Effective: September 1st, 2023
This Policy applies only to information collected through the Services and therefore does not apply to data we collect in other contexts
We collect personal and other information from you directly when you provide it to us through the Services. We may also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Services.
Personal information you provide. You can visit the Services without submitting any information that we can use to identify you personally. However, if you use certain features on the Services, such as the “Connect with Us” feature, you may be required to provide personal information. Such information could include, for example, your name, email address, or phone number.
Personal information collected in connection with community accounts. We will also collect the following information from the people who organize communities (“Community Managers”) and members of the communities (“Community Members”):
Community Managers. If you are a Community Manager, we will collect information from you in order to create your account and organize your community. This information may include your name and contact information (such as email address and phone number). We will also collect information about your community. This may include your community’s name, the type of community you are registering (school, business, etc.), your community’s address, the email addresses of the Community Members that you plan on registering, and any other information
that you choose to provide about your Community Members.
Community Members. If you are a Community Member, we will collect information from you and your Community Manager as part of creating your account. This information may include your name, contact information (email address and phone number), the topics you are interested in discussing, your time zone, your availability to connect with other Community Members, information about you relevant to the community (such as your position or role in your community), and any information available on your LinkedIn page. We will also collect information relating to your use of our Services. This information may include information relating to your meetings with other Community Members, including the date and time of these meetings, survey answers that you provide regarding those meetings, and information made available to us through video teleconferencing services (such as the length of these meetings).
Cross-account linking. For Community Members, we will collect the information above for all of the communities that you are a member of and connect your account with all of your communities (through your email address) so that you can access different communities through a single account. We also use the information that you provide to us through all of your communities to create a profile about you that improves our ability to provide you with better matches.
Web log data. When you use the Services, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Services, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Services, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
Web beacons. The Services or the emails that you receive from Orbiit may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it can allow an email sender to determine whether a user has opened a particular email.
Third-party plugins. Our Services may include plugins from other companies, including social media companies (e.g., the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.
Third-party online tracking and behavioral advertising. We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Services or in email communications from us. This information may be used for a variety of purposes, including online interest-based advertising, as discussed below (see the section entitled “With Whom and Why We Share Your Information”).
We use the information that we collect for a variety of purposes. Our legal bases for processing your personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3) your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.
The purposes for which we collect your personal information include, for example:
- To provide you with our Services. We use your information to provide you with our Services. For example, we use your information to fulfill your requests for our Services or otherwise complete a transaction that you initiate, such as a purchase, as well as to fulfill the terms of any agreement you have with us, such as your annual Community Subscription.
- For operations and customer service support/inquiry information. We use your information to respond to your inquiries about the Services and in order to improve our Services (such as where you notify us of a problem with the Services). We may also use your data to operate our Services (e.g., delivering confirmations, account information, notifications, and similar operational communications).
- For newsletters, updates, and marketing messages. We may use your data to make suggestions and recommendations to you and other users of the Services about topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional messages.
- For personalizing and improving our Services. We may use your data to improve your user experience and enhance our Services, such as to improve our artificial intelligence and machine learning processes.
- For internet-based advertising. We may also use your information to inform online interest-based advertising.
- For website analytics. We may use your information to conduct research concerning the Services, such as count and recognize visitors to the Services, as well as analyze how visitors use the Services.
- Policy enforcement and safety. We may use your personal information as needed to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel or customers, or others.
- Legal requirements. We may use your data as needed to comply with legal and/or regulatory requirements.
From time to time, Orbiit may use the information we have collected about you to compile aggregated and de-identified statistics or reports. Such aggregated or deidentified information will not identify you personally.
We may also link information gathered through the Services with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy
We share your information with other parties for a variety of purposes, as described below.
To provide our Services. If you are a Community Member, we will share information about your use of our Services with your Community Manager. This information may include information about your meetings with other Community Members, including your survey answers regarding your meetings. We will also share information about your role in the community and any information available on your LinkedIn page to other Community Members as part of introducing Community Members to one another.
We may also share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Interest-based Advertising. The Services also enable third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties may use the fact that you visited our Services to target online ads to you. In addition, our third-party advertising networks might use information about your use of our Services to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Services currently do not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.
Third-party service providers. Orbiit uses third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, video conferencing services, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.
Legal purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:
- To comply with applicable law or a court order, subpoena, or other legal process;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- To establish, protect, or exercise our legal rights or defend against legal claims; or
- To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
If you want to learn more about the personal information that Orbiit has about you, or you would like to update, change, or delete that information, please contact us by email at [email protected].
You may also opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at [email protected].
If you are a resident of a jurisdiction with an applicable data privacy law, you may have certain rights available to you in relation to your personal information. These rights may include:
- The right to be informed about our data collection practices;
- The right to access and correct your data;
- The right to erase or delete your data;
- The right to data portability;
- The right to opt out of the sale or sharing of your information;
- The right to opt out of targeted advertising;
- The right to opt-out of marketing emails and text messages;
- The right to limit our use of certain automated decision-making processes (including for profiling purposes); and
- The right to withdraw consent (to the extent applicable); and
- The right to confirm whether personal information about you is being processed.
Please note that not all of the rights listed above may be applicable to our data practices. For example, we do not use your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects and, depending on your jurisdiction, we also may not be considered to be “selling” your personal information.
To exercise any of the applicable rights listed above, please contact us via email at [email protected]. We will respond to your request as soon as reasonably possible and within the timeframe required under applicable law and will allow you to appeal any decision we make in response to such request in accordance with applicable law. Prior to complying with your request, we will first verify your identity by comparing the information you provide with the information we have on file for you.
Additionally, you may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.
You may appeal any decision we make regarding your privacy rights by contacting us at [email protected]. Depending on your jurisdiction, you may also have the right to lodge a complaint to your local supervisory authority.
We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no website is 100% secure, and we cannot ensure or
warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk
The information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. Orbiit may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any personal or other information to us, you expressly consent to such transfer and processing.
If you are a resident of the European Union, we may rely on the EU-U.S. Data Privacy Framework (as described below) or other appropriate data transfer mechanisms with regard to the transfer of your personal information from the EEA.
Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Orbiit’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Orbiit remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Orbiit proves that it is not responsible for the event giving rise to the damage.
In compliance with the Data Privacy Framework Principles, Orbiit commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Orbiit by email at [email protected]
Orbiit has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.
Under certain limited conditions, if your complaint is not resolved through these channels, it may be possible for individuals to invoke binding arbitration before the EU-U.S. DPF Panel to be created by the U.S. Department of Commerce and the European Commission. For additional
information, please visit https://www.dataprivacyframework.gov/s/article/ANNEX-Iintroduction-dpf?tabset-35584=2.The Federal Trade Commission (FTC) has jurisdiction over Orbiit’s compliance with the EU-U.S. DPF, Swiss – U.S. DPF, and the UK Extension.
Advisory: For UK and Swiss individuals, please note that we may continue to rely on alternative valid data transfer mechanisms deemed appropriate by the relevant authorities to transfer data collected from Switzerland and the UK to the U.S., such as standard contractual clauses and the UK International Data Transfer Agreement or Addendum as appropriate, until those jurisdictions approve the DPF as a valid data transfer mechanism.
Content on the Services is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.
We may make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Site, so you should review this page periodically.