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Privacy Policy

Version 2.3. Effective July 2025. Last updated July 2025. This policy explains how OrbitLink Pay collects, uses, discloses, and protects personal information.

Review required: Updated from latest legal feedback. Email addresses have been corrected to the confirmed official mailboxes.
Compliance & SecurityRisk DisclosurePrivacy PolicyTerms of ServiceAML/KYC Policy
1. Personal information we collectOpen by default

OrbitLink Pay collects personal information only to the extent necessary to provide services and fulfill legal obligations.

Identity information may include name, government-issued identification document numbers such as passport, driver's license, or other valid identification, company name, registered address, and beneficial ownership information.

Contact information may include email address, phone number, and mailing address.

Financial and transaction information may include bank account information, transaction records, payment amounts, payer information, and payee information.

Technical information may include IP address, device information, browser type, and access logs.

Other information may include information required for anti-money laundering, sanctions screening, and other regulatory requirements.

2. Purposes for using personal informationClick to review

OrbitLink Pay collects and uses personal information to perform customer identity verification, KYC review, and ongoing due diligence.

OrbitLink Pay may use personal information to provide cross-border payment services, comply with FinCEN, FINTRAC, anti-money laundering, counter-terrorist financing, sanctions, and other applicable legal requirements, detect and prevent fraud, suspicious transactions, and unlawful activity, fulfill legal obligations, and respond to regulatory requirements.

3. Information sharing and disclosureClick to review

OrbitLink Pay discloses personal information only in necessary circumstances.

Regulatory and law-enforcement reporting: OrbitLink Pay may report information to FinCEN, FINTRAC, law-enforcement agencies, or other regulators where required by law.

Service providers: OrbitLink Pay may share information with third parties that provide technical support, risk-control services, payment processing, or other operating services, subject to contractual confidentiality obligations.

Business cooperation: OrbitLink Pay may share information where necessary for bank cooperation or other required business cooperation, under strict compliance requirements.

Legal process: OrbitLink Pay may disclose information in response to court orders, subpoenas, or other legal procedures.

OrbitLink Pay does not sell personal information for marketing purposes.

4. Data securityClick to review

OrbitLink Pay adopts technical and organizational measures designed to protect personal information, including encrypted transmission and storage, access control, permission management, and periodic security audits.

No system can be guaranteed to be absolutely secure.

5. Data breach noticeClick to review

If an incident occurs that may affect the security of personal information, OrbitLink Pay will notify affected users and relevant regulators within a reasonable period as required by applicable laws and regulations.

6. User rightsClick to review

Depending on applicable law, users may have rights to access, correct, or delete personal information, restrict or object to processing, and request data portability where applicable.

Users may submit requests using the contact information at the end of this policy.

7. User obligationsClick to review

Users agree to provide true, accurate, complete, and up-to-date personal information.

Users must notify OrbitLink Pay and update information within seven business days after any material change to personal information.

Users must actively cooperate with identity verification, due diligence, and anti-money laundering review, including timely submission of supplemental documents and information.

Users must ensure that transactions conducted through the platform have lawful purposes and lawful sources of funds.

If users fail to fulfill these obligations, OrbitLink Pay may refuse to provide services, suspend or terminate accounts, and report to regulators where required by law.

8. Data retentionClick to review

OrbitLink Pay retains personal information only for as long as necessary to fulfill the purposes of collection, meet legal obligations, or resolve disputes. After that period, information will be deleted or anonymized according to applicable legal requirements.

9. International data transfersClick to review

Personal information may be processed and stored in the United States, Canada, or other countries or regions. OrbitLink Pay will take reasonable measures to help ensure an appropriate level of data protection by recipients.

10. DisclaimerClick to review

To the maximum extent permitted by law, OrbitLink Pay is not liable for any direct loss, indirect loss, incidental loss, loss of profit, data loss, or any other type of loss arising from use of the platform services or this Privacy Policy.

OrbitLink Pay does not provide any guarantee of personal information security or error-free data processing. Customers use the platform services with full understanding of and responsibility for related risks.

11. Policy changesClick to review

OrbitLink Pay reserves the right to modify this Privacy Policy at any time. Updated policies will be posted prominently on the website or communicated by other reasonable means. Continued use of the platform services indicates acceptance of the updated policy.

12. Contact usClick to review

For questions about this Privacy Policy, please contact customer support at [email protected].

Business inquiries may be sent to [email protected]. Complaints, suggestions, and service feedback may be sent to [email protected].

This draft is provided for product and compliance review only. It is not legal advice and should not be published without review by qualified counsel or the responsible compliance officer.