Privacy Policy

‍PRIVACY POLICY

Last Updated: September 20, 2022

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE OR ENGAGE IN COMMUNICATIONS WITH US CONCERNING OUR PRODUCTS OR SERVICES.

INTRODUCTION

Orbit Labs and its affiliates, including Orbit Labs France SAS, (also referred to herein as “we,” “us,” and “our”) are committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat your personal information. We have established this Privacy Policy to inform you about the privacy practices that we apply to personal information and to inform you about your rights and choices in this regard. Please read this Policy carefully to learn more about how we process personal information and what rights you may have under applicable law.

When does this Policy apply? This Policy describes our practices for the personal information for which we are a “data controller” under applicable law, including when you visit our website, orbit.love (the “Site”).

HOW DO WE COLLECT AND USE PERSONAL INFORMATION?

We collect the following types of personal data for the purposes listed below. You may choose not to provide us with any personal information, but you will not be able to access portions of the Site that require personal information. For purposes of the EU General Data Protection Regulation, 2016/679 (the “GDPR”), and certain other applicable laws, we act as a data controller with respect to the personal information described below. This Policy does not apply to our processing of personal information as a processor, as defined under the GDPR, on behalf of our customers. Our customers act as data controllers with respect to such data, and questions regarding the data controller’s practices should be directed to the data controller. When we are acting as a data processor, we collect and process personal information in accordance with the instructions provided by the data controller.

Category	Description and Purpose
Contact Information	When you request information about our products or services, ask to be added to our email distribution list, or join the mailing list for any of our print publications, we may collect your name, email address, mailing address, phone number, and other contact details to fulfill your request. When you do so in the course of a relationship between you, your organization, and us, we also collect your business contact information, including the name of your employer and your job title. If you interact with us on social media, we may also receive your user names on such social media platforms and associate such information with your other Contact Information. We process Contact Information in order to offer, market, and sell our products and services to you and to send you our notifications, newsletters, and publications. The legal basis for this processing is consent or, where applicable, our legitimate interests in taking steps, at your request, to enter into a contract with you. We will only provide you with marketing-related information after you have, where legally required to do so, opted in to receive those communications. If at any time you would like to unsubscribe from receiving future emails, you may unsubscribe using the link at the bottom of each email.
Account Information	In order to access and use certain features of the Site, you must first complete a registration. When you create an account and register with us, we collect your name, username, email address, and the password that you create. We process Account Information to operate the Site, to provide our products and services to you, to ensure the privacy and security of our Site and services, to maintain back-ups of our databases, to manage our relationships with you, to communicate with you, to keep records of our communications with you, to send you our notifications and newsletters, and to promote our products and services to our customers. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our customer relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Cookies and Similar Technologies	When you visit the Site, we collect cookies and use similar technologies as described in the “Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly. We use Cookies and Similar Technologies to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new products and services, to enhance your experience, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, to improve our marketing efforts, and for usage analytics purposes. We rely on your express opt-in consent for the use of analytic and marketing cookies and similar technologies. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Site and business.
Usage Information	When you visit the Site, we automatically collect information from your browser and your device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address or unique device identifier, domain server, browser type, access time, and data about which pages you visit. We process Usage Information to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new products and services, to enhance your experience, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, to improve our marketing efforts, and for usage analytics purposes. The legal basis for this processing is our legitimate interests in monitoring and improving our Site and services.
Your Communications and Feedback	When you communicate with us or provide feedback, we will receive and retain your communications and the information included in those messages. If you receive email communications from us, we use certain tools to capture data related to if/when you open our message and if/when you click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts. We process your Communications and Feedback in order to communicate with you, to keep records of our communications with you, to enhance your experience, and to send you relevant notifications and newsletters. The legal basis for this processing is our legitimate interests in the proper administration of our Site and business and communications with our users.
Financial and Payment Information	If you choose to purchase products or services from us, we collect your name, contact information, and your payment information, including your credit card number, security code, expiration date, and other related billing information. Financial transactions conducted via the Site are processed by Stripe, whose privacy policy is available at: https://stripe.com/privacy. We share Financial and Payment Information with our payment processor as necessary to process payments/refunds. By submitting your payment card information, you expressly consent to the sharing of your information with third-party payment processers and other third-party services (including but not limited to vendors who provide fraud detection services to us and other third parties). Please note that credit card numbers and account information are not stored on our servers. We process Financial and Payment Information in order to provide our products and services to you and to keep records of those transactions. The legal basis for this processing is the performance of a contract between you and us and taking steps, at your request, to enter into such a contract and our legitimate interests in the proper administration of our Site and business.

