Privacy Policy

Last Updated: September 13, 2025

Introduction

Welcome to Orinav!

When you use the Orinav mobile app, Orinav smart devices, or the website orinav.com (together, “Orinav”), certain of your Personal Information (defined below) will be collected and processed by us.

This Privacy Policy explains the when, how and why when it comes to processing of your Personal Information in connection with Orinav, and sets out your choices and rights in relation to that Personal Information.

Please note that this Privacy Policy only applies to Orinav. If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using Orinav. By using Orinav, you are acknowledging how we process your personal information as described in this Privacy Policy.

In this Privacy Policy, “we”, “our” or “us” refers to Orinav Team, located at 10 Kangyuan Road, Chaoyang District, Beijing, China.

Any capitalized terms used in this Privacy Policy have the same meaning as the equivalent defined terms in the Orinav Terms of Service, unless they are defined otherwise in this Privacy Policy.

Contact

If you have any questions or complaints regarding this Privacy Policy or the use of your Personal Information, please contact our Data Protection Officer via email at [email protected] or via postal mail at 10 Kangyuan Road, Chaoyang District, Beijing, China (Attention: Data Protection Officer). We have representatives for data protection purposes listed here.

Please note that if you are a resident in the EEA, the UK or Switzerland you have the right to lodge a complaint with your country’s data protection authority.

Scope and Application

This Privacy Policy only applies to you if you are an Orinav user.

This Privacy Policy does not apply to Personal Information collected by third party services that you may access through Orinav (e.g., search and navigation with third-party data providers), and Personal Information that you choose to share with an Orinav user. Please refer to the privacy policy of the relevant third party service. For more information, please see the section entitled “Who do we share your data with” below.

If you are using Orinav on behalf of a company, partnership, association, government or other organization (your “Organization“), you agree to notify such persons in your Organization whose Personal Information (defined below) we collect or you provide to us (“Connected Persons“), and you agree to obtain such Connected Persons’ consent to the processing of their Personal Information in accordance with this Privacy Policy as required by applicable laws and regulations. When this Privacy Policy refers to “you”or “your”, this includes you and any Connected Persons. If you or any Connected Persons would like to request for your Personal Information to be removed from our database, please contact us at [email protected].

Definitions

“Location Data” is information that is derived from your GPS (GPS coordinates), WiFi (approximate city location), IP address (country location), or public posts that contain location information (the location you geo-tag). Location Data will be disclosed (either to us, to other users, or both):

when you use navigation features;
when you access Orinav, we automatically derive Location Data from your IP address, device, or internet service for security purposes including to prevent fraudulent use.

You may disable the collection and use of your location data through device-level settings.

“Log Data” is information that is automatically collected when you use Orinav, including:

device attributes, such as your mobile carrier and network-related information, your device version and resettable identifiers, configuration information made available by your Orinav mobile app, and your IP address;
general information about your use of Orinav, such as the the time, date and duration of your navigation and use of environmental awareness features (but not the content of such navigation), statistics about your use of Orinav, and traffic data; and
metadata, which means information related to items you have made available through Orinav

“Personal Information” is any information, or combination of information, that relates to you, that can be used (directly or indirectly) to identify you, which we process in connection with your use of Orinav. Please see the section entitled “How do we use your information?” below for examples.

How do we use your information?

This section provides more detail on the types of Personal Information we collect from you, purpose of processing, and retention periods for each type of Personal Information.

Where applicable, it also identifies the legal basis under which we process your data under applicable data protection laws

We do not retain Personal Information for longer than is necessary unless we are required or permitted to do so under applicable laws. If we are required to retain your Personal Information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of Personal Information. Aggregated registration data (which does not contain Personal Information) is retained for spam prevention and system security purposes. For further details on how long we keep your data, please refer to the retention periods set out below.

