Privacy Policy

1. General

1.1 At Origami OG – FZCO (“Origami”, “we”, “our”, “us” or the “Site”), we value theprivacy of our users and are dedicated to protecting your personal information.Before using or accessing any websites operated by us, our application interfaces(“APIs”) and any services made available through the websites, software and APIs(collectively, the “Services”), you must read this Privacy Policy carefully tounderstand how we collect, use, and disclose your data.

1.2 All natural persons or entities who access our Sites and/or use our Services shallbe deemed users of the Sites. For the purposes of this Privacy Policy, such usersare referred to as “you”, and Origami and you together are referred to as the“Parties”, and individually as a “Party”.

1.3 Unless otherwise defined herein, all capitalized terms shall have the meaningsascribed to them in the Terms and Conditions.

2. Purposes of the Privacy Policy

2.1 This Privacy Policy sets out the types of data we may collect through yourregistration on the Sites or use of the Services. This includes personal data youprovide, data we obtain from third parties, and data collected automatically,which identifies a person or relates to an identifiable person (“Personal Data”).

2.2 The Policy also explains how we store, process, and protect your Personal Dataand describes your rights in relation to your data.

3. Your consent

3.1 By accessing or using the Sites or Services, you acknowledge that you haveread and understood this Privacy Policy and that the processing of your PersonalData may be based on one or more of the following legal grounds:

your freely given consent, where such consent is required;
the necessity of processing for the performance of a contract or for takingsteps at your request prior to entering into a contract;
compliance with legal, regulatory, or supervisory obligations applicable toOrigami, including but not limited to AML, CTF, sanctions, and financialcompliance requirements;
Origami’s legitimate interests, provided that such interests are notoverridden by your fundamental rights and freedoms.

Where processing is based on legal or contractual necessity, withdrawal ofconsent shall not affect Origami’s right to continue such processing to the extentpermitted or required by law.

3.2 You acknowledge and agree that certain Personal Data may be processedwithout your consent where such processing is required for compliance withapplicable laws, regulatory obligations, contractual performance, disputeresolution, fraud prevention, or enforcement of Origami’s rights.

4. Information collected

4.1 When you use our Sites, you agree that Origami may use cookies and othertechnologies to track your interactions, collect, and retain data such as your IPaddress, geolocation, device type, and browser information.

4.2 We may collect, process, and store Personal Data actively provided by you orautomatically collected during your use of the Services, including:

Identification Information - name and verification data to confirm youreligibility to use the Services.
Institutional Information - for corporate or institutional users, companyname, registration details, legal structure, address, and identification ofbeneficial owners.
Financial Information - billing information, wallet addresses, transactionhistory, and associated identifiers.
Service Information - logs, access data, browser type, IP address, sessiondata and information regarding your interaction with APIs.
Transaction and Wallet Information - on-chain data such as blockchainaddresses, transaction IDs and network information.
Correspondence Information - data from customer supportcommunications, feedback, surveys and inquiries

4.3 We may also collect information when you interact with integrated third-partyservices.

4.4 Origami may collect additional information as necessary to improve thefunctionality, security and performance of the Sites or as required by law orregulatory authorities.

4.5 If you access any third-party links from our Sites, you are subject to the PrivacyPolicy of that third party. Origami assumes no responsibility for their practices orcontent.4.6 User Content, API requests, communications, logs, and other data generatedthrough your use of the Services may contain Personal Data. Such data shall beprocessed in accordance with this Privacy Policy and applicable data-protectionlaws

5. Collection of Personal data

5.1 We collect Personal Data through the following means:

Information you provide directly (via account registration or emails);
Information from third parties (affiliates, service providers);
Information generated through your interactions with our APIs andplatforms;
Publicly available sources or blockchain data.

6. Transfer of Personal data

6.1 Your Personal Data may be transferred to and stored on servers located outsideyour country of residence.

6.2 By using our Services, you consent to such transfers, even if those jurisdictionsoffer a lower level of data protection.

6.3 Origami ensures that appropriate contractual and organizational safeguardsare implemented to maintain security and compliance.

7. Cookies Policy

7.1 Cookies are small text files placed on your device to store information aboutyour usage preferences, visit duration and browsing behavior.

7.2 We use both session cookies (which expire after your session ends) andpersistent cookies (which remain on your device).

