose Your Personal Data

At Orblex, your privacy and the security of your personal data are paramount to us. This section of our Privacy Policy outlines how we may share your data, ensuring transparency and clarity about the ways your data is handled. Please note that in the below cases, your data may be shared with us, or we may share this information with you. Please take a moment to review this information carefully.:

• We will share your data when you have provided explicit and voluntary consent for specific purposes. It might include sharing data with trusted third parties for marketing promotions or partner offers. You have the right to withdraw your consent at any time.
• To provide you with our services, we collaborate with trusted service providers who process your data on our behalf. These partners may include payment processors, delivery companies, or IT service providers. We select service providers who adhere to rigorous data protection standards.
• We may disclose your personal data when required by applicable laws, regulations, or legal processes. It includes sharing data with law enforcement agencies, government authorities, or regulatory bodies when necessary.
• We may share your data with our trusted business partners for joint marketing initiatives, collaborations, or co-branded services. These partnerships are designed to enhance your experience and provide you with valuable offers and opportunities.
• We may share your data with our trusted customers through licensing agreements, enabling them to use your data to enhance their services. These agreements strictly adhere to stringent data protection regulations.
• If a merger, acquisition, or any other type of corporate transaction involving Orblex, your personal data may be transferred as part of the business assets. Rest assured that your data will remain protected following any such transaction.
• We may share your personal data when it is necessary to protect our legal rights, property, or safety, as well as the rights, property, and safety of our customers, partners, and employees. It includes sharing information to prevent fraud or address security issues.
• We may share anonymized and aggregated data that cannot be used to identify individuals. This information is often used for research, analytics, and industry insights, benefiting our company and the broader community.

If you are located outside the country where Orblex is based, please note we may act as a data agent that participates in transferring your personal data internationally. We take appropriate measures to ensure that your data remains secure and protected in accordance with applicable data protection laws.

We want you to have control over your personal data. If you have questions or concerns about how we share your data, please get in touch with our privacy team using our "Contact Us" section.

Data Subject Rights

Orblex is dedicated to respecting your privacy and giving you choices and control over your personal data. Please take a moment to familiarize yourself with your rights and options:

• Data Access: You have the right to request access to the personal data we hold about you. It allows you to verify what data we have collected and how we use it.
• Data Correction: If you believe any personal data we hold about you is inaccurate or incomplete, you can request corrections or updates. We encourage you to keep your information accurate and up-to-date.
• Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format. It allows you to transfer your data to another organization if you wish.
• Data Restriction: Under certain circumstances, you can request the restriction of processing your personal data. This means we will temporarily suspend the use of your data while we investigate your request.
• Data Objection: You can object to processing your personal data for specific purposes, such as direct marketing. We will respect your request unless we have a legitimate reason to continue processing your data.
• Consent Withdrawal: If we rely on your consent to process your personal data, you can withdraw that consent at any time. It will not affect the lawfulness of processing based on consent before its withdrawal.
• Data Erasure: You have the right to request the deletion of your personal data. It includes instances where your data is no longer necessary for the purposes for which it was collected.
• Marketing Control: You can manage your marketing preferences and opt out of receiving promotional communications from us anytime. Instructions for unsubscribing are typically provided in marketing emails.
• Browsing Control: You can control cookies and tracking technologies through your browser settings or by using our website's cookie preference tools. Please review our Cookie Policy for more information.
• Do Not Track: Your web browser may offer a "Do Not Track" option. While our website respects these signals, we may still collect and use information for essential purposes.
• Privacy Concerns: If you believe your privacy rights have been violated or you have concerns about how your data is handled, don't hesitate to contact us using our "Contact Us" section. We take privacy complaints seriously and will investigate and address them accordingly.
• Right to Complaint: In accordance with your country or local regulations, you are entitled to file a complaint regarding utilizing your personal data with the appropriate supervisory authority or regulatory body.

Depending on your country and the applicable law, you or a party authorized to act on your behalf can exercise your rights or choices to control your personal data by submitting a request in our "Contact Us" or by writing to us at the following address:

Orblex Technologies
Legal Department
15 Yvonne Crt
London ON N5Z0A6

We will not refuse or impose varying charges if you decide to exercise these rights.

Time Limits for Responding to Data Protection Rights Requests: We are committed to respecting and protecting your data privacy rights. If you choose to exercise your data protection rights, including but not limited to the right to access, rectify, erase, or object to processing your personal data, please note that we will make every effort to respond to your request promptly. Following applicable data protection laws, our standard response time for addressing data protection rights requests is one calendar month from the date of receiving a valid request. However, in certain circumstances, this period may be extended in accordance with the law. If an extension is necessary, we will notify you within one month of receiving your request, explaining the reasons for the delay. Rest assured that we will handle all requests with the utmost diligence and in compliance with relevant data protection regulations.

Transferring Data

Orblex is a global data expert and consultant. As part of our services, we may need to transfer your data to various locations, customers, or third parties. Data protection laws vary for every country and may differ from the country from which you initially provided the information. In accordance with this Privacy policy, we comply with the applicable legal requirements when transferring Personal data to other countries. This section of our Privacy policy explains how we share your personal data and the steps we take to ensure the security of these transfers.

1. International Data Transfers: Your data may be transferred, processed, or stored in countries outside the European Economic Area (EEA), the United States, or your home jurisdiction, where different data protection laws may apply. We take every measure to ensure your data remains secure and protected, regardless of the destination.

