Privacy Policy

1. Introduction

Orbiton, Inc. ("the Company," "we," "us," or "our") operates the website getorbiton.app (the "Service"), an AI-assisted investor-relations drafting platform designed for IR teams at listed mining and energy companies. This Privacy Policy describes what information the Company collects, how we use it, who we share it with, and the rights you have over your data.

Our core service processes IR documents -- quarterly reports, earnings releases, analyst Q&A transcripts, and related filings -- submitted by subscriber IR teams. That material is processed solely to generate draft disclosures and Q&A responses in the submitting company's registered voice. We do not use submitted filing content to train AI models without explicit written consent from the account holder.

The Company is based at 555 17th Street, Suite 3200, Denver, CO 80265, and can be reached at [email protected].

2. Information We Collect

2.1 Information You Provide

We collect information you submit directly, including:

• Contact details (name, email, phone number) when you fill out a form, request a pilot, or subscribe to updates;
• Professional and company information (employer name, issuer entity type, stock exchange, role) that you choose to share;
• IR source documents -- prior quarterly filings, earnings releases, analyst correspondence -- uploaded by subscriber accounts for voice calibration and draft generation;
• The content of messages you send us through the contact form or by email.

2.2 Information Collected Automatically

When you visit getorbiton.app, we automatically collect limited technical information:

• IP address and approximate location (city and region level, not precise coordinates);
• Browser type, operating system, and device class;
• Pages visited, referring URLs, and time on page;
• Cookie and similar session identifiers (see Section 5).

2.3 We Do Not Knowingly Collect Children's Data

getorbiton.app is a professional B2B platform not directed to persons under 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us information, contact [email protected] and we will delete it promptly.

3. How We Use Information

The Company uses the information we collect to:

• Operate and deliver the Orbiton IR drafting platform, including voice calibration, draft generation, and Q&A bank services;
• Respond to inquiries from IR managers, CFOs, and investor-relations professionals evaluating or using the Service;
• Maintain, improve, and debug the Service;
• Send service notifications and, where your consent is required by applicable law, product updates or marketing communications;
• Detect, investigate, and prevent fraud, abuse, or unauthorized access;
• Comply with legal and regulatory obligations applicable to the Company.

We do not sell personal information for monetary value. Uploaded IR filing content is used only to provide the contracted drafting service to the account that submitted it. Where applicable state law treats certain advertising arrangements as a "sale" or "share," see your state's section below.

4. Sharing of Information

The Company shares personal information only in the following circumstances:

• With service providers acting on our behalf -- such as cloud hosting, email delivery, and site analytics -- under contractual confidentiality and data-processing terms that restrict their use of the data;
• With law enforcement or regulatory authorities when required by law, legal process, or to protect the rights, safety, or property of the Company, our users, or third parties;
• With a successor entity in the event of a merger, acquisition, or asset sale, subject to the terms of this Policy and appropriate notice.

We do not sell personal information to third parties, and we do not share subscriber IR filing content with any third party for purposes outside of service delivery.

5. Cookies and Tracking

The Company uses cookies and similar technologies to operate the site, maintain session state, remember preferences, and measure aggregate usage. For a full breakdown of cookie categories and how to manage them, see our Cookie Policy.

6. Data Retention

We retain personal information only as long as necessary for the purposes described in this Policy, to fulfill our contractual obligations to subscriber accounts, to comply with legal or accounting requirements, and to resolve any disputes. Specifically:

• Subscriber IR filing content is retained for the duration of the active subscription and deleted within 90 days of account termination, unless the subscriber requests earlier deletion;
• Contact form inquiries and marketing-list records are purged after 24 months of inactivity;
• Server access logs are retained for 90 days, then aggregated into anonymous statistical summaries.

7. Security

The Company applies administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, or loss. These include TLS encryption for data in transit, access controls on databases and file storage, and least-privilege access policies for the Company's personnel. No system is perfectly secure; we cannot guarantee absolute security, and we encourage subscribers to use strong passwords and to report any suspected unauthorized access to [email protected].

8. Your General Rights

Depending on your jurisdiction, you may have rights including access to the personal data we hold about you, correction of inaccuracies, deletion of your data, restriction or objection to certain processing, and data portability. To make a request, email [email protected]. The Company will respond within the timeframe required by applicable law.

9. Colorado Residents (CPA)

Under the Colorado Privacy Act ("CPA"), Colorado residents have the following rights with respect to personal data we control. Orbiton's subscriber base includes IR teams at companies headquartered or operating in Colorado, and this section applies to Colorado residents who use the Service or contact the Company in any capacity.

9.1 Your CPA Rights

• Right of Access: confirm whether we are processing your personal data and obtain a copy.
• Right to Correction: correct inaccuracies, considering the nature and purposes of processing.
• Right to Deletion: request deletion of personal data concerning you.
• Right to Data Portability: obtain a portable copy where technically feasible (up to twice per year).
• Right to Opt Out: opt out of (a) targeted advertising, (b) sale of personal data, and (c) profiling that produces legal or similarly significant effects.

9.2 Universal Opt-Out Mechanism

We honor browser-transmitted universal opt-out signals, including the Global Privacy Control ("GPC"), as a request to opt out of sale and targeted advertising. Configuring GPC in your browser is sufficient -- no separate request is required.

9.3 How to Exercise

Submit a request by emailing [email protected]. We respond within 45 days; one 45-day extension is available where reasonably necessary, with notice.

9.4 Appeal

You may appeal a denial by replying to our response email. If we maintain the denial, you may contact the Colorado Attorney General at coag.gov.

10. California Visitors

If you are a California resident, you may also exercise the rights granted under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, and the right to opt out of sale or sharing. The Company does not sell personal information and does not "share" personal information for cross-context behavioral advertising.

To submit a CCPA/CPRA request, email [email protected] with the subject line "California Privacy Request."

11. Changes to This Policy

We may update this Policy from time to time. Material changes will be reflected by a new "Last updated" date at the top of this page and, where appropriate, a notice on the Service. We encourage you to review this Policy periodically.

12. Contact

Questions, requests, or complaints about this Policy can be sent to:

Orbiton, Inc.
555 17th Street, Suite 3200
Denver, CO 80265
United States
Email: [email protected]
Phone: +1 (303) 553-9612