Legal & Privacy

You must immediately update and inform Oero of any changes to your User Content by updating your personal data by contacting us at [email protected] , so that we can communicate with you effectively and provide accurate and up to date information to you. You are solely responsible for creating backup copies and replacing any User Content you post or store on the Site at your sole cost and expense.

If you become aware of any User Content that you believe violates these Terms you may report it by emailing [email protected] . Enforcement of the Terms, however, is solely in our discretion and the absence of enforcement of these Terms in some instances does not constitute a waiver of our right to enforce the Terms in other instances. In addition, these Terms do not create any private right of action on the part of any third party or any reasonable expectation or promise that the Site will not contain any content that is prohibited by the Terms.

Although we have no obligation to screen, edit or monitor any User Content, we reserve the right, and have absolute discretion, to remove, screen or edit User Content. Furthermore, if we have reason to believe that there is likely to be a breach of security, breach or misuse of the Site or if you breach any of your obligations under these Terms, we may without notice suspend or terminate your use of or access to the Site at any time and for any reason.

You must only use the content or services provided on or via the Site for their stated purpose. You must not use the Site to:

(a) publish, send, upload, submit, display any information or material and/or otherwise make available or engage in any conduct that is unlawful, discriminatory, harassing, libelous, defamatory, abusive, threatening, harmful, offensive, obscene, adult, tortious or otherwise objectionable;

(b) display, upload or transmit material that encourages conduct that may constitute a criminal offence, result in civil liability or otherwise violate or breach any applicable laws, regulations or code of practice;

(c) interfere or violate the legal rights (such as rights of privacy and publicity) of others or violate others use or enjoyment of the Site;

(d) violate any applicable laws or regulations;

(e) use the Site or links on the Site in any manner that could interfere with, disrupt, negatively affect or inhibit other users from using the Site or links on the Site or that could damage, disable, overburden or impair the functioning of the Site or our servers or any networks connected to any of our servers in any manner;

(f) create a false identity for the purpose of misleading others or fraudulently or otherwise misrepresent yourself to be another person or a representative of another entity including, but not limited to, an authorized user of the Site or a Oero’s representative, or fraudulently or otherwise misrepresent that you have an affiliation with a person, entity or group;

(g) mislead or deceive Oero, our representatives and any third parties who may rely on the information provided by you, by providing inaccurate or false information, which includes omissions of information;

(h) disguise the origin of any material transmitted through the services provided by the Site (whether by forging message/packet headers or otherwise manipulating normal identification information);

(i) violate, infringe or misappropriate any intellectual or industrial property right of any person (such as copyright, trademarks, patents, or trade secrets, or other proprietary rights of any party) or commit a tort;

(j) upload files that contain viruses, Trojan horses, worms, time bombs, cancelbots, corrupted files, or any other similar software or programs that may damage the operation of another’s computer or property;

(k) send, upload, display or disseminate or otherwise make available material containing or associated with spam, junk mail, advertising for pyramid schemes, chain letters, virus warnings (without first confirming the authenticity of the warning), or any other form of unauthorized advertising or promotional material;

(l) access any content, area or functionality of the Site that you are prohibited or restricted from accessing or attempt to bypass or circumvent measures employed to prevent or limit your access to any content, area or functionality of the Site;

(m) obtain unauthorized access to or interfere with the performance of the servers which host the Site or provide the services on the Site or any servers on any associated networks or otherwise fail to comply with any policies or procedures relating to the use of those servers;

(n) attempt to gain unauthorized access to any services or products, other accounts, computer systems, or networks connected to any of our servers through hacking, password mining, or any other means;

(o) obtain or attempt to obtain any materials or information through any means not intentionally made available through the Site or its services;

(p) harvest or otherwise collect, whether aggregated or otherwise, data about others including e-mail addresses and/or distribute or sell such data in any manner;

(q) use any part of the Site other than for its intended purpose; or

(r) use the Website to engage in or promote any activity that violates these Terms.

1. Introductory

(A) Please read this Privacy Policy carefully. This Privacy Policy constitutes an integral part of the Terms of Use (the «Terms») entered into between you, a user and a data subject (the «User») and us, Oero International OÜ (Estonia) and its affiliates (also, the «Company»). Capitalised terms used in this Privacy Policy and not otherwise defined herein shall have the meaning ascribed to them in the Terms.

(B) This Privacy Policy comprises the accepted international and European data privacy principles (including the GDPR) without replacing existing national laws. It supplements national data privacy laws in each jurisdiction where the Company operates. The relevant national law will take precedence in the event of conflict with this Privacy Policy or where it has stricter requirements. This Privacy Policy must also be observed in the absence of corresponding national legislation.

(C) This Privacy Policy describes the Company’s privacy practices with regard to how the Company collects, stores, uses, shares, discloses and protects your Personal Data obtained through the Site or any of our Apps. «Personal Data» includes any data about you that specifically identifies you as an individual and information about your activities, such as information about your access and use of the Site, any of our Apps (and any related services which the Company may provide to you) (the «Service»), when directly linked to personally identifiable information, any other information and data which this Privacy Policy describes as collectable by us.