Information	Purpose of Processing	Retention Period
Diagnostic and analytics data. IP address, user identifier, region. Legal Basis (Relevant Jurisdictions only): Necessary to provide fundamental Orinav services and improve our products.	– to facilitate your use of Orinav features; – to enforce our terms, conditions, and policies; – to communicate with you to notify you about changes to Orinav; – to provide you with personalised user support; – to develop new and improve existing services; – to provide language and location customisation; – to protect any rights, property or safety of ours, our affiliate companies, or other users of Orinav; and – to administer Orinav and for troubleshooting, data analysis, testing, research, security, fraud-detection, account management, and survey purposes.	Diagnostic data is retained for a period of 3 months from the date of app use session.
Location data. See definition above. Legal Basis (Relevant Jurisdictions only): Necessary to provide navigation services.	– To allow you to navigate with Orinav; – to facilitate your use of Orinav features; – to provide you with personalised user support; – to provide language and location customisation; – to develop new and improve existing services and app experience; – to maintain and administer the Orinav platform; and – for troubleshooting, data analysis, testing, research, security, fraud-detection and account management.	Location data is retained until your app usage session ends. (however, the data may be cached on third party services and retained in accordance with their own privacy policies).
Contact data. Your name, email address, phone number, and nationality. Legal Basis (Relevant Jurisdictions only): We collect this information with your consent.	– To allow you to participate in beta testing programs and research studies; – to provide you with personalised user support; – to provide language and location customisation; – to develop new and improve existing services and app experience; – to maintain and administer the Orinav platform; and – for troubleshooting, data analysis, testing, research, security, fraud-detection and account management.	Contact data is retained until you cease to participate in beta testing programs and research studies.
Log Data. See definition above. Legal Basis (Relevant Jurisdictions only): It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.	– For troubleshooting, data analysis, testing, research, security, fraud detection, and account management.	Permanently deleted 3 months from the date of collection.
Customer Support Information. Communications with and any information that you or other users provide to our customer support team. Legal Basis (Relevant Jurisdictions only): Necessary to perform our contract with you to provide and support Orinav.	– To investigate the issue and provide customized customer support; – to develop new and improve existing services and app experience; – for security, fraud detection, and account management; and – for moderation of content or behavior that is prohibited by applicable laws and regulations, or which otherwise violate Orinav’s terms of service or other rules applicable to Orinav users.	Permanently deleted 6 months from the date of collection.

We may also pseudonymise or aggregate Personal Information for analytical purposes. This helps us develop new and improve existing services, conduct fraud detection and account safety analysis, analyze usage trends, and provide third party service providers with basic statistics about how their service is being used by Orinav users.

Sensitive Personal Information

In some jurisdictions, certain types of Personal Information, such as information about your race, religious, political or philosophical views, sexual orientation, and health, are characterised as sensitive and are subject to stricter regulation than other types of Personal Information.

Orinav does not require you to provide sensitive Personal Information to use the service. By posting or communicating any sensitive Personal Information within Orinav, you consent to such information being available within the privacy controls you have selected.

Who do we share your data with?

We will not transfer your Personal Information to third parties except as specified below, or where you consent to such transfer.

Only where necessary will we share your information with selected recipients, including:

service providers. We engage service providers to supply services to support or improve Orinav. These include location and mapping, account data labelling and safety assurance (where applicable) and content delivery service providers. These service providers are required to provide the same or equal protection of user data as stated in this Privacy Policy and are prohibited from retaining, using, or disclosing your information except as necessary to provide services to us;
third parties or related group companies in the event of a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, we will transfer your information to such entity accordingly so that your service can continue. Under these circumstances, we will always require the third parties or related group companies to comply with this Privacy Policy;
government, public, regulatory, judicial and law enforcement bodies or authorities. There are circumstances in which we are legally required to disclose your information, including (i) to comply with a legal obligation or request, such as a court order, subpoena or other legal process, (ii) to enforce our terms, (iii) to address issues relating to security or fraud, or (iv) where there is an imminent emergency involving risk of death, serious physical injury to a person or any risk of harm to a child, and in both cases, provided that the requesting entity has valid jurisdiction to obtain your Personal Information; and
third parties pursuant to your request, for example, pursuant to your data portability request.

For the purposes of providing Orinav’s services and fulfilling our contract with you, Orinav contracts the following service providers.

Service Provider	Purposes	Third Party Privacy Policy
Tencent Map, provided by Shenzhen Tencent Computer Systems Company Limited	– To provide map data for Orinav; – to facilitate searching for points of interest in Orinav; – to facilitate navigation in Orinav.	https://privacy.qq.com/document/preview/a10a8634f237464d
Mapbox, provided by Mapbox, Inc.	– To provide map data for Orinav; – to facilitate searching for points of interest in Orinav; – to facilitate navigation in Orinav.	https://www.mapbox.com/legal/privacy
Cloudflare, provided by Cloudflare, Inc.	– To deliver Orinav services to you; – to manage and administer the Orinav platform; – for troubleshooting, data analysis, testing, research, security, fraud-detection and account management.	https://www.cloudflare.com/privacypolicy
Tencent Cloud, provided by Shenzhen Tencent Computer Systems Company Limited	– To deliver Orinav services to you; – to manage and administer the Orinav platform; – for troubleshooting, data analysis, testing, research, security, fraud-detection and account management.	https://cloud.tencent.com/document/product/301/11470
Aliyun, provided by Aliyun Computation Limited	– To deliver Orinav services to you; – to manage and administer the Orinav platform; – for troubleshooting, data analysis, testing, research, security, fraud-detection and account management.	https://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud202107091605_49213.html

Where do we process your data?