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Other Processing Activities. We may also process personal information when necessary for the following:

The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)
Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.)
Compliance with federal, state, or local laws (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
Compliance with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities and cooperation with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate applicable law (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
Collection, use, retention, or disclosure of information that is deidentified or aggregated.
Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.

We may process your personal information in connection with any of the purposes and uses described in this Policy on one or more of the following legal grounds:

Because it is necessary to perform the tasks you have requested or to comply with your instructions or other contractual obligations between you and us;
To comply with our legal obligations as well as to keep records of our compliance processes;
Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
Because you have chosen to publish or display your personal information on a public area of the Site, such as a comment area;
Because it is necessary to protect your vital interests;
Because it is necessary in the public interest; or
Because you have expressly given us your consent to process your personal information in a particular manner.

We do not use personal information for making any automated decisions affecting or creating profiles other than as described herein.

Location of Processing. We have operations in the United States, and personal information may be transferred to, stored, and processed in the United States, and other countries in which we or our affiliates, partners, service providers, or agents maintain facilities. By sending us personal information or using the Site, you agree and consent to the processing of your personal information in locations such as the United States, which may not offer the levels of protection required in other countries. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information, such as express consent, when transfer is necessary for us to deliver services pursuant to an agreement, or when the transfer is subject to safeguards that assure the protection of the personal information.

Cookies and Similar Technologies

- First and Third-Party Cookies

A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your device and remain there until they expire at the end of your browsing session. “Persistent” cookies remain stored on your device until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

- Other Similar Technologies

In addition to cookies, there are other data collection technologies, such as Internet tags, web beacons, pixels (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

- What Cookies and Similar Technologies Are in Use and Why Do We Use Them?

Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use our webpages. Any data collected is used in accordance with this Privacy Policy and Google’s privacy policy. You may learn more about Google Analytics and the cookies used by Google by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. Google Analytics relies on the following cookies:

Cookie	Description	Duration
_ga	The cookie is used by Google Analytics to calculate visitor, session, and campaign data and to keep track of site usage for the Site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to identify unique visitors.	two years
_gat	This cookie is used to distinguish users.	one minute
_gid	The cookie is used by Google Analytics to store information about how visitors use the Site, and it helps create an analytics report about how the Site is performing. The data collected includes the number of visitors, where the visitor access the page from, and the pages visited by the visitor in an anonymous form.	24 hours

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To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en). Google Analytics has certified compliance with the EU-US Privacy Shield Framework set forth by the U.S. Department of Commerce.

Google Tag Manager. We also use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) is a cookie-less domain and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information. Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.

Google Marketing (Google AdWords conversion, Google Dynamic Remarketing, DoubleClick, GA Audiences). We use Google’s marketing technologies to track user activity on the Site and to serve personalized advertisements. Your browser is assigned a pseudonymous ID used to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, you can visit https://policies.google.com/technologies/ads, https://support.google.com/displayvideo/answer/7621162, and https://support.google.com/google-ads/answer/7548399?hl=en. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922. Google’s Privacy Policy is available at: https://www.google.com/policies/privacy.

