Orbital understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who uses www.getorbital.com, our mobile apps or application programming interfaces (the "API") ("Orbital", the "Platform", the "Website") offers a range of services, provided according to the Platform’s Terms and Conditions and all documents incorporated therein (the "Services"., and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it.
In this Policy the following terms shall have the following meanings:
The Services on the Platform may be provided by:
(any of the aforementioned companies further may be referred to as "Our”, "we" or "us") depending on the country you access the Platform or use the Services from and subject you conclude the agreement with when accepting General Terms and Conditions and other related documents of the Platform.
Our UK Data Protection Officer (DPO) is: Privacy Helper, Bedford Heights Brickhill Drive Bedford Bedford, MK41 7PH.
ICO Registration number: ZA822859.
Our EU Data Protection Representative is: EDPO, Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
This Privacy Policy applies only to your use of Our Platforms. Our Platforms may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
Personal data is defined by the EU, Gibraltar and UK GDPR and the Data Protection Legislation (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in Part 15.
Depending upon your use of Our Platforms, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Our use of Cookies and similar technologies is specified in our Cookie Policy https://www.getorbital.com/cookie-policy. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and Our lawful bases for doing so:
Where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on Our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
We store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We also store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We may store some or all of your personal data in countries outside of the UK and EEA, including Gibraltar. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the Data Protection Legislation as follows:
We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 15 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
We may sometimes contract with the following third parties to supply certain services.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9. A list of our sub-processors is provided in our Data Processing Agreement which is agreed with all new customers, it can also be provided by our DPO upon request.
If any personal data is transferred outside of the UK or EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
If we sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. 1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Platforms, you may be given options to restrict Our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails and by managing your Account.
You may access Our Platforms without providing any personal data at all. However, to use all features and functions available on Our Platforms you may be required to submit or allow for the collection of certain data.
You may restrict Our use of Cookies. For more information, see Part 14 and Our Cookie Policy https://www.getorbital.com/cookie-policy.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.
Our Platforms may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Platforms and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Platforms, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us for a detailed description of our use of cookies, please see our Cookie Policy https://www.getorbital.com/cookie-policy.
All Cookies used by and on Our Platforms are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Platforms may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Our Platforms uses analytics services provided by Metabase. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Platforms is used. This, in turn, enables us to improve Our Platforms and the services offered through it.
The analytics service(s) used by Our Platforms use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Platforms, it does enable us to continually improve Our Platforms, making it a better and more useful experience for you.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Platforms more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: dpo@getorbital.com.
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Platforms and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Platforms following the alterations. We recommend that you check this page regularly to keep up-to-date.
This Privacy Policy was last updated on 5 August 2024.
To find out more about us or our services, please get in touch - we look forward to hearing from you.