米乐体育M6官网首页
Last updated on 27th May 2020.
Introduction
Welcome to Orbit Labs Ltd’s privacy policy.
This privacy policy applies to all individuals accessing Orbit (“ users ”), including organisers of events and/or communities on Orbit. When we refer to “Orbit” we mean orbitapp.io and all services provided via Orbit.
Orbit enables people to create and/or participate in a professional community dedicated to an interest, event, place, brand or business (an “ Orbit Community ”) for free or for a fee. Users who create an Orbit Community (“ Organisers ”) do so to invite in people (“ Members ”) to connect with each other, through discover, messaging and discussion, and to exchange information and content. You are aware that your profile and certain other information will be shared with other users including Organisers and/or made publicly available as well as recommendations being made to other users to connect with you or to invite you to certain Orbit Communities (as discussed further below).
Orbit Labs Ltd (“ we ”, “ us ” or “ our ”) respects your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit Orbit and tells you about your privacy rights and how the law protects you. It also aims to give you information on how we collect and process your personal data through your use of Orbit, including any data you may provide when you sign up for an account.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
Who we are and important information
Controller & Contact Details
The controller of Orbit is Orbit Labs Ltd of 2 Manor Farm Court, Old Wolverton, Milton Keynes, Buckinghamshire, England, MK12 5NN. We have appointed a data protection officer (“ DPO ”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO at . or write to the DPO at Orbit Labs Ltd, 2 Manor Farm Court, Old Wolverton, Milton Keynes, Buckinghamshire, England, MK12 5NN.
You have the right to make a complaint at any time to the Information Commissioner's Office (“ ICO ”), the UK supervisory authority for data protection issues ( www.ico.org.uk ). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Orbit may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Orbit, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity & Contact Data includes name, username or similar identifier, email address, location and telephone number.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Orbit.
- Transactional Data includes details about payments to and from you and other details of services you have purchased from us.
- Usage Data includes information about how you use Orbit.
- Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Profile Data includes information available on you profile such as your job role or description, organisation, employer’s name, industry, biography, skills and links.
We also collect and use aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of Orbit. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity & Contact Data by opening an account, subscribing to our services or by corresponding with us as well as your Profile Data when you set up your profile.
- Indirect interactions. We will learn information about you from your use of the interactive functions on Orbit, such as when you enter into discussions with other users and post or upload content to Orbit. We may also learn about you from other users who post content that includes information about you.
- Automated technologies or interactions. As you interact with Orbit, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our Cookie Policy for further details.
-
Third Parties.
We will receive personal data about you from various third parties as set out below:
- Identity & Contact Data from organisers. We may be provided with your Identity & Contact Data from organisers (or on behalf of organisers via other organisations such as ticketing providers) for the purposes of inviting you to use Orbit or join a community and/or event. We rely on those third parties to have the right to share your data with us. You should review their privacy policies for more information.
- Technical Data from analytic providers (such as Google).
- Identity & Contact Data and/or Profile Data from other providers, such as LinkedIn where you consent to us populating your Orbit profile using the details from your LinkedIn profile. This may also include other services that you agree to us integrating with for the purpose of populating your profile. You can withdraw your consent at any time by disconnecting your LinkedIn account (or other relevant account) from Orbit. This can be done in your LinkedIn settings (or other relevant account settings).
- Identity & Contact Data and/or other personal data from users of Orbit (as discussed above), including where they post about you or join in discussions with you.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- where we need to comply with a legal obligation.
Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
On Boarding
To contact you to invite you to become a user or join a community or event.
To set up a temporary account for you.
(a) Identity & Contact Data
(a) Necessary for our legitimate interests (to promote Orbit, obtain new users and perform services for our users and/or organisers).
Account Setup
To assess applications for accounts and to open, set up, close your account and otherwise manage your account including to set up your profile.
(a) Identity & Contact Data
(b) Profile Data
(a) Performance of a contract with you.
(b) Necessary for legal obligation.
Services
To provide and administer our services throughout your relationship with us.
This includes enabling you to join communities, events and join in discussions and/or post content to Orbit as well as to connect with other users. As part of this, your data will be shared (as discussed further in the sharing section below).
(a) Identity & Contact Data
(b) Profile Data
(c) Marketing and Communications Data
(b) Necessary for our legitimate interests (to promote Orbit, provide services including to other users and organisers, enable all to connect and share content and connect).
Relationship Management
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) where applicable, manage payments, fees and charges.
NB. When you make a payment your financial details (such as payment card information) will be collected and processed securely by Stripe.
