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Last modified: August 2026 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 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, this Policy and the 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. We may update this Policy from time to time. When we make changes, we will revise the “Last modified” date above and provide additional notice where required by applicable law. We encourage you to review this Policy periodically 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. Builder Surveys and Product Feedback When you participate in a builder survey or provide product feedback, we may collect your survey responses, free-text comments, broker or DEX identifiers, account or wallet identifiers, locale, submission timestamps, outreach preferences, and optional social media or Telegram contact information. Survey responses may be associated with your Orderly builder account and are not anonymous. We use this information to understand how builders discover and use Orderly, improve our products and services, provide support, evaluate potential collaboration opportunities, and communicate with you where you have requested such communication. Providing survey responses and contact information is optional. Please do not include private keys, credentials, confidential business information, sensitive personal information, or information relating to another person in a free-text response. Where you choose to provide a Telegram handle or other contact information and agree to outreach, Orderly may contact you for product feedback, product-improvement discussions, support, or potential collaboration. You may withdraw this permission at any time by contacting Orderly support through Discord or Telegram. Do not post personal information in a public channel; continue your request in a private support conversation. 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. Such information includes but is not limited to on-chain account information and transaction information. This information is used to improve Orderly Network 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;
  • Conduct builder research and analyze survey responses and product feedback, including responses associated with builder, broker, DEX, wallet, or account identifiers;
  • Contact you for product feedback, support, product-improvement discussions, or potential collaboration where you have requested or consented to such communication;
  • 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 us or our service providers to process your personal data 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 interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. For builder surveys and product feedback, we generally rely on our legitimate interests in understanding use of our Services and improving our products and operations. Where we request permission to contact you through Telegram or another optional communication channel, we rely on your consent. You may withdraw that consent at any time without affecting processing carried out before withdrawal. Your rights under the General Data Protection Regulation (“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, where processing relies on consent, you may withdraw that consent 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. To exercise your privacy rights, request deletion or correction of your survey information, or withdraw outreach consent, contact Orderly support through Discord or Telegram. Do not post personal information in a public channel; continue your request in a private support conversation. 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. Identifiable builder survey responses and related free-text comments are retained for up to 12 months after submission, after which they are deleted or irreversibly aggregated or de-identified, unless a longer retention period is required or permitted for legal, regulatory, fraud-prevention, dispute-resolution, or compliance purposes. Optional Telegram handles and other outreach contact information are retained until you withdraw your consent or for up to 12 months after the last relevant interaction, whichever occurs first, unless continued retention is legally required. We may retain a limited record that a survey was completed, deferred, or skipped for longer where necessary to manage survey eligibility and prevent repeated requests. This limited record will not contain the survey answers or contact information. Deleted information may remain in encrypted backups until those backups expire under our normal backup-retention schedule. 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.