1. Introduction

This is our privacy policy. It tells you how we collect and process data received from you. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. If you have any comments or questions about this privacy policy, please email them to info@orbitpartners.com.

2. Who We Are

Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a 'data controller': - Our website address is www.orbitpartners.com. - Our company name is Orbit Partners Ltd. - Our registered address is 120 New Cavendish Street, London, W1W 6XX, United Kingdom. - Our nominated representative is Vincent Lambert and he can be contacted at info@orbitpartners.com.

3. Data We May Collect

We may collect and process the following data about you: - Information you put into forms or surveys on our site at any time - A record of any correspondence between us - Details of transactions you carry out through our site - Details of your visits to our site and the resources you use - Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration Orbit Partners also collects personal and professional information during the Advisor or Client registration process. This might be complemented by additional information generated through any interactions with Orbit Partners, our employees, our Clients and any correspondence in relation with our services. This may also include payment details for our Advisors and Clients. We may also collect certain personal and business information from third parties, always in the context of our services. Under GDPR, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies: - you have given consent to the processing of your personal data for one or more specific purposes; - processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract; - processing is necessary for compliance with a legal obligation to which we are subject; Processing is necessary to protect the vital interests of you or of another natural person; - Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or - Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

4. How We Use What We Collect

We use the information we collect about you to facilitate your participation in our services. If you are an Advisor, we may use the collected information to verify your professional history. We may also disclose information about you to prospective Clients in order to promote our business to them and to existing Clients who may be interested to engage with you. If you are a Client, we may use the information we collect about you in order to identify Advisors who might be of interest to you. We may share your information with them. We may also use information about you to: Present site content effectively to you. Provide information, products and services that you request, or (with your consent) which we think may interest you. Carry out our contracts with you. Allow you to use our interactive services if you want to. Tell you our charges. Tell you about other goods and services that might interest you. We will also let other people do this, and we (or they) may contact you. If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you. If you are a new customer, you will only be contacted if you agree to it. If you don't want to be contacted for marketing purposes, please email us at info@orbitpartners.com. In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section, you can let us know at any time by contacting us at info@orbitpartners.com and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible service to you. In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.

5. Where We Store Your Data

We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA. By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure. Payment will be encrypted. If we give you a password, you must keep it confidential. Please don't share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts. We only keep your personal data for as long as we need to in order to use it as described above in section 4, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.

6. Disclosing Your Information

We are allowed to disclose your information in the following cases: - If we decide to sell our company, we can disclose it to the potential buyer. - We can disclose it to other business in our group. - We can disclose it if we have the legal obligation to do so, or in order to protect other people’s property, safety or rights. - We can exchange information with others to protect against fraud or credit risks. We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.

7. Your Rights

You can ask us not to use your data for marketing. You can do this by contacting us at any time info@orbitpartners.com. Under the GDPR, you have the right to: Request access to, deletion of or correction of, your personal data held by us at no cost to you; - Request that your personal data be transferred to another person (data portability); Be informed of what data processing is taking place; Restrict processing; To object to processing of your personal data; and Complain to a supervisory authority. You also have rights with respect to automated decision-making and profiling as set out in section 10 below. To enforce any of the foregoing rights or if you have any other questions about our site or this Privacy Policy, please contact us at info@orbitpartners.com.

8. Links to Other Sites

Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. 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.

9. Changes

If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also email you.

10. Automated Decision-Making and Profiling

10.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.

10.2 The right described in section 10.1 does not apply in the following circumstances: a) the decision is necessary for the entry into, or performance of, a contract between the you and us; b) the decision is authorised by law; or c) you have given you explicit consent.

10.3 Where we use your personal data for profiling purposes, the following shall apply: a) Clear information explaining the profiling will be provided, including its significance and the likely consequences; b) Appropriate mathematical or statistical procedures will be used; c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented

11. Dispute Resolution

11.1 The Parties will use their best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

11.2 If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.