(D) The Service is provided by the Company at no cost and is intended for use on an «as is» basis.

(E) By using the Service, you accept this Privacy Policy and consent to the collection, storage, sharing, use and disclosure of your Personal Data in accordance with this Privacy Policy and applicable laws and regulations. You may withdraw your consent and require removal of your Personal Data by contacting us using the information below.

2. Collection

(A) When you use the Service, we may request to provide data which is necessary for the provision of the Service and the use of the Service. When we ask for certain personal information from users it is because we may be required by law to collect this information or it is relevant for specified purposes.

(B) Any non-required information you provide to us is done so voluntarily. You decided whether to provide us with these non-required information; you may not be able to access or utilize all of the Services if you choose not to.

(C) We may collect some Personal Data automatically (your IP address, cryptocurrency address, email, text, code, browser type and version, information about your visits (including the URL clickstream) to, through and from, the Service, web pages you viewed or searched for, length of visits to certain web pages, web page interaction, etc), through the use of tracking technologies, including cookies .

(D) All processing of Personal Data is carried out by the Company or its employees in accordance with the principles enshrined in the GDPR, being the following:

• fairness and lawfulness
• limited to purpose of collection (purpose limitation)
• transparency
• data minimisation
• storage limitation and deletion
• factual accuracy
• confidentiality and integrity of Personal Data
• accountability

3. Use and Process

We may use and process your Personal Data for the following purposes:

• proper provision of the Service or processing connected to a contractual relationship;
• compliance with applicable law and regulations or a legal authorisation;
• registration if any on the Site;
• following your consent to data processing;
• processing of your inquiries and operations in relation to the Service;
• preventing, detecting and investigating potentially prohibited or illegal activities, including fraud and activities in breach of the Terms and to enforce our Terms and other agreements, or otherwise processing pursuant to a legitimate interest which merits protection;
• investigation and/or enforcement of violations of this Privacy Policy, or to protect our interests and legal rights and, if required by law, those of our users;
• sending you marketing emails with the information about our Service and other products that we deem to be interesting for you. You may opt out of such emails by sending the respective request to us or by clicking the respective link in the email.

4. Disclosure

(A) The Company and its employees treat Personal Data as confidential and may not pass on or use any of such data without valid legal grounds as indicated above. We may disclose some information which constitutes Personal Data with certain third parties. Therefore normally we do not share such information with companies, organizations and individuals outside of the Company unless one of the following circumstances applies:

(i) where we have a good-faith belief that access, use, preservation or disclosure of the Personal Data is reasonably necessary to:

• meet any applicable law, regulation, legal process or enforceable governmental request;
• enforce applicable actions, including investigation of potential violations;
• detect, prevent, or otherwise address fraud, security or technical issues;
• protect against harm to the rights, property or safety of the Company, our users or the public as required or permitted by law;

(ii) we may share non-personally identifiable information publicly and with our partners (for example, where we wish to show trends about the general use of the Service);

(iii) if the Company is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any Personal Data and give affected Users notice before Personal Data is transferred or becomes subject to a different privacy policy.

(B) We may hire other companies to perform certain business-related functions such as processing payments on our behalf. Our payment processing partner may request that you provide certain Personal Data (for example, a valid government-issued ID, your legal name, address, and date of birth, banking credentials, etc.) for the purpose of making payment through its financial institutions and complying with any applicable laws and regulations. They may also communicate directly with you regarding any issues as to a payment. Any information provided to such third party will be confidential and only be used for intended purposes.

5. Third parties services

(A) We do not sell, provide on lease, or share any Personal Data of the Users to third parties.

(B) Our Service may contain links to and from third parties’ websites, apps or other services (including social media). If you follow a link to any of them, please note that those websites have their own privacy practices and policies. We shall not be liable for the respective policies and any collection, use or disclosure of your Personal Data in accordance thereto. Please check the third parties’ policies before you submit any Personal Data to their services.

(C) When we use third-party vendors to perform certain services on behalf of us, such as hosting the site or application, analytical or other services, such third-party vendors may collect or have access to information about you (for example, automatically collected information through tracking technologies). Please recognize that we and/or our vendors may store this information and share this information with third parties as necessary to provide you with the Service.

6. Data storage and security and cross-border transfer

(A) We will use all reasonable measures to protect your Personal Data from unauthorized access, alteration, disclosure or removal. The Service is equipped with the means of security and protection of your Personal Data.

(B) Immediate access to your Personal Data is allowed only to us and persons authorized by us and involved in the maintenance of the Service. Such persons have been instructed to keep strict confidentiality of and prevent unauthorized third-party access to your Personal Data.

(C) Please remember that the Service (and your Personal Data) may be hosted on a server outside your home country. Supplying us with your Personal Data, you permit its transfer outside the country, within the bounds of use of such Personal Data in accordance with the applicable law.

(D) Transmission of Personal Data to recipients by the Company, both internally and externally, is subject to the authorisation requirements and pursuant to defined purposes, as specified above. Personal Data transmitted to a recipient outside the EEA must be subject protection at least equivalent to that sought by the GDPR.

