Oribitr Ltd Privacy and Data Policy
Orbitr Ltd Contact details:
Trading Address Orbitr Ltd, Silverstream House, Fitzrovia, London, W1T
Our Registered Company Number Registered in England 14802418
Our website address: https://orbitr.co
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Orbitr Ltd
Email address: [email protected]
We are a development company providing services to our customers.
Orbitr Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our Orbitr application (the “Application”) and will tell you about your privacy rights and how the law protects you.
Please see the ‘Glossary’ section below to explain certain terms we use within this privacy policy.
1. Purpose
The purpose of this privacy policy is to inform you about Orbitr’s practices regarding the collection and processing of your personal data when you utilise our website, provide information through the website, use our application, or engage with us via social media. Please note that our website is not designed for children, and we do not intentionally gather data pertaining to children.
It is essential that you review this privacy policy alongside any additional privacy or fair processing policies provided on specific occasions when we collect or process your personal data. This ensures that you have a comprehensive understanding of how and why your data is being used. This privacy policy is intended to complement other notices and privacy policies and is not intended to supersede them.
Data Processing Roles:
When utilising the Application to assert verified information, Orbitr will process your personal data as a data processor acting on behalf of the Registered Verifier.
For all other functionalities of the Application or our website, Orbitr assumes the role of a data controller in relation to your personal data (referred to collectively as “we,” “us,” or “our” in this privacy policy).
Data Privacy Manager:
We have designated a data privacy manager to address inquiries related to this privacy policy. If you have any questions regarding this policy or wish to exercise your legal rights, please contact the data privacy manager using the details provided below.
Complaints and Oversight:
You retain the right to file a complaint at any time with the supervisory authority, the Information Commissioner’s Office (ICO) in the UK (www.ico.org.uk). However, we would appreciate the opportunity to address your concerns initially, so please reach out to us in the first instance.
Orbitr Ltd is a registered company with the ICO in the UK (www.ico.org.uk
Policy Updates and Notification Duty:
We routinely review and update our privacy policy. The latest version was revised on January 4, 2024. Previous versions can be obtained by contacting us. It is crucial to ensure that the personal data we hold about you is accurate and up to date. Kindly inform us of any changes to your personal data during your association with us.
Third-Party Links:
Our website or Application may feature links to third-party websites, plug-ins, and applications. Activating these links or connections may enable third parties to collect or share data about you. We do not govern these third-party websites and disclaim responsibility for their privacy statements. When exiting our website or Application, we encourage you to review the privacy policy of each visited website.
2. Information We Collect About You
Personal data, or personal information, refers to any details that identify an individual. This excludes data where the identity has been removed (anonymous data).
We may gather, utilise, store, and transfer various types of personal data about you, which we have categorised as follows:
- Identity Data: This encompasses first name, last name, username, or a similar identifier.
- Contact Data: This includes your address, email address, and telephone numbers.
- Financial Data: This covers bank account and payment card details.
- Profile Data: This entails information such as education, work history, and other details within your Orbitr.
- Transaction Data: This involves particulars about payments to and from you, as well as details of products and services you’ve acquired from us.
- Technical Data: This consists of internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Profile Data: This includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data: This pertains to information about how you use our website, products, and services.
- Marketing and Communications Data: This covers your preferences in receiving marketing communications from us and our third parties, as well as your communication preferences.
We also collect, utilise, and share Aggregated Data, such as statistical or demographic data, for various purposes. Aggregated Data may be derived from your personal data but is not considered personal data as it will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or application feature. However, if we combine or connect Aggregated Data with your personal data in a way that it can directly or indirectly identify you, we treat the combined data as personal data and handle it in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you, including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Additionally, we do not collect information about criminal convictions and offenses.
If you fail to provide personal data:
In instances where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide the requested data, we may be unable to fulfil the contract or service we are attempting to establish with you. For instance, this could lead to the cancellation of a product or service you have with us. If such a situation arises, we will notify you accordingly at the time.
3. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
Direct interactions: You may give us your Identity and Financial Data by creating an account on our website or Application, adding documents containing these details into your Orbit, filling in forms, corresponding with us by post, phone, email, chatbot or otherwise.
Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the ‘Cookies’ section below for further details.
Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:
Identity and Contact Data from Registered Parties: (set out in our Terms and Conditions)
- Analytics providers, such as Google; and
- Search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register based inside the UK
4. How Your Personal Data Is Utilised
Our utilisation of your personal data is guided by legal principles, ensuring your privacy and rights are respected. We employ your personal data under the following circumstances:
Contractual Necessity:
We use your personal data when it is essential for the performance of a contract that we are entering into or have already entered into with you.
Legitimate Interests:
Your personal data may be processed when necessary for our legitimate interests or those of a third party. This is conducted with due consideration to ensure your interests and fundamental rights do not supersede these interests.
Legal Obligations:
We process your personal data to fulfil legal obligations imposed upon us.
While we generally do not rely on consent as the primary basis for processing your personal data, we will seek your consent before sending third-party direct marketing communications via email or text message. You retain the right to withdraw your consent for marketing activities at any time by contacting us.
Purposeful Data Usage:
Outlined below are the specific ways we intend to use your personal data, along with the corresponding legal bases for each use. In instances where multiple legal grounds apply for processing your data, please feel free to reach out to us for further details.