Orinav is a global platform. Our engineering, technical, and other support teams are based in our offices around the world, and may have incidental access to certain of your information, for example, in order to fix technical issues that you report. The Personal Information that we collect from you will be transferred to, stored at, or processed in the United States. We rely on the European Commission’s model contracts for the transfer of personal data to third countries.

Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your Personal Information no matter where it is stored or accessed. We protect your Personal Information through the use of information security and access policies that limit unauthorized access to our systems, and technological protection measures such as encryption that ensure confidentiality of your Personal Information during transmission and in storage.

Although we will implement and maintain reasonable measures to protect your Personal Information, please note that as any transmission of information via the internet is never completely secure.

Communications From Us

We may send you service-related announcements via Orinav, email, or SMS when necessary, such as when we temporarily suspend Orinav for maintenance, or security, or privacy reasons. You may not opt-out from these service-related announcements which are not promotional in nature.

Age Restrictions and Parental/Guardian Controls

Children under the age of 13 (or such applicable age of majority under relevant local laws of the user) (“Child“) must not use Orinav for any purpose without first obtaining parental/guardian consent to and acknowledgment of this Privacy Policy (both for themselves and on their Child’s behalf). In certain jurisdictions, you may be required to provide your date of birth; we will however only process the year and month of your birth. We do not knowingly collect Personal Information from any Orinav without such consent and acknowledgment. Please contact our Data Protection Officer if you believe we have any Personal Information from any Child without such parental/guardian consent and acknowledgment so that we can promptly investigate and remove such Personal Information.

Your Rights

This Section only applies to users located in a Relevant Jurisdiction, unless otherwise specified.

If you are a user located in Australia, Brazil, Canada, China, Hong Kong SAR, Indonesia, Japan, Macau SAR, Malaysia, Mexico, Philippines, Russia, Serbia, Singapore, South Korea, Sri Lanka, Chinese Taiwan, Thailand, Türkiye, United Arab Emirates, United Kingdom, United States and Vietnam, the terms set out under the name of your jurisdiction in the “Supplemental Terms – Jurisdiction-Specific Addenda” section may apply to you in addition to the other terms set out in our Privacy Policy.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). Please note that in order to protect your information, we will need to verify your identity before responding to any request to exercise your rights (“DSR Request“). To exercise any of your rights, please contact our Data Protection Officer.

Access & Correction

This section also applies to users resident in Argentina, Canada, China, and Russia.

You have the right to request access to your Personal Information we hold about you, how we use it, and who we share it with. We may not be able to provide you with certain Personal Information if providing it to you would interfere with another person’s rights (e.g. where providing the Personal Information we hold about you would reveal information about another person).

You also have the right to correct that information if it is inaccurate or incomplete.

You can access and correct your Personal Information by contacting our Data Protection Officer.

Where we agree to correct your Personal Information, we will use reasonable steps to inform any third party to whom we have disclosed the relevant Personal Information so that they can rectify the Personal Information too.

Erasure

This section also applies to users resident in Argentina, Canada, China, and Russia.

You may request that we erase your Personal Information by contacting our Data Protection Officer.

You may request that we erase the Personal Information we hold about you where:

you believe that it is no longer necessary for us to hold your Personal Information;
we obtained your consent to process the Personal Information and you withdraw that consent (and we have no other valid legal grounds for processing the Personal Information);
you believe we are unlawfully processing your Personal Information; or
you are or were under the age of 13 (or such applicable age of majority under relevant local laws) when we collected the Personal Information and we can verify this.

You may exercise your right to restrict our processing your Personal Information (as described below) whilst we consider a request to erase your data.

We may retain the Personal Information if there are valid legal grounds for us to do so (e.g., for the defence of legal claims, freedom of expression or some other legal obligation) but we will let you know if that is the case.

Where you have requested that we erase your Personal Information that we have made public and there are valid legal grounds for erasure, we will use reasonable steps to inform any third party to whom we have disclosed the relevant Personal Information so that they can erase it too.

Restriction of Processing to Storage Only

This section also applies to users resident in Russia.

You have a right to require us to stop processing your Personal Information other than for storage purposes in certain circumstances. However, we may process it if there are other valid legal grounds for us to do so (e.g., for the defence of legal claims or for another’s protection).

