Orbit Info

Privacy

Data and wallet identity

01

Data Controller:

DeVest d.o.o. Prolaz Marije Krucifikse Kozulić 1 51000 Rijeka, Croatia Represented by Michael Hasler, CEO Email: [email protected]

For data protection inquiries, please contact us at the address provided above.

## 03 YOUR PERSONAL DATA

The information we collect ('Information') may include names, addresses, Date of Birth (including year of birth), Country of residence, financial details (bank account, credit/debit card numbers, expiry dates, wallet addresses), and email addresses. If you are a registered member, the Information includes personal details submitted to Orbit Media and details of your platform visits. We will not sell, distribute, or disclose your Information without your consent, except as required or permitted by law.

02

Purpose of Collection & Legal Basis:

We collect and process this Information for several essential purposes:

Performance of Contract (Art. 6(1)(b) GDPR): To provide the Service, manage accounts, and process transactions; Legal Obligation (Art. 6(1)(c) GDPR): To verify your age (FSK standards) and comply with international regulatory and tax reporting obligations, including the EU’s DAC8 directive and AML/KYC requirements; Legitimate Interest (Art. 6(1)(f) GDPR): To prevent fraud, maintain security, and improve our platform.

## 04 YOUR RIGHTS UNDER GDPR

As a user within the European Union, you have the following rights regarding your personal data:

1. Right of Access (Art. 15 GDPR): You can request a copy of the personal data we hold about you. 2. Right to Rectification (Art. 16 GDPR): You can ask us to correct inaccurate or incomplete data. 3. Right to Erasure ("Right to be Forgotten") (Art. 17 GDPR): You can request that we delete your data under certain conditions. 4. Right to Restriction of Processing (Art. 18 GDPR): You can ask us to limit how we use your data. 5. Right to Data Portability (Art. 20 GDPR): You can request a transfer of your data to another service. 6. Right to Object (Art. 21 GDPR): You can object to the processing of your data for specific purposes (e.g., direct marketing). 7. Right to Lodge a Complaint (Art. 77 GDPR): You have the right to complain to a data protection authority.

To exercise these rights, please contact us at [email protected].

## 05 UPDATING YOUR INFORMATION

Please notify us of any changes to the Information you have submitted. You can update your basic Information by contacting us at [email protected]

## 05 MARKETING MATERIAL

We may use your Information to notify you about important updates, changes to Orbit Media, and our terms and conditions. We may also provide you with information about our products and services. With your permission, we may allow selected third parties to contact you about relevant products and services. You can opt out of these communications by contacting us at [email protected].

We share data with third-party service providers (Processors) to operate the platform. These include:

Payment & Crypto Gateways: Transak, Revolut (for transaction processing and compliance); Invoicing & Fiscalization: Billko (for tax compliance and invoice generation); Infrastructure: Cloud and storage providers.

Your Information may be transferred to and stored outside of the EEA. We take steps to ensure adequate protection (e.g., Standard Contractual Clauses) as required by GDPR. By submitting your Information, you agree to this transfer, storage, and processing.

In the event of a merger or acquisition, your personal data may be transferred as an asset.

## 09 THIRD-PARTY PARTNERS & JOINT RESPONSIBILITY

The Service may integrate with third-party platforms such as Comparo d.o.o. for specific features (e.g., rewards or advertising). These partners may have their own independent Terms & Conditions and Privacy Policies. When you interact with these integrated services, your data may be processed by these partners as independent or joint data controllers. We recommend reviewing their respective legal documents. We are not responsible for the data processing practices of these independent third parties.

## 10 COOKIES

We may use cookies to monitor platform usage and improve our services. You can refuse cookies in your browser settings, but this may affect platform functionality. We may also use IP addresses, operating systems, and browser types to analyze usage trends, without personal identification.

## 09 INTERNET

We use security systems to protect your Information. However, Internet transmissions are not guaranteed to be 100% secure. We are not responsible for unauthorized access or loss of personal information beyond our control. Please note that emails and messages sent via the website are not secure unless encrypted.

## 10 CHANGES TO PRIVACY POLICY

We may update this Privacy Policy from time to time. The amended version will be published on Orbit Media.

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