2. Collection and use of data
2.1 Data submitted
We collect and may use information such as:
- your account information (the “Account Information”), which includes without limitation: name, address, phone number(s), email address, username, photograph, IP address, account number(s), account types, government-issued identification number(s), date of birth, physical address, source of funds, statements and reports, currency and other account preferences;
- Communications between you and us for customer service and/or other purposes (e.g., by emails, faxes, phone calls, tweets, etc.);
- the emails and phone numbers of your contacts, if you choose to invite them to use one or more of the OuroX Services as part of a referral program (unless your contact opts to unsubscribe from our commercial mailing list(s));
- data generated by or about transactions you complete using OuroX Services, including information related to the value, volume, nature and other details of a transaction;
- the unique identification number associated with your mobile device used to access any of our mobile applications. For iOS users, we also collect the Apple-recommended CFUUID (the Core Foundation Universally Unique Identifier)); and
- Other commercial and/or identification information required in order for us to comply with our anti-money laundering obligations under applicable law.
2.2 Data generated and other data
We also automatically collect and may use the following data:
- Analytics: When you visit our website, we use third party analysis tools to collect data about your computer and internet connection. That information includes the IP address of your computer and/or internet service provider, when you access our website, the internet address of websites from which you link to our website and from which you came before landing on our website, the browser that you are using, and your navigation and preferences on our website. All of this information is used internally for the purpose of understanding how our website is being used and improving our website. We also use third party analysis tools to collect data about your use of our mobile applications. The information collected identifies the nature and timing of the actions you take within our mobile applications, including installation, registration, uploading, and certain types of navigation. All of this information is used internally for the purpose of understanding how our mobile applications are being used and to facilitate the improvement of said mobile applications.
- Action Tags: When you visit our website, we use action tags (also called pixel tags, clear GIF or beacons) to identify some of the pages that you visit and how you use the content on those pages. Action tags may collect and transmit this data in a manner that identifies you if you have registered with our website or are logged into our website. We also use action tags in our emails to determine whether an email was opened or whether it was forwarded to someone else. When you use our mobile apps, we use action tags where you are accessing websites from links in our mobile apps. These may identify the pages that you visit and how you use the content on those pages.
- Site Management: We aggregate data that we collect about the use of our website for administration purposes, to protect and improve our website and our systems, to better understand the preferences of our website visitors and optimize the content that we serve, to identify server problems, to compile aggregated statistics about our website usage, and to improve our marketing and research.
3. Data protection and security
3.1 Data protection
OuroX is committed to observing high standards of information security. We use computer safeguards such as firewalls and data encryption, enforce physical access controls to our buildings and files, and authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
While we use reasonable physical, electronic and procedural safeguards to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration and destruction, please be advised that we do not accept responsibility for the security of any data transmitted over the internet or information stored, posted or provided directly to a third party website, which is governed by that third party’s policies.
Further information on our security practices are outlined in our OuroX Security.
3.2 Password protection
Your ability to securely use OuroX Services also depends on your protection of your login credentials such as your product password. We strongly recommend that you do not share your password(s) with anyone. An authorized OuroX representative will never ask you for your password. Therefore, any email or other communication requesting your password or any similar information should be treated as unauthorized and suspicious. In the event that you receive such a communication, please promptly forward it to [email protected].
If you do share your password(s) with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you will generally be considered responsible for any and all actions taken using your password. If you believe that someone else has obtained access to your password, please change it immediately by logging in to your account and changing your profile settings. We also strongly recommend that you also contact us at [email protected] immediately.
3.3 Data retention
If you wish to permanently close an account associated with one or more OuroX Services, please let us know by submitting a request to [email protected]. We may retain information about you in our databases for as long as your account is active or as needed to provide OuroX Services to you. Additionally, our retention and use of your information will be in accordance with applicable law, including our legal obligations, interest in resolving any disputes, and the enforcement of of all relevant agreements. It is important to note that the retention period may extend beyond the end of your relationship with us, as required by law or as deemed necessary in our absolute discretion.
4. Data sharing and disclosure
Like most banks or financial/payment service providers, OuroX works with third-party service providers that offer important functions to us, which facilitate or support our OuroX Services in some way. We, therefore, disclose user data to such third-party service providers from time to time so that their services can be effectively performed.
OuroX may also share your information for the purposes of fraud prevention, risk management, customer service, legal compliance and the provision of our services, particularly in circumstances where:
- You have consented or otherwise given us permission to share said information;
- We have aggregated or de-identified the information, so that it cannot reasonably be used to identify you;
- It is required by a third party service providers who we use in delivering our service, including certain advertising, referral, operations, financial services and technology services (such as hosting providers, identity verification, support, payment, and email service providers);
- It is, or we reasonably believe it to be, required by applicable law or legal process;
- It becomes necessary in order to protect the rights, property and safety of OuroX, our users and the public, including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims; and
- It relates to the sale, merger, transfer, or reorganization of all or part(s) of our business.
5. Other websites, social media platforms and online services
Our OuroX Services may incorporate links to other websites, social media platforms or online services, whose privacy policies may differ from those of OuroX. Please be aware that if you submit information to any such website, social media platform or online service, your information is governed by their privacy policies, which should be read carefully prior to use. OuroX is not responsible for the practices or procedures of such third parties.
6. Notification of changes