Where we agree to stop processing the Personal Information, we will use reasonable steps to inform any third party to whom we have disclosed the relevant Personal Information so that they can stop processing it too.

You may request we stop processing and just store the Personal Information we hold about you where:

you believe the Personal Information is not accurate (for the period it takes for us to verify whether it is accurate);
we wish to erase the Personal Information as the processing is now unlawful (but you want us to retain the Personal Information and just store it instead); or
we wish to erase the Personal Information as it is no longer necessary for our purposes (but you require it to be stored for the establishment, exercise or defence of legal claims).

Portability

You have the right to receive a copy of certain of your Personal Information in a structured, commonly used and machine-readable format. This comprises any Personal Information we process on the basis of your consent (e.g., Shared Information and content saved to Favorites) or pursuant to our contract with you (e.g., profile data), as described in the section “How do we use your personal information”. You can exercise your right to export your data by contacting our Data Protection Officer.

You also have the right to request that we transfer that Personal Information to another party. If you wish for us to transfer the Personal Information to a third party, please ensure you provide details of such party. Note that we can only make such transfers where it is technically feasible. We are not responsible for the security of the Personal Information or its processing once received by the third party.

Objection

This section also applies to users resident in Russia.

You may object to our use of your Personal Information that we use on the basis of our legitimate interests (e.g., when we use your Personal Information to ensure account security). If you object to such processing, please contact our Data Protection Officer.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us by contacting our Data Protection Officer.

Changes to This Privacy Policy

We may from time to time revise this Privacy Policy. We will update the revised version here along with the “last updated” date, and notify you via Orinav or other means, as appropriate, before the change becomes effective.

Supplemental Terms – Jurisdiction-Specific Addenda

If you are a user located in Australia, Brazil, China, Canada, Hong Kong SAR, India, Indonesia, Japan, Macau SAR, Malaysia, Mexico, Philippines, Russia, Serbia, Singapore, South Korea, Sri Lanka, Taiwan (China), Thailand, Turkey, United Arab Emirates, United Kingdom, United States or Vietnam, the terms set out below under the name of your jurisdiction apply to you in addition to the terms previously set out.

We have provided translations of the Privacy Policy, but in the event of any conflict between the local language version and the English version, unless otherwise prescribed by applicable law, the English version shall prevail.

Australia

This section applies to users located in Australia:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your Personal Information located outside Australia handle your Personal Information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

You have the right to access Personal Information we hold about you, how we use it, and who we share it with. You can access the Personal Information you have made available as part of your account by logging into your account. If you believe we hold any other Personal Information about you, please contact our Data Protection Officer.

Correction

You have the right to correct any of your Personal Information we hold that is inaccurate. You can access the Personal Information we hold about you by contacting our Data Protection Officer.

Children

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to use Orinav.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your Personal Information or your privacy complaint in respect of your Personal Information, you may contact the Office of the Australian Information Commissioner (Telephone +61 1300 363 992 or email [email protected]).

Brazil

This section applies to users located in Brazil:

Consent Revocation

Whenever we use your Personal Information based on your consent, you may revoke consent that you have previously given for the collection, use and disclosure of your Personal Information, subject to contractual or legal limitations. To revoke such consent, you may contact our Data Protection Officer. This may affect our provision of Orinav to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use Orinav for any purpose without first obtaining parental/guardian agreement to the Privacy Policy (both for themselves and on your behalf). We do not knowingly collect Personal Information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any Personal Information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such Personal Information.

Canada

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates.

Our designated data protection officer can be contacted at [email protected].

Consent Revocation

You may revoke consent that you have previously given for the collection, use and disclosure of your Personal Information, subject to contractual or legal limitations. To revoke such consent, you may contact our Data Protection Officer. This may affect our provision of Orinav to you.

Access

Correction

You have the right to correct any of your Personal Information we hold that is inaccurate. You can access the Personal Information we hold about you by contacting our Data Protection Officer.

China

Personal Information Processor

Orinav Team is the personal information processor for Orinav users in the People’s Republic of China (for the avoidance of doubt, not including Hong Kong SAR, Macau SAR, and Chinese Taiwan, and hereinafter referred to as “China”). Orinav Team may be contacted at [email protected].

International Transfer of Data

Orinav does not transfer data internationally for users from China.

Procedural Decisions Based on Personal Data

Orinav performs procedural decisions based on your personal data for the security of our operations and for the purposes of fulfilling our contract with you.