7.3 Cookies help us improve functionality, enhance security, detect suspiciousactivity, and comply with AML/CTF requirements.

7.4 You may disable cookies via your browser, but certain features of our Sites maynot function properly as a result

8. Use of Information

8.1 We use your Personal Data for the following purposes:

To provide, operate, and maintain our Services;
To verify identity and maintain security;
To enhance the Sites’ functionality and performance;
To conduct analytics and usage statistics;
To personalize your experience;
To process transactions and manage accounts;
To communicate important updates, notices, and marketing (wherepermitted);
To comply with applicable AML, CTF and sanctions regulations;
To prevent, detect, and investigate fraudulent or unauthorized activities;
To comply with court orders, legal requests, and regulatory obligations;
To conduct sanctions screening, transaction monitoring, blockchainanalytics, risk assessments, and compliance checks, including through theuse of third-party compliance, analytics, or blockchain-monitoring serviceproviders.

8.2 We may disclose Personal Data in the following cases:

To our affiliates, subsidiaries, and contractors;
To service providers that support operations (hosting, compliance,analytics, KYC);
To legal and financial advisors;
In connection with corporate restructuring or acquisition;
To law enforcement or regulators when legally required.

8.3 We do not sell, lease, or otherwise make your Personal Data available to anythird parties for marketing, promotional, or similar commercial purposes

9. Protection of Personal data

9.1. Origami applies appropriate technical and organizational measures tosafeguard your data, including:

Secure Socket Layer (SSL) encryption;
Multi-factor authentication;
Restricted internal data access;
Firewalls and intrusion detection systems;
Staff confidentiality and data security policies.

9.2. Although we employ strong security measures, no system is completelysecure. Users are responsible for maintaining the confidentiality of theircredentials.

9.3 In the event of a data breach, we will take prompt remedial action and notifyaffected users and authorities as required by law.

10. Data retention

10.1 Origami retains Personal Data only for as long as necessary to fulfill thepurposes described in this Privacy Policy, including the provision of Services,compliance with legal and regulatory obligations, resolution of disputes,enforcement of agreements, and protection of Origami’s legal rights.

10.2 Certain categories of Personal Data may be retained after accounttermination or deletion where retention is required or permitted by applicablelaws, including AML, CTF, sanctions, tax, accounting, audit, or record-keepingrequirements, or where necessary for the establishment, exercise, or defense oflegal claims.

10.3 Upon expiration of applicable retention periods, Personal Data will be securelydeleted or irreversibly anonymized.

11. Minors

11.1 Our Services are not intended for individuals under the age of 18. If we discoverthat we have collected data from a minor, we will delete it immediately.

11.2 Parents or guardians who believe their child has submitted data shouldcontact us at info@origami.tech.

12. Modifications to the Privacy Policy

12.1 Origami reserves the right to amend this Privacy Policy from time to time.Updates will be published on our website with the revised effective date.

12.2 Your continued use of the Sites constitutes acceptance of any changes.

13. Non-EU Targeting & Applicable Law

13.1 Origami OG – FZCO is incorporated and operates under the laws of the UnitedArab Emirates. This Privacy Policy and any related matters shall be governed byand construed in accordance with the applicable data-protection laws of theUnited Arab Emirates, including Federal Decree-Law No. 45 of 2021 on theProtection of Personal Data.

13.2 The Services are not specifically targeted at or intended for residents of theEuropean Union or any particular jurisdiction. Origami does not intentionallymarket, advertise, or offer its Services to EU residents.

13.3 However, if you access the Sites or use the Services from within the EuropeanUnion or another jurisdiction with specific privacy requirements, Origami willhandle your Personal Data on a best-effort basis in accordance with generallyaccepted international data-protection standards and principles.

13.4 In the event of any conflict between applicable data-protection laws, the lawthat provides the higher level of protection to the individual shall prevail to theextent required.

14. Your Data Protection Rights

Depending on your jurisdiction, you may have the right to:

Access and receive a copy of your Personal Data;
Request correction or deletion of your Personal Data;
Object to or restrict processing;
Withdraw consent at any time (without affecting prior lawful processing);
Lodge a complaint with a relevant supervisory authority.

To exercise these rights, contact us.

Contact Information

For any questions, complaints, or data protection requests, please contact:

ORIGAMI OG - FZCO

Email: info@origami.tech