Privacy Policy

1. Introduction and Scope

Orion Digital Advisory ("Orion," "we," "us," or "our") is committed to protecting the privacy and confidentiality of personal information entrusted to us. This Privacy Policy ("Policy") describes how we collect, use, disclose, retain, and protect personal information obtained through our website at oriondigitaladvisory.com and any related services, platforms, or communications (collectively, the "Platform").

This Policy applies to all individuals who access or use the Platform, including prospective participants, registered users, and visitors ("you" or "your"). By accessing the Platform, you acknowledge that you have read and understood this Policy and consent to the practices described herein.

This Policy is incorporated into and forms part of our Terms of Use. Capitalized terms not defined herein shall have the meanings ascribed to them in the Terms of Use.

2. Information We Collect

We collect personal information in the following categories:

2.1 Information You Provide Directly

• Identity Information: Full name, date of birth, nationality, and government-issued identification details;
• Contact Information: Email address, telephone number, and mailing address;
• Financial Information: Investment experience, net worth range, investable assets, accreditation status, and capital availability;
• Professional Information: Occupation, employer, professional background, and relevant industry experience;
• Communications: Content of messages, inquiries, and correspondence submitted through the Platform.

2.2 Information Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device identifiers, and referring URLs;
• Usage Data: Pages visited, time spent on pages, links clicked, and navigation patterns;
• Cookie Data: Information collected through cookies, web beacons, and similar tracking technologies as described in Section 7.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including identity verification services, credit reference agencies, sanctions screening providers, and publicly available sources, for the purposes of compliance with applicable legal and regulatory obligations.

3. Legal Basis and Purposes of Processing

We process personal information on the following legal bases and for the following purposes:

• Contractual Necessity: To process access requests, verify eligibility, onboard qualified participants, and administer participation in opportunities presented through the Platform;
• Legal Obligation: To comply with applicable anti-money laundering (AML), know-your-customer (KYC), counter-terrorism financing (CTF), and other regulatory requirements; to respond to lawful requests from regulatory authorities and law enforcement;
• Legitimate Interests: To operate, maintain, and improve the Platform; to detect, prevent, and investigate fraud, security incidents, and other prohibited activities; to communicate with you regarding Platform updates and relevant developments;
• Consent: Where required by applicable law, to send marketing communications and to use non-essential cookies and tracking technologies.

4. Disclosure of Personal Information

Orion does not sell, rent, or trade personal information to third parties for their own marketing purposes. We may disclose personal information in the following circumstances:

• Service Providers: To trusted third-party service providers who assist in operating the Platform, including technology providers, identity verification services, compliance platforms, and professional advisers, subject to appropriate confidentiality and data processing agreements;
• Regulatory and Legal Requirements: To regulatory authorities, law enforcement agencies, courts, or other governmental bodies where required by applicable law, regulation, legal process, or governmental request;
• Business Transfers: In connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, subject to appropriate confidentiality protections;
• Protection of Rights: Where necessary to protect the rights, property, or safety of Orion, its users, or the public.

5. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy applicable legal, regulatory, accounting, and reporting requirements.

In determining appropriate retention periods, we consider the nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the information, and applicable legal requirements.

Personal information collected for AML/KYC compliance purposes is retained for a minimum of five (5) years following the termination of the relevant relationship, or such longer period as may be required by applicable law. Upon expiry of the applicable retention period, personal information is securely deleted or anonymized.

6. International Data Transfers

Orion operates globally and may transfer personal information to countries outside your jurisdiction of residence, including countries that may not provide the same level of data protection as your home jurisdiction.

Where we transfer personal information internationally, we implement appropriate safeguards to ensure that such transfers comply with applicable data protection laws, including the use of standard contractual clauses approved by relevant regulatory authorities, binding corporate rules, or other legally recognized transfer mechanisms.

7. Cookies and Tracking Technologies

The Platform uses cookies and similar tracking technologies to enhance user experience, analyze Platform performance, and support security functions. Cookies are small data files stored on your device that allow us to recognize your browser and capture certain information.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the operation of the Platform and cannot be disabled;
• Performance and Analytics Cookies: Used to collect aggregated, anonymized information about how users interact with the Platform;
• Functional Cookies: Used to remember your preferences and personalize your experience.

You may control cookie settings through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform.

8. Data Security

Orion implements appropriate technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to, encryption of data in transit and at rest, access controls and authentication requirements, regular security assessments, and employee training on data protection obligations.

While we take reasonable precautions to protect personal information, no security system is impenetrable. We cannot guarantee the absolute security of information transmitted to or from the Platform. You are responsible for maintaining the confidentiality of any access credentials associated with your use of the Platform.

9. Your Rights and Choices

Subject to applicable law, you may have the following rights with respect to your personal information:

• Right of Access: To request a copy of the personal information we hold about you;
• Right of Rectification: To request correction of inaccurate or incomplete personal information;
• Right of Erasure: To request deletion of your personal information, subject to applicable legal retention obligations;
• Right to Restrict Processing: To request that we limit the processing of your personal information in certain circumstances;
• Right to Data Portability: To receive your personal information in a structured, machine-readable format;
• Right to Object: To object to processing of your personal information based on legitimate interests;
• Right to Withdraw Consent: Where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us through the contact information provided on the Platform. We will respond to your request within the timeframe required by applicable law. We may require verification of your identity before processing your request.

10. Children's Privacy

The Platform is not directed to individuals under the age of 18, and we do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a person under 18, we will take prompt steps to delete such information. If you believe we may have collected information from a minor, please contact us immediately.

11. Third-Party Links and Services

The Platform may contain links to third-party websites, services, or resources. This Policy does not apply to such third-party platforms, and Orion is not responsible for the privacy practices or content of any third-party sites. We encourage you to review the privacy policies of any third-party platforms you visit.

12. Changes to This Policy

Orion reserves the right to update or modify this Policy at any time. We will notify you of material changes by posting the revised Policy on the Platform with an updated effective date. In certain circumstances, we may provide additional notice, such as by email.

Your continued use of the Platform following the posting of changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact Orion Digital Advisory through the contact information provided on the Platform.

If you are located in a jurisdiction with a supervisory authority for data protection matters, you have the right to lodge a complaint with the relevant authority if you believe your personal information has been processed in violation of applicable law.