We strive to maintain transparency in our data processing practices, and your inquiries about the specific legal grounds for processing your personal data are welcomed.
Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below:
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
| To provide our website and Application to Registered Users and Registered Parties to enable the storage and sharing of qualification documents | Identity
Contact Career Information |
Performance of a contract with you |
| To provide Registered Employers with access to a User’s CV and:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us |
Identity
Contact Financial Transaction Marketing and Communications |
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey |
Identity
Contact Profile Marketing and Communications |
Performance of a contract with you
Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | Identity
Contact Profile Usage Marketing and Communications |
Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity
Contact Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity
Contact Profile Usage Marketing and Communications Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our products/services, marketing, customer and relationships experiences | Technical
Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity
Contact Technical Usage Profile Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We are committed to providing you with choices regarding the utilisation of your personal data, especially in the realms of marketing and advertising. Our privacy centre, accessible at http://orbitr .co/#cookie-preferences, empowers you to review and make decisions about the use of your personal data.
Promotional Offers
We may analyse your Identity, Contact, Technical, Usage, and Profile Data to understand your preferences and interests. This analysis guides us in determining which products, services, and offers may align with your needs (referred to as marketing).
You will receive marketing communications from us if you have requested information or utilised our Application and have not opted out of receiving such communications.
Third-Party Marketing
Before sharing your personal data with any third party for marketing purposes, we will seek your explicit opt-in consent.
Opting Out
You have the option to stop receiving marketing messages at any time by:
Logging into the privacy centre and adjusting your marketing preferences by checking or unchecking relevant boxes.
Following the opt-out links provided in any marketing message sent to you.
Contacting us at any time.
It’s important to note that opting out of marketing messages does not affect personal data provided to us as a result of using our application.
Cookies:
Our website and application use cookies to distinguish you from other users, providing a better browsing experience and enabling site improvements. Cookies are categorised as strictly necessary, analytical or performance, functionality, and targeting cookies.
You have the option to configure your browser settings to reject all or specific types of browser cookies or to receive notifications when websites attempt to set or access cookies. It’s important to be aware that disabling or refusing cookies may result in certain parts of this website becoming inaccessible or functioning improperly. Refer to the ‘Cookies’ section below for more details on the cookies we employ.
Change of Purpose:
We commit to utilising your personal data solely for the purposes for which it was initially collected. However, in instances where we reasonably determine that there is a need to use the data for a different purpose, and that purpose aligns with the original intent, we may proceed. If you seek clarification on how the processing for the new purpose aligns with the original one, please reach out to us.
Should there be a necessity to employ your personal data for an unrelated purpose, we will inform you and provide an explanation of the legal basis permitting such usage. It’s important to note that, in accordance with applicable laws, we may process your personal data without your explicit knowledge or consent while adhering to the aforementioned principles.
5. Sharing Of Your Personal Data
We may disclose your personal data to the following parties for the purposes outlined in the above table:
- Registered Parties
- Our suppliers, including IT providers and providers of our blockchain environment
- Providers collecting information on our behalf, such as cloud-based log aggregators, customer satisfaction surveyors, analytics, performance, tracking, and advertising partners necessary for website features
- Professional advisers, including consultants, lawyers, bankers, auditors, and insurers offering consultancy, banking, legal, insurance accounting, and related services
- Trusted business partners with whom we collaborate
- HM Revenue & Customs, regulators, and other authorities requiring reporting of processing activities under specific circumstances
- Third parties in the event of selling, transferring, or merging parts of our business or assets. In such cases, new owners will adhere to the same privacy policy.
We mandate all third parties to respect the security of your personal data, treating it in compliance with the law. Our third-party service providers are restricted from using your personal data for their own purposes and are only permitted to process it for specified purposes as per our instructions.
6. International Transfers
Our external third parties may be situated outside the UK or EEA, leading to the transfer of your personal data outside these regions. When transferring your data, we ensure a similar level of protection through:
- Transferring to countries deemed to provide an adequate level of protection
- Using specific contracts approved for use in the UK, offering the same protection as in the UK or EEA.
- Contact us for more information on the mechanisms used for transferring your personal data out of the UK or EEA.
7. Data Security
We have implemented appropriate security measures to prevent unauthorised access, loss, alteration, or disclosure of your personal data. Access to your data is limited to employees, agents, contractors, and other third parties with a legitimate business need, and they process it only as per our instructions, bound by confidentiality.
We have procedures to address suspected personal data breaches and will notify you and relevant regulators when legally required.
8. Data Retention
We retain your personal data for as long as necessary to fulfil the purposes we collected it for. This includes meeting legal, regulatory, tax, accounting, or reporting requirements. Retention periods are determined based on the nature and sensitivity of the data, potential risks, purposes of processing, and legal requirements. You can request our retention policy for more details.
9. Your Legal Rights
While we hold or process your personal data, you have the following rights:
- Right of access
- Right of rectification
- Right to be forgotten
- Right to restriction of processing
- Right of portability
- Right to object
- Right to object to automated processing, including profiling
- Right to judicial review
You can exercise these rights at any time by contacting the appropriate individual under ‘Key Contacts.’ If you withdraw consent, we may be unable to provide certain products or services, and we will advise you accordingly.
