Privacy Policy
Ornn Compute Exchange ("Ornn," "we," "our," or "us") is committed to protecting the privacy and security of personal information collected from users of our website, trading platform, and related services (collectively, the "Services"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with applicable federal and state privacy laws, including the Gramm-Leach-Bliley Act (GLBA), the Commodity Futures Trading Commission (CFTC) privacy regulations under 17 C.F.R. Part 160, and other relevant data protection standards.
1. Information We Collect
We collect several categories of information to provide, maintain, and improve our Services:
Personal Identification Information
We collect personal identification details such as your full name, residential and business addresses, telephone numbers, email addresses, date of birth, Social Security number or taxpayer identification number, and government-issued identification documents required for account verification and regulatory compliance.
Financial Information
We collect financial data including bank account numbers, credit or debit card information, account balances, transaction history, trading activity, portfolio holdings, income levels, net worth, investment experience, risk tolerance, credit history, and related financial details necessary to facilitate trading, clearing, and settlement activities on our exchange.
Technical and Usage Information
We automatically collect technical data when you access our Services, including IP addresses, browser type and version, device identifiers, operating system, time zone settings, access times, pages viewed, and interaction patterns with our platform to enhance functionality and security.
Communications and Support Records
We retain records of communications you have with our customer support teams, including emails, chat transcripts, telephone calls, and inquiries submitted through our platform for quality assurance, training, and service improvement purposes.
2. How We Collect Information
Information is collected through multiple channels:
Direct Collection
When you register for an account, complete application forms, execute trades, contact customer support, or participate in surveys or promotional activities, you provide information directly to us.
Automated Technologies
We use cookies, web beacons, analytics tools, and similar tracking technologies to gather usage data and improve user experience. You may adjust your browser settings to refuse cookies, though this may limit certain features of our Services
Third-Party Sources
We may receive information from identity verification services, credit reporting agencies, fraud prevention vendors, and regulatory databases to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements.
3. How We Use Your Information
We use collected information for the following purposes:
Account Management and Service Delivery
We process your information to open and maintain your trading account, execute transactions, provide clearing and settlement services, maintain records, and deliver customer support.
Regulatory Compliance and Legal Obligations
We use your data to comply with CFTC regulations, federal and state financial privacy laws, anti-fraud measures, tax reporting obligations, and respond to legal processes such as subpoenas or court orders.
Security and Fraud Prevention
We monitor account activity, detect suspicious transactions, verify identities, and implement safeguards to protect against unauthorized access, identity theft, and fraudulent activity.
Platform Improvement and Analytics
We analyze usage patterns and customer feedback to enhance platform functionality, develop new features, optimize user experience, and conduct market research.
Marketing and Communications
With your consent where required by law, we may send you promotional materials, product updates, educational content, and service announcements relevant to your trading activities. You may opt out of marketing communications at any time.
4. How We Share Your Information
We share your information only as described below and in accordance with applicable law:
Affiliates
We may share information with affiliated entities within the Ornn corporate family to provide integrated services, support operations, and enhance customer experience.
Service Providers
We disclose information to unaffiliated third-party service providers, including clearing firms, payment processors, identity verification vendors, data analytics providers, cloud hosting services, cybersecurity firms, and marketing platforms that assist us in delivering the Services. These providers are contractually obligated to protect your information and use it only for authorized purposes.
Security and Fraud Prevention
We disclose information to the CFTC, other regulatory authorities, law enforcement agencies, and governmental bodies as required by law or in response to valid legal processes such as subpoenas, court orders, or investigations.
Business Transfers
In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred to successor entities, subject to applicable legal protections.
With Your Consent
We may share information with third parties when you provide explicit consent or direct us to do so.
5. Your Rights and Choices
Depending on your jurisdiction and applicable law, you may have the following rights:
Access and Correction
You may request access to the personal information we hold about you and request corrections or updates to inaccurate or incomplete data by contacting us at the information provided below.
Opt-Out Rights
Under GLBA and CFTC regulations, you have the right to opt out of certain information sharing with nonaffiliated third parties. To exercise this right, please submit a written request as described in the Contact Information section. Your opt-out will not apply to disclosures permitted by law, such as those necessary for transaction processing or regulatory compliance.
Marketing Preferences
You may opt out of receiving marketing communications by following the unsubscribe instructions in our emails or by contacting customer support.
Cookie Management
You may adjust your browser settings to block or delete cookies. Note that disabling cookies may affect the functionality of our Services.
6. Data Security
We implement administrative, technical, and physical safeguards designed to protect your information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption of sensitive data in transit and at rest, multi-factor authentication, intrusion detection systems, regular security audits, employee training, and access controls limiting data access to authorized personnel.
Despite these efforts, no electronic transmission or storage system is entirely secure. We encourage you to protect your account credentials and notify us immediately if you suspect unauthorized activity.
7. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Retention periods vary based on the type of information and applicable regulatory requirements, including CFTC recordkeeping mandates.
8. Third-Party Links and Services
Our Services may contain links to third-party websites, platforms, or services not controlled by Ornn. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party sites you visit.
9. Children's Privacy
Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a child, we will take steps to delete it promptly
10. International Data Transfers
Ornn operates primarily in the United States. If you access our Services from outside the U.S., your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using our Services, you consent to such transfers.
11. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, Services, or legal requirements. We will post the revised policy on our website with an updated "Last Updated" date. Material changes will be communicated through email or prominent notice on our platform. We encourage you to review this Privacy Policy regularly.
12. Contact Information
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Ornn Compute Exchange
Privacy Office
263 Newbury St, Boston MA, 02116
Email: kush@ornnai.com
Phone: +1-512-781-0303
For privacy-related inquiries under CFTC regulations or to submit opt-out requests, please provide your full name, account number, contact information, and a clear description of your request.
13. Additional Notices for Specific Jurisdictions
California Residents
If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA). For more information, please refer to our California Privacy Notice [available upon request].
European Economic Area (EEA) Residents
If you are located in the EEA, data protection laws such as the General Data Protection Regulation (GDPR) may provide additional rights. Please contact us for further information regarding your rights under GDPR.
Your privacy matters to us. Ornn Compute Exchange is dedicated to maintaining the confidentiality and security of your information in accordance with the highest industry standards and regulatory requirements.