Hubspot. We use Hubspot to track visitors to the Site and to gather demographic information about them. Hubspot keeps track of the pages you visit. This data is used to deliver customized content and promotions to users whose behavior indicates that they are interested in a particular subject area. For more information about Hubspot’s Privacy Policy, see https://legal.hubspot.com/privacy-policy. Hubspot uses the following cookies:

Cookie	Description	Type	Duration
__hssc	This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp	Analytics	30 minutes
__hssrc	Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.	Analytics	Session
__hstc	This cookie tracks visitors, and it contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).	Analytics	6 months
hubspotutk	This cookie keeps track of a visitor’s identity. It is passed to HubSpot on form submission and used when deduplicating contacts. It contains an opaque GUID to represent the current visitor.	Analytics	6 Months
__cfruid	This cookie is set by HubSpot’s content delivery network provider (Cloudflare) because of their rate limiting policies	Necessary	Session
__cf_bm	This cookie is set by HubSpot's CDN provider and is a necessary cookie for bot protection.	Necessary	30 minutes

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Fastly. We use Fastly to monitor traffic to our Site, optimize the delivery of our Site, and protect our services and API integrations. For more information about Fastly’s Privacy Policy, visit https://www.fastly.com/privacy/.

Probely. Probely is a vulnerability scanner we use to protect the security of our Site, services, and API integrations. For more information about Probely’s Privacy Policy, visit https://probely.com/privacy-policy/.

Segment. We use Segment to collect and sort data gathered from our Site. This data is used to better understand use of our Site and services. For more information about Segment’s Privacy Policy, visit https://www.twilio.com/legal/privacy.

Fathom Analytics. We use Fathom Analytics to gather usage statistics relating to our Site. Fastly does not track or store your personal information. You can learn more about the Fathom Analytics Privacy Policy by visiting https://usefathom.com/privacy.

- Other Third-Party Technologies

Some third parties may use data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

- Choices About Cookies

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being stored. These settings may affect your enjoyment of the Site’s functionality. Adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. The links below provide additional information about how to disable cookies or manage the cookie settings:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac and https://support.apple.com/en-us/HT201265

For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.

SHARING AND DISCLOSING OF YOUR PERSONAL INFORMATION

We may share your personal information in the following contexts.

Category	Disclosure Contexts
Corporate Affiliates	We share personal information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents.
Acquisitions and Similar Transactions	We may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Disclosures with Your Consent	We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent.
Legal Obligations and Rights	We disclose personal information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share personal information in order to establish or exercise our legal rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of contract. We may also disclose personal information as needed to protect vital interests.
Public	Some areas of our Site may offer forums or provide the opportunity for users to post comments or reviews in a public forum. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information. If you decide to submit your personal information in these areas, you do so at your own risk and acknowledge that the information will be publicly-available.
Service Providers	We share personal information with our agents, contractors, and service providers. Among other things, service providers help us to administer the Site; support our provision of products and services; send communications; provide technical support; and assist with other legitimate purposes permitted by law. Financial transactions conducted via the Site are processed by Stripe whose privacy policy is available at: https://stripe.com/privacy. We share Financial and Payment Information with our payment processor as necessary to process payments/refunds. By submitting your payment card information, you expressly consent to the sharing of your information with third-party payment processers and other third-party services (including but not limited to vendors who provide fraud detection services to us and other third parties).
Professional Advisors	We share personal information with our insurers and other professional advisors, including attorneys, accountants, consultants, and auditors, that need access to your information to provide operational or other support services on our behalf.
Deidentified or Aggregated Data	We share aggregated information and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, (i) for compliance with reporting obligations; (ii) for business or marketing purposes; and (iii) to assist us and others in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, marketing, and/or functionality.
Third Parties	We may provide personal information about you to third parties that may offer products and services specifically requested by you. The third party will act as the controller for purposes of the GDPR.

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HOW LONG DO WE PROCESS YOUR INFORMATION?

We retain and use your personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.

We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives.

To the extent permitted by law, we may retain and use anonymous, de-identified, and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement. When we delete data, it will be removed from our active servers and databases; but, it may remain in our archives when it is not practical or possible to delete it.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We have put security measures in place to protect personal information from being accidentally lost, used, altered, or disclosed or accessed in an unauthorized manner and to detect fraudulent identify-verification activity, including when transmitting personal information in response to data subject requests. From time to time, we review our security procedures to consider appropriate new technologies and methods.

We use SSL technology to encrypt data in transit, and we also encrypt data at rest on our systems. We do not store or save your financial information. While our security measures seek to protect your personal information in our possession, no security system is perfect, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you do so at your own risk. We cannot promise that your personal information will remain absolutely secure in all circumstances.

The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.