Age Restrictions

Parental consent is required for children under the age of 18 years who wish to use our services. Where the users are children, their parents understand and acknowledge that our collection, storage and processing of Personal Information shared with us, shall be used for the lawful purposes set out in the Privacy Policy and is considered necessary for us to provide the services.

Data Subject Rights

You may act upon your rights to access, modify, and erase your personal information by contacting our Data Protection Officer.

Hong Kong SAR

If you choose not to provide your Personal Information, you may not be able to use Orinav properly.

As a Hong Kong SAR data subject you have legal rights in relation to the Personal Information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request (to receive a copy of the data we process about you). You can also exercise your right to data correction as well as your right to stop to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Sensitive Personal Information

“Sensitive Personal Information” means passwords, financial information (such as bank account or credit card or debit card or other payment instrument details), biometric data, data relating to physical or mental health, sex life or sexual orientation, and/or medical records or history, and similar information, but does not include information available in the public domain, or provided under Indian laws, including the Right to Information Act, 2005.

Sharing of Your Sensitive Personal Information

In the circumstances enumerated in the Privacy Policy, where we permit any third parties to collect and use your Sensitive Personal Information, we shall (i) ensure that such third parties maintain the same security standards that are adhered to by us for the protection of your Sensitive Personal Information and (ii) take reasonable measures to ensure that the third parties do not further disclose the Sensitive Personal Information.

Correction of Your Personal Information & Withdrawal of Consent

If you believe we hold any other Personal Information about you or your children, and that information is inaccurate, or you have queries regarding the processing, transfer or end-use of your Personal Information, please contact our Data Protection Officer.

You do not have the right to retrospectively retract consent or request for deletion of records required for statutory purposes but can withdraw consent to any further processing of your or your children’s Personal Information.

Security Measures of Your Personal Information

In accordance with applicable data privacy laws and regulations in India, we shall take appropriate, reasonable technical and organizational measures to prevent the loss of, damage to or unauthorized access to or processing of your Sensitive Personal Information.

Age Restrictions

Indonesia

Consent

By accepting and consenting to the Privacy Policy, you agree that we may collect, use and share your Personal Information in accordance with the Privacy Policy, as revised from time to time. If you do not agree to the Privacy Policy, you must not access or use our services and we have the right not to provide you with access to Orinav.

Accuracy of Information

You are responsible for ensuring that any Personal Information which you provide to us is accurate and up-to-date. In order to confirm the accuracy of the information, we may also verify the information you provided to us, at any time.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use Orinav.

Data Subject Rights

You have the right to access, update, correct and request erasure of Personal Information stored on Orinav from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your Personal Information, we will notify you through the contact information provided by you or via Orinav, to the extent required by local laws and regulations.

Data Retention

We will retain your personal information in line with legal requirements.

Notification to Amendment of the Privacy Policy

In the event we amend this policy, we will post the updated Privacy Policy at this link and notify you via Orinav or other means before the change becomes effective.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s Personal Information (for example, for referral promotions, if applicable), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

Consent

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates or where our service providers are located.

Your Rights

You may request that we notify you about the purposes of use of, the disclosure of, any correction to, the discontinuation of the use of or provision of, and/or the deletion of any and all of your Personal Information which is stored by us, to the extent provided for by the Act on the Protection of Personal Information of Japan. If you wish to make such a request, please contact our Data Protection Officer.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, export and storage of your Personal Information as described in the Privacy Policy.

Macau SAR

You have the right not to provide your Personal Information. However, as a result, we may not be able to provide Orinav to you. As a Macau SAR data subject you have legal rights in relation to your Personal Information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your Personal Information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Parental and Guardian Consent

In the event you are agreeing to the Privacy Policy in order for a minor (a person under the age of 18) to access and use Orinav, you hereby consent to the provision of Personal Information of the minor to be processed in accordance with the Privacy Policy and you personally accept and agree to be bound by the terms in the Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with the Privacy Policy.

How We Store and Share Your Personal Information

In relation to users in Malaysia, our servers are located in the United States and you consent to the transfer of your data outside of your country.

Rights of Data Subjects

Right of access: You have the right to request access to and obtain a copy of the Personal Information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your Personal Information in the amounts permitted by law.

When handling a data access request, we are permitted to request certain information in order to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

We will comply with data access requests within the time periods as stipulated under Malaysian data protection laws.

Right of correction: You may request for the correction of your Personal Information. When handling a data correction request, we are permitted to request certain information in order to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your Personal Information: You may request limiting the processing of your Personal Information by using the contact details provided in the Privacy Policy. However this may affect our provision of Orinav to you.

Contact

To protect your Personal Information and handle complaints relating to your Personal Information, we have appointed a data protection officer, responsible for the management and safety of your Personal Information.

