1. 谁决定了您的个人数据是“如何”且“为什么”要被处理？
2. 我们会处理您的哪些个人数据？
3. 我们为何要处理您的个人数据？
4. 我们如何保护您的个人数据？
5. How long do we retain your personal data?
6. 我们与谁分享您的数据？
7. 您在GDPR下的权利
8. 加州居民信息
9. 我们隐私政策的变更
10. 如何联系我们？

When you decide to register on Oranum and use our services, we will collect some of your personal data.

Please be assured that we are fully dedicated to the protection of your personal data.

We operate our site and our services in compliance with applicable data protection laws, including the EU General Data Protection Regulation (“GDPR“) and the California Consumer Privacy Act (“CCPA“). For more information, please see Section 7 “YOUR RIGHTS UNDER GDPR“. If you are a California resident, please also see Section 8 “INFORMATION FOR CALIFORNIA RESIDENTS.“

Your privacy is important to us. We provide you with this Privacy Policy, so that you can make informed choices about the use of your data. This Privacy Policy describes how we collect, use, share, and store the personal data of visitors to our site (“Guests“) and individuals who register as members (“Members“). Please note that this Privacy Policy only applies to the personal data of Guests and Members. Personal data of broadcasters (“Broadcasters“) is governed by a separate Privacy Policy.

As used in this Privacy Policy, the term “personal data“ means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. For example, under CCPA Personal Data includes identifiers such as your real name, alias, or postal address; commercial information, including records of products or services purchased; Internet or other electronic network activity information, including, but not limited to, browsing history, and search history; and audio or video recordings. CCPA § 1798.140(o)(1).

Please read this Privacy Policy carefully. This Privacy Policy forms a part of and is incorporated into the Oranum Terms and Conditions. By using the Oranum website or any of our services you agree that the Terms and Conditions, including this Privacy Policy, forms a binding legal contract with you.

You can contact us if you have any questions about our privacy practices or about what we are doing with your personal data. We will be happy to assist you in any way we can.

您在我们的网站上访问和/或使用我们的服务，我们收集、使用、传输、以及储存您不同类型的个人数据。

The personal data we collect includes the following:

1. 您提供的个人数据

   1. Account Information

      当您在我们的网站上创建账户时，我们需要以下重要细节：

      • 一个电邮地址
      • 一个用户名
      • 一个密码

   2. 账单客服&消费者客服

      我们收集您选择与我们的账单&消费者客服团队共享的所有信息，就像：

      • 您的个人电邮
      • the services, the Expert or username associated with your request
      • your comments or opinions about an Expert
      • 您与客服团队的对话

      一般说来，当您以其它任何方式与我们沟通时，我们将收集您选择提供的任何信息。

   3. Purchasing Coins

      When you purchase coins to participate on our site, depending on the payment method you choose, we may collect and process your identification information (full name, country, ZIP code) and payment information. As regards your payment information, note that we only store the last four digits of your payment card number and the expiration year/month.

2. Personal Information from Site Use

   当您使用我们的服务和我们的网站时，我们会收集和处理有关您的某些信息。

   这意味着，当您访问我们的网站或使用我们的服务时，即使您没有创建账户或进行登录，我们也会收集某些信息，包括：

   1. 使用信息

      We collect information about your activity on our site and about how you interact with features on our site. If you are a Member, we may link this information to your personal identity (e.g. for fraud detection purposes). The data we collect includes:

      • Activity history
      • Special features used, e.g.,
        • Rated a Broadcaster
        • Added a Broadcaster to your favorites
        • Video/Voice Call with a Broadcaster
      We collect information about your conversations with Broadcasters, including:

      • Broadcaster screen name
      • Time and date of communication
      • Method of communication (e.g. Messenger etc.)

   2. 内容信息

      For technical purposes, to prevent violation of our Terms & Conditions and to defend against complaints and legal claims, we store on our system the chat logs and may review them.

      In case you turn on your camera or microphone in private chat, we never record or keep in any way your camera feed or audio. We also do not allow Broadcasters to record or capture your camera or audio feeds during private shows. Such action is prohibited on our site.