(E) We emphasize that none of the existing ways of data transfer can be absolutely safe. The Company does not guarantee the absolute security of data in case of unauthorized access of the third parties.

(F) We shall not be responsible for unlawful acts of third parties, hackers, intruders, and other offenders of applicable legislation that can violate the provisions of this Privacy Policy and try to collect, either fully or in part, your Personal Data and to use it for personal advantages.

7. Children’s privacy

(A) We do not collect, use or share the Personal Data of children (under the age under the applicable law). You must be a legal adult to access the Service under the applicable law and the law of the country where you are located.

(B) While individuals under the childhood age may use the Service, they shall do so only with the involvement, supervision, and approval of a parent or legal guardian. At any case, we are committed to comply with applicable laws and requirements of the residence country.

8. Cookies

(A) To ensure that the Site and our Apps functions properly, we may use various tracking technologies like cookies, web beacons or similar technologies. By using the Site and any App, you provide us your consent for our using of cookies and similar tracking technologies under the terms hereof.

(B) Cookies are small data files that are commonly stored on your device when you browse and use online services. They are widely used to make web applications work or to work more efficiently, as well as to provide reporting information and assist with service or advertising personalization.

• to manage our business and improve the Service based on factors such as how many users visit or use the Service, what pages and views are accessed, whether visitors are new or repeat visitors, which features of the Service most interest our visitors etc.;
• to provide personalized recommendations, advertising, marketing emails, and guidance on Service features based on your activity using the Service and browsing activities;
• to remember actions you took to avoid asking you to repeat them during a session or to provide features such as enabling you to resume reading at the last page you accessed, synchronized across devices
• to measure and analyze activity on our services, or third-party services. In addition, we or any provider of such measurement and analytical services may provide non-personally identifiable data to third parties.

(D) The User may block, clear and delete cookies in accordance with the instruction for their web-browser or device.

9. Users rights

Every User has the following rights in relation to the processing of his or her Personal Data in accordance with the GDPR and other applicable law:

• right of access
• right of rectification
• data portability
• right to erasure
• right to restrict processing
• right to object to processing

10. Amendments to Privacy Policy

We have the right to amend this Private Policy at any time, without prior notice to each User. Any changes we may make to our Privacy Policy in the future will be posted here. Please check back frequently to see any updates or changes to our Privacy Policy.

11. Contact info

If at any time you would like to contact us or the Company’s Data Protection Officer with your views about our privacy practices, or with any inquiry relating to your Personal Data (its correction, removal or use) or the exercise of any of your rights described above or would like to receive the Company’s Data Protection Policy, you can do so by sending a letter to our email address: [email protected]

Anti-Money Laundering Policy (AML Policy)

This Anti-money Laundering Policy (hereinafter referred to as "AML Policy") outlines the procedures and mechanisms used by Oero International for the purpose of preventing money laundering. Oero International adheres to the following policies:

• not entering into business relationships with criminals and/or terrorists;
• not processing transactions that are result from criminal and/or terrorist activities;
• not facilitating any transactions related to criminal and/or terrorist activities;

Verification Procedures

Oero International shall establish its own procedures for determining compliance with the anti-money laundering standards and Know Your Customer (KYC) policy. Oero International Customers complete a verification procedure (they must provide an identification document issued by the state: passport or an ID card). Oero International reserves the right to collect Customers' identification information for AML Policy purposes. This information is processed and stored strictly in accordance with the Oero International Privacy Policy. Oero International may also request a second Customer identification document: a bank statement or utility bill no older than 3 months, which includes the Customer's full name and current address. Oero International shall verify the authenticity of documents and information provided by Customers and reserves the right to request additional information on Customers who have been identified as dangerous or suspicious. If the Customer's identification information has been changed or their activity appears suspicious, Oero International is entitled to request updated documents from the Customer, even if they have been authenticated in the past.

Anti-Money Laundering Officer

We may use and process your Personal Data for the following purposes:

• The Anti-Money Laundering Officer is a Oero International employee who is responsible for ensuring compliance with the AML Policy, such as:
• • establish and update internal policies and procedures for creating, reviewing, submitting and storing all reports required in accordance with existing laws and regulations;
  • transactions monitoring and analysis of any significant deviations from the Customers' usual activities;
  • the introduction of a records management system for storing and retrieving documents, files, forms and logs;
  • regularly update risk assessments.
• An Anti-Money Laundering Officer has the right to engage with law enforcement agencies that deal with the prevention of money laundering, financing of terrorism and other illegal activities.

Risk assessment

In accordance with international requirements, Oero International applies a risk-based approach tо anti-money laundering and financing of terrorism. Thus, measures aimed at the prevention of money laundering and financing of terrorism are commensurate with the identified risks, allowing resources to be effectively dedicated. Resources are used on a priority basis; the greatest attention is given to the greatest risks.

Licensing

Oero International OÜ is licensed subject of the European Union and has the following licenses for crypto-activity:

1. Providing a virtual currency wallet service
2. Providing services of exchanging a virtual currency against a fiat currency