1. PERSONAL INFORMATION WE COLLECT
Orbital Insight collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).We may collect Personal Information in a variety of ways, including, but not limited to, when Individuals visit or register on the Site, fill out a form, respond to a survey, and in connection with other activities, Services, features or resources we make available. As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below. The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Orbital Insight and the requirements of applicable law.
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with Orbital Insight, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
- Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Orbital Insight’s newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
- Surveys. From time to time, we may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.
- Posting on the Site. Orbital Insight may offer publicly accessible pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Orbital Insight’s pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
- Registration for Sweepstakes or Contests. Occasionally, Orbital Insight may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.
- Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
Information Submitted Via Services. You agree that Orbital Insight is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Orbital Insight will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Orbital Insight and to enhance our ability to provide you with information about our business, products, and Services.
2. NON-PERSONAL, ANONYMIZED, AND AGGREGATED INFORMATION
We may collect Non-Personal Information whenever Individuals interact with our Site. Non-Personal Information may include the browser name, the type of computer and technical information about means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information. Orbital Insight also may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Orbital Insight’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Orbital Insight may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Orbital Insight and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
3. COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on third party Sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
4. HOW WE USE COLLECTED INFORMATION
Orbital Insight may collect and use Personal Information for the following purposes:
- To Provide Products, Services, or Information Requested: For example, to run and operate our Site, including to display content on the Site correctly and provide access to certain areas, functionalities, and features of the Services; to send emails and updates pertaining to an order, and to respond to inquiries, questions, and/or other requests; to manage Individual information and Accounts; and to improve customer service, respond to your customer service requests, and support needs more efficiently.
- Administrative Purposes: For example, to improve our Site personalize user experience, verify Individual identity, and improve and/or develop products and services; communicate about Individual Accounts and activities on Orbital Insight’s Services and systems and, in Orbital Insight’s discretion, changes to any Orbital Insight policy; understand how our customers as a group use the Services and resources provided on our Site; and prevent potentially prohibited or illegal activities and to enforce our Terms.
- Marketing Orbital Insight Products and Services: For example, to run a promotion, contest, survey or other Site feature;. to tailor content, advertisements, and offers; to send periodic emails with information about topics (including offers, products, and services) that we think will be of interest; for other purposes disclosed at the time that Individuals provide Personal Information; or otherwise with your consent.
- Research and Development: For example, to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Orbital Insight may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf.
- Direct Mail, Email and Outbound Telemarketing: For example, Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Orbital Insight’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest.
- Services via Mobile Devices: From time to time, Orbital Insight may provide Services that are specifically designed to be compatible and used on mobile devices. Orbital Insight will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. In addition, Orbital Insight may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices.
- Other Uses: Orbital Insight may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
5. HOW WE PROTECT YOUR INFORMATION
We adopt appropriate data collection, storage and Processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
6. SHARING YOUR PERSONAL INFORMATION
- We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Orbital Insight has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners. Orbital Insight may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Orbital Insight may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Orbital Insight. Orbital Insight requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Orbital Insight provided them.
- Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
- Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Orbital Insight may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Orbital Insight related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 6 below.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Orbital Insight policies or contracts; (v) to collect amounts owed to Orbital Insight; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
- In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
7. DATA TRANSFERS
All Personal Information collected via or by Orbital Insight may be stored anywhere in the world, including but not limited to, in the United States, Japan, [add any other jurisdictions,] in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Orbital Insight, you consent to the storage of your Personal Information in these locations.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States, Japan[, and any other jurisdictions]and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
8. OPT-OUT (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Orbital Insight’s Processing of your Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting [insert alias]. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
9. RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
Although Orbital Insight makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Orbital Insight is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Orbital Insight determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Orbital Insight will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
10. DATA RETENTION
11. THIRD-PARTY WEBSITES AND SOCIAL MEDIA PLATFORMS
You may find advertising or other content on our Site that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Orbital Insight’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
13. YOUR ACCEPTANCE OF THESE TERMS
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
14. CHILDREN’S PRIVACY
The Services are not directed to children under 16 years of age, and Orbital Insight does not knowingly collect Personally Identifiable Information from children under 16 years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 16 years old, we will promptly take steps to delete such information and terminate the child’s Account.
15. CALIFORNIA PRIVACY RIGHTS
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Orbital Insight does not share Personal Information with Third Parties for their own marketing purposes.
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Orbital Insight or to which Orbital Insight discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person.
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Orbital Insight or Orbital Insight’s Agents.
Last revised November 13, 2018