Collection of Personal Data
We may collect the following categories of Personal Data when you use or otherwise interact with our financial products or services:
- Email address
- Home/work/mobile telephone number
- Postal or other physical address
- Credit/debit card information
- SSO profile information (when you use 3rd party services to log-in to our Products or to create an account for our Products)
- IP addresses and other information collected passively, as further detailed in the “Passive Collection” section below
We collect and/or process Personal Data in connection with the below activities related to our financial products and services:
- Account registration
- Use of certain Product features
- Generating reports based on information collected from use of our Products
- Requesting service and support for our Products and providing such support
- Placing transactions or orders
- Registering to attend a seminar or webinar
- Participating in an online survey
- Billing and collecting payments for our Products
- Participating in discussion groups or forums
- Registering for newsletter subscriptions
- Customizing the advertising and content you see
Processing of Personal Data
We will only process Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the financial products and services) and our “legitimate interests” or the legitimate interest of others (e.g. our users) such as:
- Personalizing, improving or operating our financial products and business
- Better understanding customer needs and interests
- Fulfilling requests you make related to the financial products or services
- Providing you with information and offers from us or third parties
- Complying with our legal obligations, resolving disputes with users, enforcing our agreements
- Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity
We process Personal Data for purposes such as:
- To process orders and deliver the financial products and services you have ordered
- To provide reports based on information collected from use of our financial products
- To keep you up to date on the latest product and services announcements, software updates, software upgrades, system enhancements, special offers, and other information
- To provide support and assistance for our financial products and services
- To provide the ability to create personal profile areas and view protected content
- To provide the ability to contact you and provide you with shipping and billing information
- To provide customer feedback and support
- To the extent you choose to participate, to conduct questionnaires and surveys in order to provide better products and services to our customers and end users
- To support recruitment inquiries
- To personalize marketing communications and website content based on your preferences, such as in response to your request for specific information on products and services that may be of interest
- To meet contract or legal obligations
Data Subject Rights
You have certain rights with respect to Personal Data provided by you to us, as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.
- Access: You can request more information about the Personal Data we hold about you and those at your company. You can also request a copy of the Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Products.
How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.
Orion and our third-party service providers automatically collect some information about you when you use our financial products and services, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website and/or financial products.
In addition, when you use some of our financial products, network information is transmitted back to us such as product usage information. This information is transmitted back to us so we can determine how users are interacting with our financial products, to assist us with improving our products and services, and to try to correct any problems that may occur.
Cookies and Tracking Technologies
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Products do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Products and after you leave our properties.
We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Some of our third party partners use technologies such as cookies and other technologies to gather information about your activities on this website, our affiliates’ websites, and unaffiliated websites in order to provide you advertising based upon your browsing activities and interests. With respect to our interest-based ads, we adhere to self-regulatory principles for online behavioral advertising.
Mobile Application (if applicable)
When you download and use our Products, we automatically collect information on the type of device you use, operating system version, and the device identifier (or ”UDID“). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
Sharing Personal Data
We do not sell or rent Personal Data to third parties for marketing purposes unless you have granted us permission to do so.
We share Personal Data within Orion, and with third party service providers for purposes of data processing or storage.
We also share Personal Data with business partners, service vendors and/or authorized third-party agents or contractors in order to provide requested Products or transactions, including processing orders, processing credit card transactions, hosting websites, hosting event and seminar registration and providing customer support. We provide these third parties with Personal to complete/utilize the requested Product or transaction.
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Orion’s terms of service, or as otherwise required by law.
Security of your Personal Data
Orion is committed to protecting Personal Data. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect Personal Data from unauthorized access, use or disclosure. When we transfer credit card information over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology.
We recommend you take every precaution in protecting Personal Data provided to us by you when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of Personal Data you have provided, you can contact us by using the information in the “Contact Us” section of this policy.
Linked websites and third-party services
Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.
Transfer and Storage of Personal Data
Our financial products are hosted and operated in the United States (“U.S.”) through Orion and its service providers. We may transfer Personal Data to the U.S., to any Orion affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our financial products or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request the address below.
Attention: Privacy Officer
PO BOX 2149
Gig Harbor, WA 98335