This includes enabling you to join communities, events and join in discussions and/or post content to Orbit as well as to connect with other users. As part of this, your data will be shared (as discussed further in the sharing section below).
(a) Identity & Contact Data
(b) Profile Data
(c) Marketing and Communications Data
(d) Transaction Data
(e) Usage Data
(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated and to study how our services and Orbit are being used and to recover payments due or to make payments).
Communication
To respond to your enquiry submitted on Orbit, or via phone, email, post or otherwise.
(a) Identity & Contact Data
(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (where you have made contact with us prior to entering into a contractual relationship with us).
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
(a) Identity & Contact Data
(b) Profile Data
(c) Usage Data
(d) Marketing and Communications Data
(e) Technical Data
(a) Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy).
To administer and protect our business and Orbit (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
(a) Identity & Contact Data
(b) Technical Data
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation.
To use data analytics to improve Orbit, our services, marketing, customer relationships and experiences.
This may also include analysing the data we collect for the purpose of providing recommendations to users (such as recommendations of users to connect with, communities to join, events to attend and relevant or useful content). NB. See paragraph headed ‘Profiling’ below.
(a) Technical Data
(b) Marketing and Communications Data
(c) Usage Data
(d) Profile Data
(e) Identity & Contact Data
(a) Necessary for our legitimate interests (to define types of customers for our services, to keep Orbit updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you or to other users and/or organisers about communities, events, users to connect with and relevant or useful content and/or services that may be of interest.
NB. Where we recommend to other users that they should connect with you, we will only share your Profile Data.
(a) Identity & Contact Data
(b) Technical Data
(c) Marketing and Communications
(d) Usage Data
(e) Profile Data
(a) Necessary for our legitimate interests (to develop Orbit and our services and grow our business).
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity & Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing). You can manage your preferences (such as unsubscribing from marketing emails) by amending the settings in your account.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of Orbit may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy .
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us on .
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Sharing of your personal data
Your profile (which will include Profile Data) is visible to other users and publicly available to anyone with a link. You should be mindful of the content you include on your profile. Users will also have visibility of public communities other users are a part of as well as those communities in common. Users will also have visibility of connections in common.
When you connect with other users they will have access to your profile (which will include Profile Data and Identity & Contact Data) as well as any other content, information, discussions or posts you share with those users. They will also be able to see your connections in common with other users as well as events you will be attending and events in common. When you join communities, you understand that this is a space for people to connect and interact and, as such, all users within that community can see the profiles (which will include Profile Data) of all users who are members of that community as well as any information or content posted within that community (including announcements and opportunities) and all discussions that take place. If you join sub-communities for specific events, you understand that as per communities, all users attending the event can see the profiles (which will include Profile Data) of the other users in that sub-community who are attending the event as well as the discussions, announcements and opportunities posted. All those who have joined communities, events / sub-community will be able to see the event / community details (where applicable) and sponsor information (where applicable).
If you join an Orbit community your Profile Data and Identity & Contact Data may be available to the organiser in order to facilitate communications. An organiser may use this data solely to communicate with a members for purposes related to the Orbit community or the reasonably assumed interests of the Member who has joined the Orbit community. You may also decide to give organisers other information beyond what is available via your profile – if you choose to do so, you understand that the organiser will be acting as the controller of this data and must ensure you review their privacy policy. We are not responsible for the actions of these organisers or their Orbit communities. In addition to this, organisers are provided access to certain Data, which may be aggregated or personalised, in order to facilitate member engagement and communications. Any posts, replies or content posted in a community or event will be viewed by those within that community or event/sub-community. It may be possible for users to reply your posts. You can also send direct message to other users.
We may share your Profile Data with other users and/or organisers to make recommendations. These recommendations could be people to connect with, communities to join, events to attend and relevant or useful content.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5 above:
- External Third Parties as set out in the Glossary .
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention - how long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us on .
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Glossary
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us on .
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Third Parties
External Third Parties
- HM Revenue & Customs, law enforcement agencies (including the Police), regulators and other authorities based in the United Kingdom.
- Payment providers for the purpose of handling payments.
- Service providers for the purpose of being provided IT and system administration services as well as hosting, support, maps & location and authentication.
- Error reporting services for the purpose of assisting us identify bugs.
- Analytics companies (such as Google Analytics) for the purposes of website analytics and reporting in respect of our analytics and marketing.
- Professional advisers including lawyers, bankers, auditors and insurers for the purpose of providing consultancy, banking, legal, insurance and accounting services.
- Marketing agencies to allow us to send marketing communications to you and to make sure the marketing communications are relevant.
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.