      Please note that when you are using Video/Voice Call to contact offline Broadcasters, your conversation is not recorded or stored in any circumstances. Please be advised that we are not responsible for your experience or the content of these private calls.

   3. Log Data & Device Information

      We automatically collect log data and information from/about your computer, phone or other device you use to access our services/site, including:

      • IP地址
      • Date and time you logged in
      • 查看的页面
      • 所使用的功能
      • Hardware / Software / Internet browser used
      • 所使用的操作系统/应用版本
      • Cookies / other technologies that may uniquely identify your device / browser
      如果您正在使用一台移动设备，我们可能也会收集：

      • 识别您移动设备的数据
      • 特殊设备的设置和功能
      • 位置详情
      • 应用程序崩溃和其它系统活动

   4. Cookies/其它技术

      与许多网站和应用程序一样，我们使用cookies和其它技术（例如，网络信标、网络存储）来收集关于您的设备和您活动的信息，例如您的浏览器类型和浏览器信息、您的计算机操作系统、您的IP地址、您浏览的页面、或者您使用的功能。

      对于使用本网站不需要的cookies，我们在将其放置至您的设备之前，会要求您给与明确的许可（也即，当您第一次进入我们的网站时，您的设备上显示的横条）。但请记住，屏蔽cookies可能会对您在我们网站上的体验产生负面影响。

      了解更多我们如何使用cookies以及您的选项，请查看我们的Cookies政策

      Pixels. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information over time from our websites and across different online services and use that information to provide measurement services and target ads. You can opt-out of the collection and use of information for ad targeting by updating your Facebook account ad settings or by visiting http://www.aboutads.info/choices and http://www.youronlinechoices.eu/ where you can manage your preferences. For more information on our use of these technologies, see our Cookie Policy.

3. Data Collected by Third Parties

   The following are situations where your personal data has been collected by a third party:

   1. 主播

      When discussing with our Billing Support and Customer Support teams, a Broadcaster may provide some information about you, which will be collected.

   2. External Partners' Ad Networks

      Partner ad networks help us to promote our site. They may collect information about your interactions with our ads on our behalf.

   3. Internal Partner Ad Network

      Our group manage an ad network and promotional tools/programs. Third parties affiliated partners may contact us with information about your interactions with our ads and promotional tools published/used on their sites or affiliated sites (i.e. sites with partial or full reproduction of our primary site).

4. 公开个人数据

   我们只在必要时收集您的公开信息，以防止在我们的网站出现欺诈和非法活动（当我们怀疑您使用伪造的或偷来的信用卡、当我们目睹虐童案件、或恋童癖的活动等时）。

   该数据可能包含您在诸如脸书、您的博客和/或网站等社交媒体上所分享的公开可得的数据，以及其它所有您在互联网上公开可得的数据。

   This information is always associated or combined with the data we collect through our site to finalize our investigation before reporting any fraud and/or illegal activity to the authorities. We never use publicly available data for any other purpose.

5. 特殊的数据板块

   This means data of a sensitive nature, the exposure of which would significantly impact your fundamental rights and freedoms; for example, it could be used against you for unlawful discrimination (e.g., your philosophical or religious interests/beliefs).

   When you use our site and purchase services (e.g., live cam, private chat, buy a Broadcaster surprises, etc.), we process and store sensitive information related to your activity (e.g., the Broadcaster category, the content unlocked, etc.) in order to provide you with the services you requested.

   Due to the explicit meaning of each category name (e.g. Chinese astrology, reiki, clairvoyance, angel communication, etc…), as well as the types of Broadcasters you request services from, it is possible, although not certain, that the chosen categories indicate your philosophical or religious beliefs.

   You may revoke your consent regarding this processing by contacting the Support Team as indicated in Section 10 “HOW TO CONTACT US?“. However, please note that such revocation means that you will not be able to log into your account and use the services, as we will not be able to provide you with the services without processing such information.

   We understand that the information we have about you may not explicitly reflect the reality of your life outside of the site. Your online preferences may only show a punctual interest. In order to provide you with the utmost level of data protection, we categorize such type of data as sensitive, which is highly protected and handled with the utmost care.