Mexico

Purposes of Processing

Certain of the purposes for processing stated in the Privacy Policy are voluntary, including:

to participate in beta testing programs and research studies

Data Transfer Consent

We require your consent to carry out the following transfers of data, which are detailed in the section “Who Do We Share Your Data With” in the Privacy Policy:

Map and diagnostics operators
A third party that acquires all or substantially all of us or our business.

By using Orinav and providing us with your personal data, you agree to the data transfers detailed above that require your consent.

Age Restrictions

You won’t be able to use Orinav unless you are 18 years old or you have obtained parental/guardian agreement to the Privacy Policy (both for themselves and on your behalf).

Your Rights

The sub-sections entitled “Access & Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only”, which includes the limitation to the use and disclosure of your personal data included in the section “Your Rights” in the Privacy Policy also apply to users that are located in Mexico.

You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact our Data Protection Officer.

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer.

Phillippines

Minimum Age

You must be at least 18 years of age to be able to use Orinav.

Your Rights

You are entitled to the following rights:

Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to is being, or has been processed, including the existence of automated decision-making and profiling.
Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

By consenting to this Privacy Policy, you consent to us:

collecting and processing your personal information as described in the section “How We Use Your Personal Information” in the Privacy Policy;
sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
transferring or storing your personal information in destinations outside the Philippines as described in the sections “Who Do We Share Your Data With” and “Where Do We Process Your Data” in the Privacy Policy.

Russia

If you are using Orinav from Russia:

You confirm that you are at least 18 years old.
You consent (for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations) to the processing in accordance herewith of your information. In particular, if legitimate interests, optimisation of the service, carrying out of the contract or any other purposes are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent). You also consent to the cross-border transfer of your information to any country where we have databases or affiliates or where our service providers are located and, in particular the United States.
We will not implement any material changes hereto, unless we have notified you.
You can contact our Data Protection Officer. Please include the word “Russia” in the subject line of your email.

Singapore

By clicking “accept”, you consent to the collection, use and disclosure of your Personal Information, for the purposes set out in the section “How Do We Use Your Information” in the Privacy Policy, and which we will process as an “organization” as defined under the Personal Data Protection Act 2012.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at [email protected].

Access

You have the right to access your Personal Information, how we use it, and who we share it with. You can access the Personal Information you have made available as part of your account by logging into your account. If you believe we hold any other Personal Information about you, please contact our Data Protection Officer.

Correction

You have the right to correct any of your Personal Information that is inaccurate. You can access the Personal Information we hold about you by logging into your account. If you believe we hold any other Personal Information about you and that information is inaccurate, please contact our Data Protection Officer.

South Korea

Children under the age of 14 must not use Orinav for any purpose without first obtaining parental/guardian consent to the Privacy Policy (both for the parent/guardian themself and on their child’s behalf). We do not knowingly collect Personal Information from any children under the age of 14 without such consent. Please contact our Data Protection Officer if you believe we have any Personal Information from any children under the age of 14 without such parental/guardian consent – we will promptly investigate (and remove) such Personal Information.

The Personal Information (including your personal location information) we provide to third parties located outside of Korea for the Orinav service can be found in the “Who Do We Share Your Data With” section.

The mandatory retention periods for Personal Information required by law in Korea is as follows:

Items	Relevant Statute	Retention Period
Records related to entering into and withdrawing from a contract	Act on the Consumer Protection in Electronic Commerce	5 years
Records related to payment and other supplies of money	Act on the Consumer Protection in Electronic Commerce	5 years
Records related to consumer complaints and dispute settlement	Act on the Consumer Protection in Electronic Commerce	3 years
Records related to labelling	Act on the Consumer Protection in Electronic Commerce	6 months
Service visit logs	Protection of Communications Secrets Act	3 months
Telecommunication logs	Protection of Communications Secrets Act	12 months

Destruction of Personal Information

We destroy Personal Information upon the extinguishment of need for such Personal Information, such as the expiration of its retention period and achievement of its purpose for processing, except where there is a law or regulation that requires us to retain that Personal Information.

The destruction procedure of Personal Information (including your personal location information) is as follows:

Destruction procedure : Personal Information that needs to be destroyed is destroyed in accordance with our data deletion and retention protocols under the supervision of our Data Protection Officer.
Destruction method : We destroy Personal Information recorded and saved in electronic format via methods such as Low Level Format so as to disable the reproduction thereof; and Personal Information recorded and saved in hardcopy via grinder or incineration.

