Orbit App, Inc. and its affiliated entities ("Orbit," "we," "us," or "our") are committed to respecting your privacy and protecting the personal information you share with us when using our websites (including orbit.org), applications, and other services that link to or reference this Privacy Policy (collectively, the "Services"). This Privacy Policy outlines how we collect, use, share, and secure your personal data and what choices you have regarding that information.

By accessing or using the Services, you agree to the practices described in this Privacy Policy. If you do not agree, you should not use the Services. Additionally, the Terms of Service govern your use of the Services and are incorporated by reference.

1. Our Approach to Privacy

As a non-custodial software wallet provider, Orbit does not host customer accounts, nor do we require users to submit personal data to access the core functionalities of our wallet. However, certain limited interactions—such as newsletter sign-ups, job applications, customer support inquiries, or third-party integrations—may involve the collection of personally identifiable information ("Personal Data"), which refers to information associated with a specific individual or device that can be used to identify them.

2. Information We Collect

We may collect the following categories of Personal Data through your use of our Services:

2.1 Information You Voluntarily Provide

When you directly interact with us—for example, by subscribing to our newsletter, submitting a support ticket, or applying for a job—we may collect details such as your name, email address, and any content included in your message or application.

2.2 Automatically Collected Data

When you access our websites or applications, we automatically gather information including IP address, device type, operating system, browser version, access times, referring URLs, pages viewed, clicks, session duration, and other usage data.

2.3 Cookies and Similar Technologies

We and our service providers may use cookies, pixel tags, and similar tracking technologies to gather data about your use of the Services. These technologies help us analyze trends, remember user preferences, and improve functionality. Cookies may be session-based (deleted when you close your browser) or persistent (retained until manually deleted or they expire). You can control or block cookies via your browser settings. Some functionality may be limited if cookies are disabled.

Types of cookies we use:

• Functional Cookies: Remember your preferences and enhance user experience.
• Analytics Cookies: Help us understand website usage trends through tools like Google Analytics.
• Advertising Cookies: May be used by third-party partners to track your browsing behavior across other sites.

2.4 Information from Third Parties

We may supplement our data with information from marketing or analytics partners and may combine it with information we collect directly to improve our Services or tailor communications.

3. How We Use Personal Data

We use your Personal Data for a variety of purposes, including:

• Providing, maintaining, and improving the Services
• Responding to your inquiries and providing customer support
• Sending newsletters or promotional materials (if you opt in)
• Processing job applications
• Detecting fraud, abuse, or other unauthorized activities
• Enforcing our legal rights and complying with applicable laws
• Facilitating integrations with third-party applications
• Aggregating or anonymizing data for internal analysis and product development
• Communicating administrative or security-related updates
• Creating usage analytics and performance reports

4. Legal Basis for Processing (EU/UK Users)

For users in the European Economic Area (EEA) or the United Kingdom (UK), our processing of Personal Data is based on the following lawful grounds:

• Consent – When you've given explicit permission (e.g., email marketing).
• Contractual Necessity – When necessary to deliver Services or respond to inquiries.
• Legal Obligation – Where we must process data to comply with law.
• Legitimate Interests – For internal analytics, product enhancement, and fraud prevention.

5. How We Share Personal Data

Orbit does not sell your Personal Data. However, we may disclose information under the following circumstances:

• With Affiliates: For operational or analytical purposes across Orbit entities.
• Service Providers: Vendors that assist in delivering services such as hosting, customer support, analytics, and marketing.
• Legal Requirements: When legally required to do so by law enforcement, court orders, or government agencies.
• Business Transfers: If we engage in a merger, acquisition, asset sale, or similar transaction.
• With Your Consent: When you authorize or request disclosure.
• Aggregated or De-Identified Data: Which cannot be used to identify you.

6. International Data Transfers

Your Personal Data may be stored and processed outside of your jurisdiction, including in the United States. Where required by law, we implement safeguards to ensure that cross-border transfers comply with applicable data protection regulations, such as the use of standard contractual clauses.

7. Security Measures

We take reasonable organizational and technical precautions to secure your Personal Data. However, no method of data transmission or storage is completely secure. If you believe your interaction with Orbit is no longer secure, please notify us immediately at the contact information below.

8. Data Retention

We retain your Personal Data only for as long as is reasonably necessary to fulfill the purposes for which it was collected, including providing support or satisfying legal obligations. Retention duration is determined by factors such as the nature of the interaction, applicable legal requirements, and legitimate business needs.

9. Third-Party Links and Services

Our Services may include links to third-party websites, applications, or services that we do not control. This Privacy Policy does not apply to those external services. We encourage you to review their privacy policies before providing any information.

10. Your Rights and Choices

Depending on your location, you may have rights under data protection laws, including:

• Access: Request a copy of your Personal Data.
• Amendment: Correct or update inaccurate information.
• Erasure: Request deletion where legally applicable.
• Restriction or Objection: Limit or object to processing under certain conditions.
• Data Portability: Receive your Personal Data in a structured format.
• Consent Withdrawal: Revoke any prior consent (e.g., for marketing).
• Opt-Out: You may opt out of marketing communications via the link in our emails.

To exercise any of these rights, please contact us using the details provided below. We may need to verify your identity to process your request and may retain limited information for backup or legal compliance purposes.

11. California Privacy Notice

If you are a California resident, please review our California Privacy Notice for additional information regarding your rights under the California Consumer Privacy Act (CCPA).

12. Children's Privacy

Orbit does not knowingly collect or solicit Personal Data from children under 16. If you believe we have collected information from a child, please contact us immediately.

13. Changes to This Privacy Policy

We may revise this Privacy Policy periodically. When we do, the updated version will be posted to this page with a new effective date. If material changes are made, we will make reasonable efforts to notify you via the Services or other contact methods.

14. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or your Personal Data, please contact us:

Email: privacy@orbit.app