We respect your privacy

1. 1. Operations Tech Limited BVI Company Number 2174463 (“we”, “us”, “our”, “Opteq”), a company registered in the British Virgin Islands with its registered office address at Jayla Place, 2^nd Floor, Road Town, Tortola, BVI VG1110, respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors in accordance with the laws of the British Virgin Islands relating to data protection (“DPL”).  This policy sets out how we collect and treat your personal information as a data controller under the DPL.
   2. We comply with the DPL and maintain data protection standards that meet or exceed its requirements.
   3. “Personal information” is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.
   4. You may contact us via [email protected] for further information about this Privacy Policy.
2. What personal information is collected
   
   1. We do not store any personal information you submit for the purpose of creating a login.  This information will be passed on and stored securely with the Third-party authentication platform to which we will have access as required.
   2. Personal information collected will include your email, password and public passkey.
   3. We may also collect any other information you provide while interacting with us via email or via a contact form.
3. How we collect your personal information
   
   1. We collect personal information via a Third-party platform when you use the Opteq Application, additionally, data information is collected when you access our website and when we engage in business activities with you. We may receive personal information from third parties.  If we do, we will protect it as set out in this Privacy Policy.
   2. By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy.
4. How we use your personal information
   
   1. We will use personal information only for the purposes that you consent to.  This may include to:
      
      1. provide you with products and services during the usual course of our business activities;
      2. administer our business activities;
      3. manage, research and develop our products and services;
      4. provide you with information about our products and services;
      5. communicate with you by a variety of measures including, but not limited to email; and
      6. investigate any complaints.

If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our website.

1. 1. We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.
   2. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.
2. Disclosure of your personal information
   
   1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.
   2. If we do disclose your personal information to a third party, we will protect it in accordance with this privacy policy.
3. Data Protection
   
   1. We will comply with the principles of data protection set out in the DPL for the purpose of fairness transparency and lawful data collection and use including:
      
      1. Maintaining appropriate technical and organizational measures to protect personal data;
      2. Only transferring personal data outside the British Virgin Islands in compliance with the DPL’s requirements for international transfers;
      3. Promptly notifying the other party of any personal data breach; Cooperating with the relevant authorities of the British Virgin Islands and responding to data subject rights requests in accordance with the DPL;
   2. Maintaining records of processing activities as required under the DPL.
   3. We shall ensure we has valid legal grounds under the DPL for processing any personal data disclosed to or received from you.
   4. We process your personal information as a Data Controller and/or Data Processor as defined in the DPL.
   5. We must establish a lawful basis for processing your personal information.  The legal basis for which we collect your personal information depends on the data that we collect and how we use it.
   6. We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose.  Your data will be kept safe and secure.
   7. We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.
   8. We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
   9. We do not collect or process any sensitive personal data (as defined in the DPL from you, including but not limited to information relating to your sexual orientation, ethnic origin, political opinions, religious beliefs, or health information, unless we have obtained your explicit consent or are otherwise permitted to do so under the Data Protection Law.
   10. You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.
4. Your rights under the DPL
   
   1. If you are an individual residing in the British Virgin Islands, you have certain rights under the DPL as to how your personal information is obtained and used.  We comply with your rights under the DPL regarding how your personal information is used and controlled.
   2. Except as otherwise provided in the DPL, you have the following rights:
      
      1. to be informed how your personal information is being used;
      2. access your personal information (we will provide you with a free copy of it);
      3. to correct your personal information if it is inaccurate or incomplete;
      4. to delete your personal information (also known as “the right to be forgotten”);
      5. to restrict processing of your personal information;
      6. to retain and reuse your personal information for your own purposes;
      7. to object to your personal information being used; and
      8. to object against automated decision making and profiling.
   3. Please contact us at any time to exercise your rights under the DPL at the contact details in this Privacy Policy.
   4. We may ask you to verify your identity before acting on any of your requests.
5. Hosting and International Data Transfers
   
   1. The hosting facilities for our website are situated in United States of America.  Transfers to each of these countries will be protected by appropriate safeguards under the DPL, including but not limited to standard contractual clauses approved by the Ombudsman or other lawful data transfer mechanisms recognized under the DPL.
   2. The hosting facilities for our website are situated in United States of America.  Transfers to each of these countries will be protected by appropriate safeguards, these include one or more of the following:

1. the use of standard data protection clauses adopted or acceptable under British Virgin Islands Law;
2. the use of binding corporate rules, a copy of which you can obtain from Optech’s Data Protection Officer.

1. 1. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world.  We cannot prevent the use (or misuse) of such personal data by others.

1. Security of your personal information
   
   1. We are committed to ensuring that the information you provide to us is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
   2. Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the DPL and that have adequate technical and organizational measures in place to protect personal information against unauthorised use, loss and theft.
   3. The transmission and exchange of information is carried out at your own risk.  We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
2. Access to your personal information
   
   1. You may request details of personal information that we hold about you in accordance with the DPL. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected].  We will respond to your request in accordance with the requirements and timeframes set out in the DPL.
   2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the DPL or any other applicable law.
3. Complaints about privacy

If you have any complaints about our privacy practices, please send details of your complaints to [email protected]. You have the right to file a complaint with the relevant authorities of the British Virgin Islands, who oversees data protection matters in the British Virgin Islands.  We take complaints seriously and will respond.

1. Changes to Privacy Policy

Please be aware that we may change this Privacy Policy in the future.  We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

1. Website
   
   1. When you come to our website (opteq.app), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc.  This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
   2. We may from time to time use cookies on our website.  Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site.  Cookies are not malicious programs that access or damage your computer.  Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings.  However, this may prevent you from taking full advantage of our website.  Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords.  These ads may appear on this website or other websites you visit.
   3. Our site may from time to time have links to other websites not owned or controlled by us.  These links are meant for your convenience only.  Links to third party websites do not constitute sponsorship or endorsement or approval of these websites.  Please be aware that we are not responsible for the privacy practices of other such websites.  We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

Effective date

This policy is effective from July 2025.