Personal Location Information

Purposes for which your personal location information is processed: To provide location information-based services as described in our Terms and Conditions of Location-Based Service.

Period for retaining your personal location information: Retained for the minimum period necessary to provide you with location-based services.

Grounds for retaining the data verifying the collection, use and provision of location information and period of retaining the data: In accordance with Article 16(2) of the Act on the Protection and Use of Location Information (“Location Information Act“), we will automatically record data verifying the collection, use, and provision of location information in a location information system, and preserve the data for 6 months or longer.

Notification under the Article 19(3) of the Location Information Act: After you share your personal location information with a third party, we may be required to notify you of the relevant details (i.e. who will get the information, as well as the date, time and purpose of the sharing) via Orinav or other permitted methods.

Rights of the legal guardian of a child and methods for exercising those rights under the Article 26(1) of the Location Information Act: Where the legal guardian of any of the following persons (hereinafter referred to as “Child“):

(i) a child of eight years old or younger;
(ii) a person under adult guardianship; or
(iii) a person with a mental disorder defined in Article 2(2) 2 of the Act on Welfare of Persons with Disabilities, classified as a person with a severe disability defined in subparagraph 2 of Article 2 of the Act on the Employment Promotion and Vocational Rehabilitation of Persons with Disabilities (limited to those registered as disabled persons under Article 32 of the Act on Welfare of Persons with Disabilities);

gives consent to the use or provision of personal location information regarding the child, for the protection of the child’s health or safety, we shall deem that the child has consented to such use or provision.

For the protection of the health or safety of the child, the legal guardian who intends to consent to the use or provision of personal location information of the child must submit a written consent to us along with a document proving that he/she is the legal guardian.

The legal guardian can exercise all of the rights of the subject of personal location information if he/she agrees to the use or provision of personal location information for a child.

Contact Information of Location Information Officer:

E-mail: [email protected]

Sri Lanka

By clicking “accept”, you consent to the terms and conditions of the Privacy Policy and permit the collection, use and disclosure of your Personal Information. However, if you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use Orinav.

Where you request to withdraw consent or, refrain from further processing of data or, erase or, rectify or, complete your Personal Information, we will provide you with our response to the request within 21 working days.

Chinese Taiwan

We do not knowingly collect or solicit Personal Information from anyone under the age of 7 or knowingly allow such persons to register with Orinav. If you are under 7, please do not attempt to use or register for Orinav or send any Personal Information about yourself to us. No one under the age of 7 may provide any Personal Information to us while using Orinav. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using Orinav.

You may exercise the following rights as set forth in Article 3 of the Personal Data Protection Act: (1) access your Personal Information to check and review it; (2) have a copy of your Personal Information; (3) supplement or correct your Personal Information; (4) demand that we cease the collection, processing, or use of your Personal Information; and (5) demand that we delete your Personal Information. To the extent permitted by law, there may be limitations on our ability to comply with your request.

Thailand

By clicking “accept”, you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use Orinav.

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use Orinav.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

withdraw your consent to the processing of your Personal Information (only where the legal basis for our processing is consent); however, please note that where consent is required to process your Personal Information, we may not be able to deliver the expected service without it;
request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your Personal Information;
request us to provide you or a third party with your Personal Information which is stored by us in a machine readable format; and/or
lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us at [email protected].

Türkiye

You have legal rights, which are specified set forth Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have right to apply to the data controller and (and to the extent permitted under applicable laws and regulations):

learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the Personal Data Protection Law (Türkiye);
object to certain processing of data, and seek certain remedies in accordance with the Personal Data Protection Law (Türkiye).

United Arab Emirates

You consent to the collection, use, disclosure, export and storage of your Personal Information as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note also that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT“). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

Children

In the case of users located in the United Arab Emirates, the minimum age to be able to legally agree to commercial transactions is 21 (under the Hijri calendar). However, a minor, who is between the ages of 18 and 21 may obtain a court order giving him/her permission to engage in specific commercial transactions. In addition, a minor who is above the age of 7 years old may engage in commercial transactions subject to their guardian’s approval.

United States: California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

The CCPA provides California residents with certain legal rights such as access, deletion, disclosure, or “do not sell.” These rights are not absolute and are subject to certain exceptions.