   Because your online philosophical or religious interests and other data related to them are essential aspects of privacy, we are maintaining very high technology security standards. We are regularly proceeding with controls and assessments of our security measures, to guarantee a trustworthy environment.

我们收集并使用信息，是基于以下目的：

1. 账号激活

   1. Basic information

      We primarily use the data you give us when creating your online account to open and manage this account. The account then allows you to use features, buy coins and benefit from and paid services.

      Your account will also allow you to exercise control over your personal data. Through your account, you can manage your purchases, benefit from special offers, and manage your account settings.

      We process this information to perform the contract that we have with you and provide you with the services you request. If you fail to provide the minimum details required, we will not be able to create your account and allow you to use our services.

2. 改善并推广我们的服务

   To understand how we can improve our services and find better ways to promote our services to others, we collect your personal data for the following purposes:

   1. Analytics & Statistics

      We use the information you provide us with and that we collect ourselves to detect general trends regarding the preferences/habits of our users. This helps us to generate statistical reports on our customers' activity including those based on country and purchases. The information in these reports is in aggregate form and cannot be used to identify individuals.

   2. Improvements

      We use your data for testing, troubleshooting and improving the functionality and quality of our online entertainment services. Our main goal is to optimize our site and services, making them easier and more enjoyable to use.

      We also use your log data to provide search functionality and display the results of your search. In order to make our services useful, the rank and the relevance of the results obtained may be improved based on attributes we determined (e.g. the newest content published by Broadcasters, the live status of Broadcasters).

   3. 促销

      As mentioned in Section 2.3 , we have external partners who help us to promote our sites.

      We process this information with the legitimate interest of developing and improving our site and users' experience, as well as promoting our site and services.

      When we use cookies or similar technologies for the same purpose (i.e. product enhancement/improvement/promotion), we rely on your consent to the use of cookies, including third party cookies.

      To learn more about how we use cookies, and your choices, please check out our Cookie Policy.

3. Customer Relationship Management

   客户关系管理是所有服务的关键，同时也包括在这个条款中，我们与您的所有联系。以下是我们收集和处理您个人数据的相关实例：

   • Customer Support & Billing Support

     Customer Support and Billing Support operates 24/7. By sharing your personal data with our Customer Support and Billing Support teams, we will be able to provide you with your answers, and any help you may require, more efficiently.

     All your communications with the teams and any information you provide, including comments about our Broadcasters, are stored and reviewed so that we may respond to your request. This way we can ensure the full compliance of all users with our Terms & Conditions.

     与您的一些通信记录将用于消费者客服和账单客服团队的培训，以便我们能为您提供优秀的客户服务。

     请注意，我们的消费者客服和账单客服团队，将有权获得所收集的有关您的所有信息。有了这个权限，我们可以确保我们的客户支持和账单支持团队，拥有他们所需要的一切，从而为您提供适当和有效的回应。

     请注意，消费者客服和账单客服将视情况，使用各种方式联系您，包括电子邮件和电话。

   • General exchanges

     Please note that we may contact you through emails or other appropriate means, to inform you of any changes regarding our site or announcements relating to your subscription (e.g., successful account creation).

     We have a legitimate interest in improving our users' experience and delivering appropriate customer services to you.

4. 支付

   我们使用您的身份信息和支付信息来处理交易。这可能取决于您选择哪种支付方式，但大多数方法如此。

   Please note that depending on the payment method you choose, your payment will be processed by affiliates of our group or third party payment processors/service providers as explained in section 6.5 “Payment providers and financial institutions".

   在这种情况下，您的个人数据的使用是绝对必要的，以便执行任何付款并向您提供您已购买的点数或服务（即，履行我们与您签订的合同）。

5. 确保安全可靠的环境

   为保障您和我们的业务，我们会以下列方式使用你的个人数据：

   • 检测及防止欺诈/非法活动。
   • 检测潜在的违反我们条款及其细则、以及与任何其它相关的规则
   • 用于安全&风险评估（例如，身份的认证&验证）

   我们有合法的利益保证您和我们的业务安全，并确保遵守T&Cs/规则，目的就是试图保证这一点。

6. 市场/信息的消息

   一般而言，当您注册并使用我们的网站时，我们会向您发送有用的消息和市场信息，以使您及时了解我们的新功能和/或服务的发布、特别促销、优惠、等等......

