WEBSITE PRIVACY POLICY TEMPLATE

Last updated 06 December 2021

INTRODUCTION

ORCOM US (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website [name of website.com] [and our mobile application], including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data

Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you register with the Site or our mobile application, or when you choose to participate in various activities related to the Site , such as online chat and message boards. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

Derivative Data

Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. If you are using our mobile application, this information may also include your device name and type, your operating system, your phone number, your country, your likes and replies to a post, and other interactions with the application and other users via server log files, as well as any other information you choose to provide.

Third-Party Data

Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.

Data From Contests, Giveaways, and Surveys

Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

Mobile Application Information

If you connect using our mobile application:

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s [bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

• Mobile Device Data. We may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

• Push Notifications. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:

• Administer sweepstakes, promotions, and contests.

• Assist law enforcement and respond to subpoena.

• Compile anonymous statistical data and analysis for use internally or with third parties.

• Create and manage your account.

• Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site to you.

• Email you regarding your account or order.

• Enable user-to-user communications.

• Fulfill and manage purchases, orders, payments, and other transactions related to the Site.

• Generate a personal profile about you to make future visits to the Site more personalized.

• Increase the efficiency and operation of the Site.

• Monitor and analyze usage and trends to improve your experience with the Site [and our mobile application].

• Notify you of updates to the Site.

• Offer new products, services, [mobile applications,] and/or recommendations to you.

• Perform other business activities as needed.

• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.

• Process payments and refunds.

• Request feedback and contact you about your use of the Site [and our mobile application] .

• Resolve disputes and troubleshoot problems.

• Respond to product and customer service requests.

• Send you a newsletter.

• Solicit support for the Site .

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Interactions with Other Users

If you interact with other users of the Site [and our mobile application], those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.

Online Postings

When you post comments, contributions or other content to the Site [or our mobile applications], your posts may be viewed by all users and may be publicly distributed outside the Site [and our mobile application] in perpetuity.

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Site [or our mobile application]. These companies may use information about your visits to the Site [and our mobile application] and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

THIRD-PARTY WEBSITES

The Site [and our mobile application] may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site [or our mobile application], any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site [or our mobile application].

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

• Noting your preferences at the time you register your account with the Site

• Logging into your account settings and updating your preferences.

• Contacting us using the contact information provided below

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

ORCOM US

1200 Brickell Av suite 1960

Miami , FL 33131

3056004405