If a security breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

RIGHTS AND CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

Please use the Contact Us details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your personal information or if you no longer want to receive any email, postal mail, or telephone contact from us in the future, such requests may be submitted via the “Contact Us” details at the end of this Policy. If you are exercising a right that is the responsibility of our data controller customers, we will direct you to contact the appropriate data controller who is responsible for responding to your request.

Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link available at the bottom of our email communications or by contacting us at [email protected] and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.

Cookies. You may choose to not allow cookies via the cookies consent banner or set your browser to refuse all or some browser cookies or to alert you when cookies are being set. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.

Online Tracking. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on the Site or on third-party websites or online services where we may collect information.

Accuracy and Updating Your Personal Information. Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please let us know via “Contact Us” details provided at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

Preferences. If you wish to change your communication preferences or ask that we restrict how we use your personal information, please contact us using the information in the “Contact Us” section of this Policy. You may follow opt-out links on any marketing communications sent to you.

Complaints. If you believe that your rights relating to your personal information have been violated, you may lodge a complaint with us by contacting us using the information provided in the “Contact Us” section of this Policy.

Individual Rights. You may have certain rights relating to your personal data under local data protection laws, and we discuss the rights provided in various jurisdictions below. We honor individuals’ rights where required under applicable law, and, depending on the applicable laws, these rights may include the right to:

Access your personal information;
Know more about how we process your personal information;
Rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete;
Erase or delete your personal information;
Restrict our processing of your personal information;
Transfer your personal information to another controller, to the extent possible;
Object to certain processing of your personal information;
Opt-out of certain disclosures of your personal information to third parties;
If you’re under the age of 16, or such other applicable age of consent, opt-in to certain disclosures of your personal information to third parties;
Not be discriminated against for exercising your rights described above;
Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects; and
Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

All requests should be sent to us at the contact details noted in the “Contact Us” section of this Policy. Your personal information may be processed in responding to these rights. If you are exercising a right that is the responsibility of a third party, including one of our affiliates, we will direct you to contact the appropriate data controller who is responsible for responding to your request.

EU/EEA Residents

Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.

Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.

Right to Erasure. In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the personal information has been unlawfully processed, (5) the personal data have to be erased for compliance with a legal obligation; and (6) the personal data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Restrict Processing. You have the right to restrict the processing of your data when (1) the accuracy of the personal data is contested, for a period enabling the controller to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the personal data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the personal information, pending resolution of the objection.

Right to Object. In certain circumstances, you have the right to object to the processing of your personal information where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where personal data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.

Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.

Right to Complain. If you believe we have not processed your personal information in accordance with applicable law, we encourage you to contact us at [email protected]. You may also have the right to make a complaint to an applicable Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities for residents of the EU or EEA is available at: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.

Nevada Residents

Nevada residents may submit a verified request to us at [email protected] to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.

California Residents

Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at [email protected].

THIRD-PARTY SITES AND SERVICES

This Policy is applicable only to the Site, and it does not apply to any third-party websites.

The Site may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties with which we may have no relationship. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to the Site and which are to external, third-party websites. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left the Site.

We cannot and do not (1) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your personal information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on this Site.

Any personal information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT

Our Site, products, and services are not directed to children under the age of 13, nor is information knowingly collected from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or provide any information to us. If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we have any received information from a child under the age of 13, please contact us using the “Contact Us” details provided below.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

UPDATES AND CHANGES TO THIS POLICY

We may add to, change, update, or modify this Policy from time to time. We will post all changes to this Policy on this page, and the updated policy will be effective immediately upon posting. If we make material changes, we will also notify you through a notice on the homepage of the Site for a reasonable period of time. We may also, in our discretion, notify you of changes to this Policy via email.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of its current terms. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to any changes and to our collection and sharing of your information according to the then-current Policy. If you do not agree with this Policy and our practices, you should not use the Site.

CONTACT US

For more information, or if you have any questions or concerns regarding this Privacy Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.

In Writing:

Orbit Labs, Inc.
325 9^th Street
San Francisco, CA 94103

Orbit Labs France SAS
57 Rue d’Amsterdam - Paris HQ St Lazare
75008 Paris

By Email: [email protected]