   To evaluate the success of our marketing initiatives, we may pseudonymize your email address and use it to generate statistics. These would be in the form of aggregated data, not personal information (e.g., number of users per country who receive marketing communications).

   Your email will be further used to send survey participation requests, so that we learn more about your experience and satisfaction or suggestions for improvements to our service.

   We have a legitimate interest in keeping you informed and in the outcome of our marketing campaigns. You can, of course, unsubscribe from receiving our marketing and informative emails at any time, using a link contained within the emails themselves. You can also opt-out contacting the Support Team as indicated in Section 10 “HOW TO CONTACT US?“. However, this may mean that you miss out on special offers and information regarding new services.

7. 符合任何法律要求并执行我们的合法权益

   我们可能依赖法律义务处理您的个人数据。例如，我们必须保留您的交易信息，以维护法律要求的会计记录。

   We may also use your information to respond to requests from competent authorities or given our legitimate interest to establish, exercise or defend legal claims. If necessary, we would use your data to investigate issues with the relevant bank processing your payment, or with a debt collector, in cases of unpaid transactions, chargebacks or refunds.

   We may also combine your data with information lawfully obtained from other third-party sources, for the above purposes.

We implement various security measures, technical and organizational, to ensure the protection of your personal data against unauthorized access, modification, disclosure or deletion.

We periodically test our IT systems, conduct penetration tests and implement data loss prevention systems against leakage, theft and data breach.

Our site incorporates reasonable security technologies in order to ensure the safety of its users and the safekeeping of their related information.

We do not normally retain personal data of Guests for more than ten to fifteen days, though this period is typically shorter (depending on traffic volume). Any information collected to verify your identity in connection with a request (e.g., a request to access your data) will only be kept for a short time, typically no more than five days. Otherwise, we will retain your personal data for as long as we consider it necessary:

1. Provision of Services

   让我们能够向您提供我们的服务，并让您可以享受服务，包括维护您的会员账户。

2. Legal Obligation Compliance

   For example, we may keep some of your information for tax, legal reporting and auditing obligations. Please note that in accordance with Luxembourg legislation, financial information will be kept for a minimum period of 10 years (even though shorter retention periods may apply as the case may be).

3. Legitimate Interests and Business Conduct

   包括：

   • 建立、行使或辩护法律诉讼

   • Chargeback prevention:

     从您在网站上前一次的购买之日起算，我们保留您的聊天日志和日志数据、设备及使用信息，最多120天。

   • Fraud/illegal activity detection and prevention:

     我们在一定时期内将所有以前的用户名列入黑名单；在此期间，这些用户名将不能用于新的注册。

   • Enhancing safety:

     例如，如果我们因欺诈或非法活动而暂停或关闭您的账户，我们可能会保留您的某些信息，以防止您今后再开立新账户。如果正在进行司法程序和/或调查，这些信息也将会被保留。

4. Security

   正如我们所说，保护您的信息和我们的站点免受意外或恶意的损失和破坏，是我们的首要任务之一。

   您的部分个人信息的剩余副本将在我们的备份系统中保存30天。

   Some anonymized copies of your information (e.g. log records) may also remain in our database.

   If you have a question about any specific retention periods of certain personal data, please contact us via the contact details provided in Section 10 “HOW TO CONTACT US?

1. 主播

   Your account with us secures your ability to benefit from and purchase services from the Broadcasters.

   The following information about you is automatically available to Broadcasters with whom you interact:

   • Your username: Broadcasters will be able to reach you out by searching your username
   • If they are one of your favorites: Broadcasters will be able to see a special icon and your username in their account, if you added them in your list of favorites
   • If you sent them a surprise
   • Coins you spent on them (every Broadcaster will be able to see the coins you spent on them, not on other Broadcasters)

   • Additional information:

     You can choose to share other information about yourself with the Broadcasters (e.g., gender, age, location, interests, etc.). You may also connect your camera in private chat to visually communicate with the Broadcaster or simply turn on your microphone. As a reminder, the Broadcaster is not allowed to record the video or voice data you provide.

