Privacy policy

1.1This policy covers the Orbit website, the account and vault services reachable from it, and the Orbit Agent. It does not cover a manager's own site, a custodian, a chain explorer or any other third party you reach through a link.

1.2Orbit is the controller of the data described here: we decide what is collected and why. Where a manager receives data about a subscription into their vault, they are a controller of that data in their own right.

1.3Questions about this policy go to privacy@the-orbit.xyz. We answer privacy mail before other mail.

Data falls into four groups. The left column is the group, the middle is what it holds, the right is where it comes from.

We do not sell personal data, and we do not hand it to a third party for that party's own advertising.

4.1Strictly necessary storage keeps you signed in, holds your session and remembers your language, theme and currency. It cannot be switched off without breaking the product.

4.2Analytics storage counts page views and feature use so we can see what is worth building. You can decline it, and declining changes nothing else about the service.

4.3We set no advertising cookies and run no cross-site tracking pixels.

4.4In this demo, everything above is browser localStorage on your own device. Clearing site data resets the product to its opening state.

5.1Service providers who work on our instructions: identity verification, cloud hosting, email delivery, error monitoring and customer support tooling. They may use the data only for the task we set.

5.2Vault managers, where you subscribe to their vault, receive what they need to maintain the register: your account reference, the size of your holding and the dealing instruction. They do not receive your identity document.

5.3Banks, custodians and payment providers, where a transfer requires it.

5.4Regulators, law enforcement, auditors and courts, where we are required or permitted to disclose.

5.5An acquirer, where a merger or sale of the business happens. You would be told before your data moved.

6.1Primary storage sits in Hong Kong and Singapore. Some providers process data in the European Union and the United States.

6.2Where data leaves the jurisdiction it was collected in, we use contractual protections at least as strong as the local standard, and we assess the recipient's country before we send anything.

6.3You can ask us which providers hold data about you and where they are.

Write to privacy@the-orbit.xyz for any of these. We answer within 30 days of receiving the request, and tell you why if we need longer.

• Access

  Ask for a copy of the personal data we hold about you, and for an explanation of where it came from.

• Correction

  Ask us to fix data that is wrong or out of date. Identity fields may need a document to support the change.

• Erasure

  Ask us to delete data. We must refuse where a record is held under a legal retention duty, and we will say which.

• Portability

  Ask for the data you gave us in a machine-readable file, or ask us to send it to another provider.

• Objection

  Object to processing based on legitimate interest, including analytics.

• Withdraw consent

  Turn off product news at any time, in settings or from the footer of any such email.

If you think we have handled this badly, you can complain to the Office of the Privacy Commissioner for Personal Data in Hong Kong, or to the data protection authority where you live.

9.1Data is encrypted in transit and at rest. Access is role-based, logged, and reviewed; identity documents are held in a separate store with a narrower access list.

9.2Staff access requires a business reason and multi-factor authentication. Access to production data is time-boxed and recorded.

9.3We test the service against common attack classes and run a disclosure channel for researchers at security@the-orbit.xyz.

9.4If a breach is likely to put you at risk, we tell you and the regulator without undue delay, with what happened and what to do about it.

10.1Screening for sanctions and fraud is partly automated. An automated hit never closes an account on its own; a person reviews it before anything happens to you.

10.2The Agent generates text from data you can see. It does not score you, does not decide your eligibility, and its output is not a decision about you.

10.3You can ask for a human review of any automated outcome that affects your account.

11.1Orbit is not for anyone under 18. We do not knowingly collect data from children.

11.2If we learn that an account belongs to a minor, we close it and delete the data except what a legal duty requires us to keep.

12.1We update this policy as the product changes. The revision line at the top shows the version in force.

12.2Material changes are notified in the product before they take effect, and the previous version stays available on request.

12.3Write to privacy@the-orbit.xyz for a request, a question or a complaint; write to security@the-orbit.xyz to report a vulnerability.