Collection and Disclosure of Personal Information

Over the past 12 months, through your use of Orinav, we may have collected and disclosed the following categories of Personal Information from or about consumers, as defined in the CCPA:

Identifiers, such as phone number, name, alias, token, username, IP address, mobile application store user ID, mailing address, emergency contact information, and contact list. This information is collected directly from the consumer or device;
Geolocation data, including geolocation information derived from GPS coordinates, Wi-Fi access points, IP address, and public posts. This information is collected directly from the consumer or device, and we obtain consumer consent prior to collecting any “precise geolocation” data (as defined under the CCPA), which is considered “sensitive” under the CCPA;
Internet or other electronic network activity information, including your device model, network type, OS type and version, client version, call history, chat data, invitations data, call credits history, search history, log data, and survey information. This information is collected directly from a device;
Audio, electronic, visual, or similar information. This information is collected directly from the consumer; and
Other information that is described in subdivision (e) of Section 1798.80, such as nationality and gender (this information is being collected in the consumer context rather than the employer context). This information is collected directly from the consumer.

We collect Personal Information for the following purposes:

To operate and administer Orinav;
To communicate with consumers;
To improve our services;
For security and verification purposes, including to prevent and detect fraudulent activity; and
To address and remediate technical issues and bugs.

For additional information about how each type of Personal Information is used and retained, see the main portion of the Privacy Policy.

We may disclose each of the categories of Personal Information identified in the Privacy Policy to the following types of entities:

Related group companies within our corporate group who process your Personal Information in order to operate the services (as described in the section “Who Do We Share Your Data With”);
Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing Personal Information for any purpose other than for providing such services to us;
Regulators and judicial authorities and law enforcement agencies; and
Entities that acquire all or substantially all of our business.

We do not sell or share personal information and in the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” or “shared” in the CCPA. Further, we do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age.

Rights Under the CCPA

If you are a California resident and the CCPA does not recognize an exemption that applies to you or your Personal Information, you have the right to:

Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of Personal Information about you that we collected;
- the categories of sources from which the Personal Information was collected;
- the purpose for collecting Personal Information about you;
- the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
- the specific pieces of Personal Information we collected about you;
Request we delete Personal Information we collected from you, unless CCPA recognizes an exemption;
Request that we correct inaccurate personal information we maintain about you; and
Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

Please note that in order to protect your information, we will need to verify your identity before responding to any request to exercise your rights. In some cases we may need to collect additional information to verify your identity, such as a government issued ID.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, to other data by contacting our Data Protection Officer or by submitting a request here.

Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf by contacting our Data Protection Officer. For requests by an authorized agent, we may require you to directly verify your identity with us, and confirm with us that you provided the authorized agent permission to submit the request.

Other U.S. States

This section applies to U.S. residents who live in states that have comprehensive privacy laws similar to the CCPA that apply to us. If you are a California resident, please see the section above, California, for information on your rights in relation to information that we have collected about you.

Sensitive Data Collection

For certain Orinav features, such as navigation, we may collect geolocation data from U.S. residents that could be considered “precise geolocation data” under applicable U.S. state privacy laws. We do not collect such data without obtaining your consent. We may also collect information from children under the age of 13 who use Orinav, but only after obtaining parental/guardian consent.

Rights Under U.S. State Privacy Laws

Depending on the state you live in, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law, including in the event you reside in a state that does not currently grant you these rights.

Right to request that we confirm whether we process information about you and give you access to that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment;
Right to request that we delete information we maintain about you; and
Right to request that we correct inaccurate information we maintain about you.

Note that we do not process your information for the purposes of targeted advertising, profiling in furtherance of decisions that produce legal or similarly significant effects, or selling your information (as all such terms and concepts are defined under applicable U.S. state privacy laws).

How to Exercise Your Rights

You may exercise any of these rights by contacting us at [email protected]. We will not discriminate against you for exercising any of these rights. We may need to collect additional information to verify your identity, such as your email address or a government issued ID. Depending on your location, you may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

Right to Appeal

In addition, you may have the right to appeal our decision regarding a request related to these rights by contacting us at [email protected]. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Vietnam

By accepting the Privacy Policy, you expressly agree and authorize us to collect, use, store, and process your Personal Information, including, lawfully disclosing and transferring it to third parties, as described in the Privacy Policy.

We maintain international standards and security practices for data protection. When your Personal Information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.

Where we permit any third parties to collect and use your Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Personal Information.

Your Personal Information, if required to be disclosed to the competent law enforcement agencies, public authorities or other judicial bodies and organisations, will be disclosed upon receipt of written request from such organisations.

Where required by the law and regulatory requirements of your jurisdiction from time to time, we may retain all or part of your Personal Information for a period longer than described in the Privacy Policy.

You have the right to access, correct, and erase the Personal Information we hold about you. You also have the right to withdraw your consent to collect, store, process, use and disclose your Personal Information and to request us to stop processing or providing your Personal Information to a third party.