   • Video/Audio in Private Chat:

     Please note that no one can access your video feed or audio feed should you decide to turn on your camera or microphone during private chat (see clause 2.2: “Content Information“).

   • Video/Audio Offline Calls:

     As a reminder, your communication is this instance is completely private. Please note that no one can access your video feed or audio feed should you decide to turn on your camera or microphone during private chat.

   • Voluntary Sharing:

     If you decide to share additional content with the Broadcasters (e.g. pictures), please note that you are fully responsible for the sharing of such information and we cannot be held responsible for any disclosure that you freely made.

2. Other Users & the Public

   1. 评论

      If you post comments on a Broadcaster's Live content, other users will see them.

      Please be aware that your comments might be seen by other Members watching the Live session.

      As well, please be assured that, if you decide to send a private message to the Broadcaster, other users of our site will not be able to access any information about you from the moment you enter into private chat but it will be visible only to him/her.

3. Entities of Our Company's Group

   We share your personal information with the following companies of our group based in Luxembourg, Hungary and the US, as the case may be, as they are helping us to deliver our services to you:

   • Jasmin Holding SA, 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
   • 卢森堡大公国，卢森堡市，John F. Kennedy大街，44号，Docler服务有限责任公司；
   • 卢森堡大公国，卢森堡市，John F. Kennedy大街，44号，Docler IP有限责任公司；
   • Jasmin SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
   • 匈牙利，布达佩斯，世博空间5-7, H-1101，Jasmin IP有限责任公司匈牙利分公司；
   • 匈牙利，布达佩斯，世博广场5-7号，H-1101，Docler服务Kft公司
   • Docler LA LLC, 10811 Washington Blvd, Culver City, CA 90232, USA;
   • Escalion S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
   • Duodecad IT Services S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.

4. 服务供应商

   We use carefully selected and trusted third parties, who act as service providers/processors to our site.

   We ensure that they are bound by contractual obligations to process information we share with them in accordance with our instructions, this Privacy Policy, and all applicable data protection laws.

   As we constantly work on the development and enhancement of the technology to support our site, our third-party processors may regularly change.

   Such entities mainly operate in the following areas:

   • 商业智能与分析
   • Marketing & sales
   • 客户服务
   • 欺诈预防

5. Payment Providers & Financial Institutions

   When you purchase coins, depending on your choice of payment method, a third-party bank or a payment processor may process your payment. If this is the case, you may need to share personal data with them in order to complete the transaction.

   您可能会收到来自该方的交易电子邮件以确认订单，包括急件、可能的退款、以及为该实体留下反馈的后续邀请。

   This Privacy Policy does not govern the processing of your personal information by these third parties if it was shared directly with them.

   1. 信用卡/借记卡

      If you choose to pay by credit/debit card, your transaction will be handled by Escalion S.à r.l. which is one of our affiliated companies located in Luxembourg (see Section 6.3, “Entities of Our Company's Group“). You can find its privacy policy here.

   2. 退款

      If you, or the credit card holder, request a chargeback, in certain circumstances we have to share some information about you and your use of our services with the processing bank, financial institution, payment processor, the credit card holder or any relevant third party.

   3. Fraud Detection & Prevention

      We may share information with relevant financial institutions if we consider it strictly necessary for fraud detection and prevention purposes.

6. Law Enforcement Agencies & Governmental Authorities

   To the extent permitted by applicable laws, we may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary for the following:

   • 遵守我们的法律义务
   • Respond to information requests for fraud investigations and other alleged illegal activities
   • Enforce and administer our terms and conditions
   • Protect our rights and defend ourselves against any claims

7. 商业传输

   Your information may be transferred to another entity of our group (i.e. as a result of reorganization, restructuring, etc.) or third party (i.e. as a result of sale, merger and/or acquisition, etc.) if part (more than 50%) or whole of the business (or related assets) is either directly or indirectly transferred or falling under the control of the new owner.

