Last modified: August, 2025 This Privacy Policy (the “Policy”) explains how Orderly Network Ltd. (“Orderly”, the “Company”, “we”, “us” or “our”) collects, uses, and shares data in connection with the your access to and use of the websites, platform, software, technologies, features, and other online products and services (collectively, the “Services”) provided or made available by Orderly. Your use of the Services is subject to this Policy as well as our Terms of Use as posted and updated on our website. Unless provided or mutually agreed otherwise, these Policy and Terms constitute a binding obligation between you and the Company. If you wish to understand more about our Terms of Use, please visit our website for further information. The Company may update the Terms at any time, in its sole discretion. If you continue the use of our Services after the Company updates the Terms, you are agreeing to be bound by the updated Terms. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

​
COLLECTION OF INFORMATION

Information You Provide to Us The categories of personal information we collect depend on how you interact with Orderly and its Services. Orderly collects information that you provide us, information we obtain automatically when you use our Services or participate in our marketing campaign, and information from third-party sources and other organizations. The types of personal information we may collect from you include, but not limited to, name, cryptocurrency wallet address and social media information (e.g: Twitter handle, Discord name), and any other information you choose to provide. Information We Collect Automatically When You Interact with Us Orderly may collect certain information automatically when you use our Services. Examples of this information include but not limited to, cookie identifiers, internet protocol (IP) address, trading volume, mobile carrier, MAC address, user settings, mobile ad identifiers, Internet service provider, browser or device information, location information and metadata about information you provide to Orderly. We may also automatically collect information pertaining to your use of our Services. Examples of this information may be related to your pages visited, links clicked, content interacted with, duration and frequency of your activities and other information about your use of our Services. Information We Collect from Other Sources We obtain information from third-party sources. For example, we may collect information about you from identity verification services, data analytics providers, mailing list providers (if applicable) and public blockchains. Additionally, our Services may allow you to provide information about your family or friends through our referral service, which allows you to forward or share certain information with Orderly. Please share information only for people that you know. Public Blockchains We obtain information from public blockchains, including the NEAR blockchain. Such information includes but is not limited to on-chain account information and transaction information. This information is used to improve the NEAR blockchain and Orderly Network mainnet, and our services and products.

​
USE OF INFORMATION

We use the information we collect to:
  • Provide, maintain, and improve our products and services;
  • Process transactions and send you related information in relation to our products and services, including but not limited to, confirmations, receipts, invoices, customer experience surveys, and recall notices;
  • Personalize and improve your experience on our Services;
  • Send you technical notices, security alerts, and support and administrative messages;
  • Respond to your comments and questions and provide customer service;
  • Communicate with you about products, services, and events offered by Orderly and others and provide news, marketing campaign and relevant information that we think will interest you;
  • Monitor and analyze trends, usage, and activities in connection with our Services;
  • Facilitate contests, campaigns, and promotions and process and deliver entries and rewards;
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, witches or illegal activities and protect the rights and properties (including intellectual properties) of Orderly and others;
  • Debug to identify and repair errors in our Services;
  • Tailor and provide you with content and advertisements;
  • Comply with our legal and financial obligations; and
  • Carry out any other purpose described to you at the time the information was collected.
Any communications we send to you will either be related to your account or will be related to our Services or products. In the event we send any communication to you which is not related specifically to your account, we will provide you with an “unsubscribe” mechanism through which you may opt out of receiving other similar messages in the future. In order to comply with legal obligations under applicable rules and regulations, we may conduct AML/CFT procedure, anti-fraud procedure, identity verification and authentication checks where applicable.

​
SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:
  • We share personal information with our affiliates, vendors, service providers, and consultants that need access to personal information in order to perform services for us, including but not limited to, companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, audit, and marketing and advertising.
  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
  • We may share personal information if we believe that your actions are inconsistent with our agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Orderly, our partners, the public, or others.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • Business changes. We may transfer or share data to another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction.
  • We also share aggregated or de-identified information that cannot reasonably be used to identify you.

​
ANALYTICS

We allow others to provide analytics services on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other Services and applications, IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Orderly and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity. SECURITY OF YOUR INFORMATION Orderly takes steps designed to treat your information securely and in accordance with this Privacy Policy. However, there is no guarantee behind the security of any information you provide us. As such, Orderly does not accept liability for any unauthorized disclosure. If we learn of any authorized disclosure of your information, Orderly may attempt to notify you electronically or by mail by posting a notice on our Services.

​
TRANSFER OF INFORMATION TO THE OTHER COUNTRIES

Orderly operates and engages service providers in various jurisdictions. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction.

​
ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you. We process your data on one or more of the following legal bases in accordance with applicable rules and regulations, including the General Data Protection Regulation (GDPR) in the EU. We process personal data for the purposes described in the section titled “USE OF INFORMATION” above. Our bases for processing your data include: (i) you have given consent to the process to us or our Service provides for one or more specific purposes; (ii) processing is necessary for the performance of a contract or our Services with you; (iii) processing is necessary for compliance with a legal obligation; and/or (iv) processing is necessary for the purposes of the legitimate interested pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Your rights under the General Data Protection Regulations (“GDPR”) include the right to (i) request access and obtain a copy of your personal data, (ii) request rectification or erasure of your personal data, (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, you may withdraw your consent to our collection at any time. Nevertheless, we cannot edit or delete information that is stored on a particular blockchain. Information such as your transaction data, blockchain wallet address, and assets held by your address that may be related to the data we collect is beyond our control. Please note that we may retain information as necessary to fulfill the purpose for which it was collected and may continue to do so even after a data subject request in accordance with our legitimate interests, including to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. Data Retention We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. Age Requirement We do not target our websites, mobile apps, API, or any of the Services for children. We do not intentionally collect information from children. If we become aware that we have inadvertently received personal data from a user under the age of 18 (or any lower age pursuant to applicable law), we will delete such information from our records.