2. Legal Bases for Data Transfers: We commit to transferring your data only when there's a valid legal basis and legitimate purpose. These may include:

• Consent: Your explicit consent for the data transfer.
• Contractual Necessity: When the transfer is essential for fulfilling a contract.
• Legal Compliance: Transfers must meet legal obligations or respond to lawful government requests.
• Legitimate Interests: Transfers that serve our legitimate interests, provided they do not infringe on your rights and freedoms.

3. Safeguarding Your Data During Transfers: To protect your data during international transfers, we employ robust security measures such as:

Data Security: We Implement technical and organizational safeguards to prevent unauthorized access, disclosure, alteration, or destruction of your data.

Data Transfer Mechanisms: We Utilize GDPR-approved mechanisms, like Standard Contractual Clauses or other authorized methods, to safeguard data transfers.

Data Minimization: We only transfer the minimum amount of data required for the intended purpose.

Data Transfer Mechanism: To facilitate the lawful and secure transfer of your personal data to recipients in countries outside the European Economic Area (EEA) or other regions with data protection regulations, we may utilize specific data transfer mechanisms recognized by data protection authorities. These mechanisms include Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), or other legal mechanisms as required by the applicable data protection laws. These mechanisms safeguard your data and maintain the high standards of data protection to which we are committed.

4. Sharing Data with Third Parties: We may share your data with trusted third-party service providers, partners, or affiliates bound by contractual agreements to adhere to data protection standards in compliance with GDPR, CCPA, or relevant regulations.

5. Data Subject Rights: If your data is transferred internationally, you may have specific rights for protecting your personal data. To understand and exercise these rights, please contact us using the "Contact Us" page.

6. Changes to Data Transfer Practices: Our data transfer practices are subject to change due to evolving legal requirements or business operations. We will update this Privacy Policy accordingly. We recommend checking this section regularly for the latest information.

7. Data Protection Impact Assessment (DPIA): If required by the applicable data protection laws, we may ask the Data Processor to conduct a Data Protection Impact Assessment to evaluate and mitigate the potential risks associated with transferring your data.

At Orblex, we take data transfers seriously and are committed to upholding the privacy and security of your personal data in compliance with GDPR, CCPA, and applicable laws. If you have questions or concerns about our data transfer practices, please contact us from the "Contact Us" section. Your privacy is our priority, and we are dedicated to ensuring your data is handled carefully and in line with data protection regulations.

Safeguarding Your Personal Data

At Orblex, safeguarding your personal data is a top priority. We are committed to ensuring the security and confidentiality of the data you entrust. This section of our Privacy Policy explains the measures we have in place to protect your data effectively.

• We utilize advanced encryption technologies to secure your data during transmission. Any data exchanged between your device and our servers remains encrypted and unreadable to unauthorized parties. You can recognize secure connections by looking for "https" in your browser's website address and a padlock icon.
• Your data in our possession is maintained under strict controls. Our data storage systems are designed to protect against unauthorized access, data breaches, and other security threats. We regularly review and update our security protocols to stay ahead of emerging risks.
• Access to your data is restricted to authorized personnel who require this information to perform their job duties. We implement role-based access controls and conduct regular training to ensure that our employees understand the importance of data security and privacy.
• We conduct security audits and assessments of our systems and infrastructure to identify and rectify vulnerabilities promptly. This ongoing process helps us maintain high security and protect your personal data from potential threats.
• We are committed to complying with all relevant data protection laws and regulations. This includes adherence to the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA), if applicable. We thoroughly understand these laws and continuously update our practices to align with changing requirements.
• When we engage third-party service providers, partners, or vendors, we ensure they meet our stringent security and privacy standards. All such parties are contractually bound to uphold data protection requirements.
• Despite our best efforts, no system is entirely immune to potential security incidents. In the unlikely event of a data breach or security compromise, we have a well-defined incident response plan in place. We will promptly investigate and take appropriate action to mitigate any impact on your data.
• We encourage you to use strong, unique passwords for your accounts, regularly update your login credentials, and be cautious of phishing attempts and suspicious emails. If you ever suspect any unauthorized activity related to your account, please report it to us immediately.

For how long your data is retained

Orblex or its affiliates ("we") may retain the personal data we collect or supply where we have an ongoing legitimate business need to do so. In certain circumstances, we may need to keep your information for legal reasons after our contractual relationship has ended, for example, situations where we are made subject to a legal obligation, where we require access to your information to effectively resolve requests or complaints, as evidence to compliance laws, in connection to litigation or regulatory matters or conclusion of your recruitment process. Once there is no valid business necessity or legal requirement for retaining your data, we will delete or anonymize it. In cases where deletion or anonymization is not immediately feasible, the data is securely archived and isolated from any further processing until deletion becomes viable. Archived data will have a maximum retention period of 8 years. Detailed retention schedules are provided in the below table for reference.

Privacy Policy Review and Updates

This policy will undergo an annual review to ensure that it reflects any changes in our privacy practices. Additionally, periodic revisions may occur as needed to incorporate any alterations.

How to Contact Us

You may submit a request to exercise your rights to your Personal Data on our "Contact Us" page or by emailing us at [email protected]. If you have any questions, comments, or complaints about our privacy practices, please email us at [email protected] or write to us at:

Orblex Technologies
Legal Department
15 Yvonne Crt
London ON N5Z0A6