   如果新的持有者与我们从事相同或类似的业务，并承诺遵守本隐私政策，则情况将会如此。

1. 关于将您的个人数据转移到欧洲经济区以外的信息？

   As we are a Luxembourg based company, we comply with the EU Data Protection Regulation, “GDPR“. Regardless of whether you are located in Europe or elsewhere, our own location in Europe requires us to comply with GDPR. You can read the entire Regulation here.

   During the course of operation and exploitation of the site and provision of services, your personal information may be transferred outside of the European Economic Area (“EEA“) to third party data processors, located in the United States and other countries, for the purposes specified in this Privacy Policy.

   If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.

2. 您对个人数据的权利是什么？

   我们的客服团队，在接收到您要求的当日的一个月内，向您提供信息。只有在特殊情况下，当我们面对复杂或大量的要求时，我们可能会延长这一反映时间至其后的两个月。

   请注意，行使权利是免费的。无论如何，毫无根据的或过分的请求，尤其是因为他们反反复复的性格，都将会导致支付一笔费用。

   也请您理解，因为我们认为您的隐私非常重要，我们的客服团队可能需要充分地验证您的身份信息，因此在执行您的需求前，需要您提供额外的信息。

   1. Data Access

      You have the right to access the personal data we hold about you. You can request a copy of your personal data, free of charge. To exercise this right, you can send an email to privacy@oranum.com.

      在确认您的身份后，您的要求将被发送至我们的客服团队。

      如果我们认为您的要求明显没有根据或者比较过分（例如，由于短时间内多次要求），我们可能拒绝采取行动，或者考虑到向您提供信息的行政成本，而收取合理的费用。

   2. Data Portability

      Please note that the following is separate from the right to access your data.

      In certain cases, you are entitled to request copies of your personal information in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

      For clarification, only the following information can be made available:

      • The data actively and knowingly provided by you (e.g., e-mail address, username, etc.)
      • The observed data provided by you by virtue of the use of the service or the device (e.g., your search history, traffic data and location data).

      To exercise this right, you can send an email to privacy@oranum.com.

   3. 纠正不准确或不完整的数据

      您有权要求我们纠正您个人数据中的任何不准确之处。

      For this purpose, you can contact our Customer Support or send an email to privacy@oranum.com.

   4. 数据擦除

      If you no longer want us to use your personal data, you can request that we erase it and close your account. Requests for account cancellation or closure will be considered as a request for the erasure of your personal data. To exercise this right, you can send an email to privacy@oranum.com.

      Your request will then be sent to our Support Team who will contact you. However, if you face any difficulties, please contact us at any time.

      For avoidance of a doubt, when the erasure process starts (notably upon a successful verification of your identity as the owner of the account), you will no longer be able to log in to our site (Oranum.com).

      另外，如果您的账户停止使用超过一（1）年，我们有权终止您的账户，并根据我们的条款及其细则，删除您的数据。

      Please note that even if you request the erasure of your personal information, we will retain some of it for as long as we consider it necessary for compliance with our legal obligations or other legitimate interests as explained above in Section 5. “HOW LONG DO WE RETAIN YOUR PERSONAL DATA?“.

   5. 拒绝的权利

      We process your data for a variety of reasons (see Section 3: “WHY DO WE PROCESS YOUR PERSONAL DATA?“).

      Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on a legitimate interest. If you object to such processing, we will stop processing your personal data for those purposes.

      In specific situations, we may have to refuse the execution of your request. This would only be in the cases where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

      Please keep in mind that objecting to certain uses of your data may disable the use of your account.

      Please also remember that you may unsubscribe from receiving our marketing and informative emails at any time, using a link contained within the emails themselves. You can also opt-out contacting the Support Team as indicated in Section 10 “HOW TO CONTACT US?“.

   6. 限制加工权

      You have the right to request that we stop processing your data, while we resolve any issues.

      这只有在以下四种情况下才有可能：

      1. Accuracy

         If you contest the accuracy of your personal data, processing would be stopped while we verify your claim.

