Privacy policy

Effective Date: 09.12.2025
Last Updated: 09.12.2025

1. Introduction

Welcome to OROKAI. We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information when you use our software platform and services. We will never sell your personal information to third parties.

What OROKAI Is:
OROKAI is a non-custodial software layer that helps you prepare and authorize blockchain transactions. We do not hold your funds, control your private keys, or execute transactions on your behalf. You maintain full control over your assets at all times.

What This Policy Covers:
This policy applies to information we collect through our website, web application, mobile app, and APIs (collectively, the "Services").

2. Information We Collect

We practice privacy-by-design and collect only the minimum information necessary to provide our Services.

2.1. Information You Provide

  • Account Information: Email address, display name, language/region preferences

  • Wallet Addresses: Public blockchain addresses you connect (these are already public on blockchain networks)

  • User Preferences: Risk tolerance settings, preferred chains/assets, notification preferences

  • Support Communications: Information you provide when contacting our support team

2.2. Information Collected Automatically

  • Usage Data: Pages visited, features used, transaction intents created (not finalized transactions)

  • Device Information: Browser type, IP address, device identifiers, operating system

  • Performance Metrics: Load times, error rates, feature usage patterns (aggregated and anonymized)

2.3. Information from Third Parties

  • Blockchain Data: Public transaction data visible on blockchain networks

  • Partner Services: When you use licensed partners for fiat on/off-ramp or card services, they conduct their own KYC/AML under their privacy policies. We receive only transaction status updates—never sensitive payment data (PAN/CVV)

2.4. What We Do NOT Collect

  • Private Keys: Never collected, stored, or accessed

  • Seed Phrases: Never collected or stored

  • Payment Card Details: PAN/CVV are processed exclusively by licensed partners, never by OROKAI

  • Transaction Signatures: We prepare transactions; you sign them in your own wallet

3. How We Use Your Information

We use collected information to:

  • Provide Services: Prepare transaction intents, display routes and costs, generate informational recommendations

  • Improve User Experience: Optimize interface, personalize content (language, preferences), enhance accessibility

  • Ensure Security: Detect fraud, prevent abuse, monitor system health, enforce geographic restrictions

  • Communicate: Send service updates, security alerts, feature announcements (you can opt out of marketing communications)

  • Comply with Legal Obligations: Respond to lawful requests, enforce Terms of Service, implement sanctions/geo-restrictions

  • Research & Development: Improve AI recommendations, optimize routing algorithms (using aggregated, anonymized data)

Informational-Only Basis:
AI-generated recommendations are informational suggestions based on your declared preferences. They are not investment advice and do not trigger automatic execution.

4. How We Share Your Information

We do not sell your personal data. We share information only in these limited circumstances:

4.1. With Service Providers

We work with trusted vendors for:

  • Cloud infrastructure (hosting, databases)

  • Analytics and monitoring (observability tools)

  • Customer support platforms

  • Communication services (email, notifications)

  • KYC/AML providers (via licensed partners) - where required for unlocking specific platform capabilities

These providers are contractually bound to protect your data and use it only for specified purposes.

4.2. With Licensed Partners

When you use:

  • Fiat On/Off-Ramp: Licensed payment providers conduct KYC/AML under their own policies

  • Card Services: Card issuers/processors handle PCI DSS compliance and transaction processing

We share only operational data (transaction status, amounts in aggregate) — never your private keys or payment credentials.

4.3. For Legal Compliance

We may disclose information when required by law or to:

  • Comply with subpoenas, court orders, or regulatory requests

  • Enforce our Terms of Service

  • Protect rights, property, or safety of OROKAI, users, or the public

  • Implement sanctions and geographic restrictions

4.4. Business Transfers

If OROKAI is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you and ensure continued privacy protection.

4.5. With Your Consent

We may share information for other purposes with your explicit consent.

5. Data Security

We implement industry-standard security measures:

  • Encryption: Data in transit (TLS/mTLS) and at rest

  • Access Controls: Role-based access, multi-factor authentication, principle of least privilege

  • Secrets Management: KMS/HSM for integration credentials (never for user keys)

  • Regular Audits: Smart contract audits, security assessments, penetration testing

  • Incident Response: Documented procedures for breach detection and notification

Your Responsibility:
Since OROKAI is non-custodial, you are responsible for securing your wallet, private keys, and seed phrases. We cannot recover lost keys or reverse transactions.

6. Data Retention

  • Account Data: Retained while your account is active and for a reasonable period afterward for legal compliance

  • Usage Logs: Aggregated metrics retained for analytics; detailed logs retained per operational needs (typically 90 days)

  • Transaction History: On-chain data is permanent and public on blockchains; off-chain metadata follows our retention schedule

  • Deletion Requests: You may request data deletion (see Your Rights below), subject to legal retention requirements

7. Your Rights

Depending on your jurisdiction, you may have rights including:

  • Access: Request a copy of your personal data

  • Rectification: Correct inaccurate or incomplete data

  • Erasure: Request deletion of your data (subject to legal obligations)

  • Portability: Receive your data in a structured, machine-readable format

  • Objection: Object to certain processing activities

  • Restriction: Request limitation of processing

  • Withdraw Consent: Where processing is based on consent

Exercising Rights:
Contact us at privacy@orokai.com We will respond within applicable legal timeframes.

Limitations:
We cannot delete public blockchain data (which exists outside our control) or data required for legal compliance.

8. International Data Transfers

OROKAI operates globally. Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards through:

  • Standard contractual clauses

  • Adequacy decisions by relevant authorities

  • Other legally compliant transfer mechanisms

9. Children's Privacy

Our Services are not intended for individuals under 18 (or the age of majority in your jurisdiction). We do not knowingly collect data from children. If we learn we have collected such data, we will delete it promptly.

10. Cookies and Tracking Technologies

We use cookies and similar technologies for:

  • Essential Functions: Authentication, security, preference storage

  • Analytics: Understanding usage patterns (anonymized/aggregated)

  • Performance: Monitoring and improving Service reliability

Your Choices:
You can manage cookie preferences through your browser settings. Disabling essential cookies may affect Service functionality.

Do Not Track:
We respect browser DNT signals where technically feasible.

11. Third-Party Links and Services

Our Services may contain links to third-party websites, protocols, or applications (DEX, bridges, lending platforms). We are not responsible for their privacy practices. Review their policies before interacting.

12. Geographic Restrictions and Sanctions Compliance

Certain features may be unavailable in specific jurisdictions due to legal restrictions. We implement:

  • IP-based geo-blocking

  • Sanctions screening (OFAC and equivalent lists)

  • Feature flags based on regulatory requirements

Prohibited Conduct:
Do not use VPNs or other methods to circumvent geographic restrictions. Violations may result in account suspension.

13. Updates to This Policy

We may update this Privacy Policy to reflect:

  • Changes in legal requirements

  • New features or Services

  • Improvements in privacy practices

Notification:
We will notify you of material changes via email or prominent notice in the Services. Continued use after changes indicates acceptance.

14. Contact Us

For privacy questions or to exercise your rights:

Email: privacy@orokai.com

Complaints:
You have the right to lodge a complaint with your local data protection authority.

By using OROKAI, you acknowledge that you have read and understood this Privacy Policy.