Legal - Privacy Policy

1. Information We Collect

Information You Provide to Us

We collect information you provide directly to us, such as when you contact us through our website, subscribe to our newsletter, or engage our services. This may include:

• Name and contact information (email, phone, address)
• Company information and job title
• Project requirements and technical specifications
• Communications and correspondence
• Payment and billing information
• Feedback and survey responses

Information We Collect Automatically

When you visit our website, we automatically collect certain information about your device and usage:

• IP address and geolocation data
• Browser type and version
• Device information and operating system
• Pages visited and time spent on our site
• Referring website and search terms
• Cookies and similar tracking technologies

2. How We Use Your Information

We use the information we collect to:

• Respond to your inquiries and provide our services
• Send you updates and communications about our services
• Improve our website and services
• Comply with legal obligations

3. Information Sharing

We do not sell, trade, or otherwise transfer your personal information to third parties without your consent, except as described in this privacy policy. We may share information in the following circumstances:

• With service providers who assist us in operating our business
• To comply with legal requirements or protect our rights
• In connection with a business transaction

4. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication systems
• Secure hosting and backup procedures
• Employee training on data protection

5. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law. Generally:

• Contact information: Until you request deletion or 3 years after last contact
• Project data: 7 years after project completion for tax and legal purposes
• Website analytics: 26 months from collection
• Marketing communications: Until you unsubscribe

6. International Data Transfers

We are based in the Isle of Man, which has been recognized by the European Commission as providing adequate protection for personal data. However, your personal information may be transferred to and processed in other countries. When we transfer data outside of adequate jurisdictions, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by the European Commission
• Adequacy decisions by the European Commission for specific countries
• Binding corporate rules where applicable
• Certification schemes and approved codes of conduct
• Explicit consent where required and appropriate

Data Controller Information: Orthogonal Ltd (Company Registration: [Registration Number]) is the data controller for the purposes of applicable data protection laws.

7. Legal Basis for Processing

We process your personal information under the following legal bases:

• Contract: To perform our services and fulfill contractual obligations
• Legitimate interests: To improve our services and communicate with you
• Consent: For marketing communications and optional services
• Legal obligation: To comply with tax, accounting, and legal requirements

8. Your Rights

Under applicable data protection laws, you have the right to:

• Access your personal information and obtain a copy
• Correct inaccurate or incomplete information
• Request deletion of your information (right to be forgotten)
• Object to processing of your information
• Restrict processing in certain circumstances
• Data portability for information you provided
• Withdraw consent at any time (where processing is based on consent)
• Lodge a complaint with a supervisory authority

To exercise these rights, please contact us using the details provided below. We will respond to your request within one month of receipt (or two months for complex requests). Some rights may not apply in all circumstances, and we may need to verify your identity before processing your request.

Data Protection Officer: For data protection matters, you can contact our Data Protection Officer at dpo@orthogonal.im or using the postal address provided below.

Supervisory Authority: You have the right to lodge a complaint with the Isle of Man Information Commissioner if you believe we have not complied with applicable data protection laws. Contact: inforights@gov.im or visit www.inforights.im

9. Cookies and Tracking

Our website uses cookies to enhance your experience. You can control cookie settings through your browser. For more information, please see ourCookie Policy.

10. Updates to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated policy on this page and updating the “Last updated” date.

11. Contact Us

If you have any questions about this privacy policy, please contact us:

Email: privacy@orthogonal.im