      2. Legitimate Interest

         If you object to a processing activity based on a legitimate interest, you can require the processing operation to be put on hold while we verify your grounds for objection.

      3. Unlawful Processing

         You can request the restriction of data processing if you consider your data is being processed unlawfully, but do not wish for your data to be immediately erased.

      4. Data Storage

         You can request us to store your data, if you require it to establish, exercise or defend any legal claims, and we have no further need of it.

         Despite your request, we may continue to process your data, if we have to establish, exercise or defend legal claims. We will notify you before lifting any restriction.

   7. Right to Lodge a Complaint with a Supervisory Authority**

      If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with the relevant supervisory authority (i.e. your local authority or the CNPD).

如果您是加州居民，除本隐私政策中概述的其它任何权利外，您还享有加州消费者隐私权法案（“CCPA”）规定的下列特殊权利。

请注意，我们不会“出售”您的个人数据，正如CCPA中定义的那样。

1. 您“了解”和要求删除的权力

   您有权知道我们所收集的有关您个人数据的类别和具体部分。您有权知道所收集个人数据的来源类别、收集或出售个人数据的商业或商务用途、以及与我们共享个人资料的第三方类别。

   You also have the right to request deletion of personal data we've collected or maintain. Please note this right is subject to certain exceptions, including without limitation our retaining information as necessary to protect against malicious, deceptive, fraudulent, or illegal activity, to comply with our legal obligations, and for other internal purposes.

   To exercise these rights contact us as provided in Section 10 “HOW TO CONTACT US?“ below. Please note that any requested disclosures in connection with a request to know will only apply to the 12-month period preceding the request, and you are entitled to request disclosure twice in any 12-month period. You may also ask for your data to be provided or exercise your right to delete by deleting your account.

2. 个人信息披露

   You also have the right to know what categories of personal data we've disclosed for a business purpose, and the third parties to whom that information was disclosed.

   In the past 12 months, we've disclosed for a business purpose and for different products the following categories of information to the following parties: Usage/device information (including, without limitation, your IP address, as the case may be) to our business intelligence and analytics service providers (e.g., Hotjar, Google Analytics); Payment/transaction data to our customer/payment service providers; Contact information, device/usage information (including, without limitation, your IP address and the website you are coming from, as the case may), information relating to the purchase made (excluding any data relating to your mean of payment, such as credit card information) and information as regards your interactions with the emails we sent to our marketing and sales partners (e.g. Emarsys, marketing partners promoting our site); and identification information, contact information, device and usage information, payment information (as the case may be) to our antifraud service providers and auditing service providers.

3. 您不受歧视的权利

   您有权在行使CCPA所授的隐私权时，不受到歧视性的对待，包括但不限于，拒绝为您提供服务、收取不同的价格或费率，或向您提供不同水平或质量的服务。然而，请注意，您行使的部分权力（例如，删除您的数据）可能使我们无法继续为您提供服务。

4. 您使用授权代理的权力

   You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided in Section 10 “HOW TO CONTACT US?“ below. In order to verify you have authorized an agent we may require a signed, written authorization from you.

5. 禁止跟踪

   有些浏览器有“禁止跟踪”的功能，可以让您告诉网站您的在线活动不想被跟踪。由于这些功能还未统一，因此我们目前不响应“禁止跟踪”的信号。然而，我们将把“禁止出售”或类似的信号，作为CCPA下的退出请求。

我们可能会不时修订本隐私政策，以反映我们的服务以及我们处理您个人数据的方式的变化、或者所适用的法律的变化。

如果我们有任何重要的变更，我们会在相关网站上发布通知，并/或通过电子邮件等其它方式直接联系您。

在适用法律允许的范围内，这些变化从他们在我们网站上发布时开始生效，除非我们指定了一个生效日期。从那天起您继续使用我们的网站将必须遵守新的隐私政策。

if you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to privacy@oranum.com or by mail to the address indicated below, and we will get back to you as soon as possible.

we are also happy to inform you that we have an employee dedicated to ensuring your privacy, our data protection officer. you can directly reach our data protection officer via email at: dpo@oranum.com or mail to the following address: