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Privacy Policy

Last updated 30 Nov 2022
 

This Privacy Policy explains how OpenOrigins Limited (Frankli's parent company) and any of its subsidiaries or affiliates (collectively, “OpenOrigins”, “Frankli”,  “Company”, “we”, “our” or “us”) collect, use, and discloses personal data or other information about you (“Personal Information”) collected through the Frankli application (the “App”), and the features, content, applications, or services we provide (collectively, the “Services”), including through https://www.openorigins.com/ and https://www.frankliapp.com/ (the “Sites”). We encourage you to read the Privacy Policy carefully. When you use the Services, you are consenting to the collection, transfer, storage, disclosure, and other uses of your information as described in this Privacy Policy.

 

Why Do You Collect My Information? 
 

We collect your Personal Information when you register for our App and gather information about your user behaviour related to the App and the Services in order to provide, maintain, and improve our Services. To be more specific, we primarily use your Personal Information to: 

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  1. Communicate with you about our products, services, technical updates, policy changes and any information that you request through the Services or that we think you might be interested; 

  2. Track and analyse activities, usage, trends, numbers, and market insights related to our Services; 

  3. Process your interaction with our Services or perform a contract with you; 

  4. Personalize your experience of the App and our Services; 

  5. Improve our customer service; 

  6. Detect, prevent, and address security or technical issues; 

  7. Prevent illegal activities and protect the rights and property of Frankli and the users;  

  8. Comply with our legal obligations, including but not limited to regulatory requirements and court orders; and 

  9. Facilitate our work with vendors, agents, consultants, and other service providers. 
     

What Information Do You Collect and How Is It Collected? 
 

Information You Choose to Share: We collect information you directly share with us. When you fill out a survey, request support, use any interactive features of the Services, or communicate with us in other ways, you choose to provide the information to us. We may collect data such as your email address, full name, residency or nationality information, telephone number, username or password. 
 

IP Address and Device Information: When you use our Services, we collect log information including your IP address, browser type, time of visit and time zone, pages viewed, and any other log information typically shared through interacting with websites. We also obtain information about the device you use to access our Services, including operating system, model of the computer or mobile device, mobile network, and any other information about your device. 
 

Information Collected by Cookies: Cookies are small data files stored on your computer’s hard drive by websites that you visit. Our Site is using Cookies, which help us understand trends and quality of visits. We use information collected by Cookies to enhance effectiveness of our Services and improve your experience. For more information, see our Cookie Policy on our Site. 
 

Email Communication: If you subscribe to our newsletter with your email address, we may from time to time communicate news, updates, promotional information, marketing materials and other information related to Frankli, and the Services. If you want to opt out of receiving such emails from us, you can opt out by clicking “unsubscribe” in any of the emails we sent you. 

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We may also collect and store information that you share with us through email, including inquiries, requests, feedback, and any other information you choose to provide. 

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Social Media : We are using plugins from social networks such as GitHub, Twitter, Discord, Facebook, Reddit, Medium, YouTube on the Site. When you click on a plugin, the associated social network may collect your data, including the data of your visits on the Site, in accordance with their respective privacy policies. We are not responsible for data collected by these social networks. Please check with these social networks on their privacy policies. 

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Financial and Transaction Data: We may collect details about transactions made by you or transactions you attempt to make through our Services as well as related information such as your digital wallet data.  

Information Collected From Other Sources: We may receive information from other sources, including third party service providers. This helps us evaluate and improve our Services. 

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How Is My Information Shared? 
 

We may share your Personal Information with third parties including vendors, marketing agencies, consultants, agents, or other service providers if such sharing is necessary or if we deem it useful to facilitate our work with the third parties. 

We may also share your Personal Information as we reasonably believe is necessary to 1) comply with any applicable law, regulation, or valid directive from law enforcement or a court; 2) detect, prevent or address any security or technical issues; 3) enforce this Privacy Policy, or Terms of Service; 4) protect rights, property or safety of Frankli or others; or 5) for any legitimate purpose at our sole discretion. 

We have the right to share your Personal Information between and among Frankli (current and future) parents, subsidiaries or any other affiliates. You acknowledge that in cases where we may choose to sell or transfer our business assets, your Personal Information may be transferred or acquired by a third party, and that any acquirer of our assets may continue to use your Personal Information as provided in this Privacy Policy. 
 

What Rights Or Choices Do I Have? 
 

Under certain circumstances, you may have one or more of the following rights under data protection laws, for example under the United Kingdom’s Data Protection Act and the retained General Data Protection Regulation, the European Union’s General Data Protection Regulation or the U.S. State of California’s Consumer Protection Act,  in relation to your Personal Information:  

  • Request access to your Personal Information. 

  • Request correction of your Personal Information. 

  • Request erasure of your Personal Information. 

  • Object to processing of your Personal Information. 

  • Request restriction of processing your Personal Information. 

  • Request transfer or your Personal Information. 

  • Right to withdraw consent. 
     

You also have the right to ask us not to continue to process your Personal Information for marketing purposes. 

You can exercise any of these rights, where applicable, at any time by contacting us at: legal@openorigins.com.  

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 
 

You may unsubscribe from our email communications or opt out of receiving promotional communications from us by completing the instructed steps in those communications or by emailing us at: legal@openorigins.com. 

You may also stop us from sharing your Personal Information with third party service providers, including marketing agencies, by sending us a request at: legal@openorigins.com. 
 

How Do You Keep My Information Secure? 
 

All Personal Information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 

While we are continuously improving our security measures, we cannot guarantee the security of your Personal Information. You should be aware that unauthorized entry or use, technical system failures, and other factors, may jeopardize your Personal Information. 

 

How Long Do You Keep My Information? 
 

We store your Personal Information only for the period necessary for the purpose(s) for which we collect the information, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or as required or allowed by applicable laws. 

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for a number of years after they cease being customers for tax and other legal purposes 

In some circumstances you have the right to ask us to delete your data. In some circumstances we will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 
 

How Do You Update the Privacy Policy? 
 

We may amend this Privacy Policy at any time by posting the amended version on the Site, through the App or otherwise through our Services including the date of the amendment. If we make changes, we will notify you by posting an announcement on the Services or sending you an email. Your use of the Services after any changes to the Privacy Policy constitutes your consent to the changes and you are bound by the amended Privacy Policy. 
 

What If My Information Is Transferred To Foreign Countries? 
 

We process and store your information in the United Kingdom. However, we and our service providers may transfer your Personal Information to, or store it in, other jurisdictions.  

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.  

  • Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK. 

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. 
 

What If I Have Questions About the Privacy Policy? 
 

If you have any questions regarding this Privacy Policy, please contact us at: legal@openorigins.com. 

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