Privacy Policy

Introduction

Orbian is a financial services company providing supply chain finance programs to corporate buyers of goods and services and their suppliers.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes Orbian’s policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

For general legal policies including our underaged policy notice and Modern Slavery Act Statement, please see Legal Notices.

Topics

Data Protection Officer
How We Collect and Use (Process) Your Personal Information
Use of Orbian Websites
Cookie Notice
Privacy Policies of Other Websites
When and How We Share Information with Others
Transferring Personal Data from the EU to the US
Data Subject Rights
Supplemental Notice for California Residents
Supplemental Notice for Nevada Residents
Security of Your Information
Data Storage and Retention
Changes and Updates to the Privacy Policy
Contact Us
How to Contact the Appropriate Authority

Data Protection Officer

Orbian has offices in London (United Kingdom), Munich (Germany) and Carlsbad, CA (USA).

Orbian has appointed an internal data protection officer for you to contact if you have any questions or concerns about Orbian’s personal data policies or practices. Orbian’s data protection officer’s name and contact information are as follows:

Patrick Clark
Chief Legal Officer
2nd Floor, 34-37 Liverpool Street
London EC2M 7PP
United Kingdom
[email protected]
+44 (0) 208 051 8890

How We Collect and Use (Process) Your Personal Information

Orbian collects personal information about its customers. With a few exceptions, this information is limited to the kinds of information that can be found on a business card: first name, last name, job title, employer name, work address, work email, and work phone number. We use this information to provide customers with financial services and only those services for which our customers directly contract with us. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of Orbian services for the same purposes.

2.1. Personal Information You Give to Us Directly:

Customer

When you become an Orbian customer, we collect information about you including (but not limited to) your name, your employer’s name, your work address (including your country location), and your email address. We may also collect your personal email address, a personal mailing address, and a mobile phone number, although this is not typical.

We process your personal information for contract and payments administration, to deliver customer benefits to you, and to inform you of Orbian-related events, content and other benefits or opportunities associated with your Orbian account. Orbian may also use this information to help us understand our customers’ interests and requirements to better tailor our products and services to meet your needs.

Live Events and Web Conferences

Orbian hosts events throughout the year. These include in-person conferences as well as live web conferences (collectively, “Events”). If you register for one of our Events and you are a customer, we will access the information in your customer account to provide you with information and services associated with the Event. If you are not a customer and you register for one of our Events, we will collect your name and contact information, which we will store in our database(s) and use to provide you with information and services associated with the Event.

We keep a record of your participation in Orbian Events as an attendee. This information may be used to tell you about other Events and publications. It may also be used to help us understand our customers’ interests and requirements to better tailor our products and services to meet your needs.

Some of our Events in the future may be sponsored. In this case, Orbian will provide an attendee list to sponsors, co-sponsors, and exhibitors of our Events. Orbian may also allow sponsors, co-sponsors and/or exhibitors to send you material by mail once per sponsored Event, in which case Orbian will engage a third-party mailing service and will not share your mailing address directly with the sponsor/exhibitor. If you do not wish to have your information included in an attendee list or to receive information from sponsors, co-sponsors and/or exhibitors, you can express your preferences when you register for Events or you may contact Orbian directly at [email protected].

Publications

Orbian offers supply chain finance (“SCF”) related content for our customers. In addition to producing original content, Orbian also subscribes to news feeds and blogs produced by others which we may link to from an Orbian Website. This means you may find yourself on an Orbian Website or reading an email from the Orbian publications team and we will offer you a link to another organization’s website where you will find content on supply chain finance that we find relevant and useful to you. At these times, you will be leaving an Orbian Website. Orbian is not responsible or liable for content provided by these third-party websites or personal information they may gather from you.

You may wish to subscribe to Orbian’s publications without becoming a customer of Orbian. To receive Orbian news by email, you will need to create a “profile” with us which involves providing Orbian with at least your first name and last name, an email address, and the country in which you live. Orbian does not share this information with any third party other than to store the information in our cloud-hosted databases.

You may manage your Orbian subscriptions by subscribing or unsubscribing at any time. Please note that if you have set your browser to block cookies, this may have an impact on your ability to unsubscribe. If you have any difficulties managing your subscription or other communication preferences with Orbian, please contact us at [email protected].

Orbian uses Google Analytics to track how often people gain access to or read our content. We use this information in the aggregate to understand what content our customers find useful or interesting so we can produce the most valuable content to meet your needs.

Surveys

We also conduct surveys that we use to produce original research on supply chain finance. We do not track individuals but look at information in the aggregate only. Participation in surveys is voluntary.

Training

If you participate in an Orbian training, information session, Webex or the like, you may sign up directly in which case we collect your name and contact information directly from you. You may, alternatively, sign up for training – or be signed up for training – by or through a third party such as your own employer. Your personal information will be stored in our database (hosted by our cloud service provider) and may also be shared with our trainers. Orbian’s trainers have agreed not to share your information with others and not to use your personal information other than to provide you with Orbian products and services.

Your Correspondence with Orbian

If you correspond with us by email, the postal service, or another form of communication, we may retain such correspondence and the information contained in it and use it to respond to your inquiry, to notify you of conferences, publications, or other services, or to keep a record of your complaint, accommodation request, and the like. If you wish to have Orbian “erase” your personal information or otherwise refrain from communicating with you, please contact us at [email protected].

Note: if you ask Orbian not to contact you by email at a certain email address, Orbian will retain a copy of that email address on its master “do not contact” list in order to comply with your no-contact request.

2.2. Personal Information Collected Automatically

Automatic Collection of Personal Information

We may collect certain information automatically when you use our services, such as your approximate geographic location (city and country) derived from your IP address, language, and browser and device information. We may also automatically collect information regarding your use of our services, such as pages that you’ve visited before, during and after using our services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our services.

Cookie Policy

We may use cookies and other technologies (“Technologies”) to automatically collect information through your use of our services. Please see the Cookie Policy below for more information.

Operationally Necessary

This includes Technologies that allow you access to our services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our website functionality.

Performance-Related

We may use Technologies, including Google Analytics, to assess the performance of our services including as part of our analytic practices to help us understand how individuals use our services.

Social Media Platforms

Our services may contain social media buttons which might include widgets such as the “share this” button or other links to third party websites such as LinkedIn. These features may collect personal information such as your IP address and which page you are visiting on our websites and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

2.3. Purposes for Processing Your Data

As explained above, Orbian processes your data to provide you with the products or services you have requested and for which you have contracted with us. We use this information to refine our products and services to better tailor them to your needs and to communicate with you about other services Orbian offers that may assist you in your career or otherwise help you do your job relative to your company’s supply chain finance program or participation as a vendor therein.

2.4. Personal Information We Get from Third Parties

From time to time, Orbian receives personal information about individuals from third parties. This may happen if your employer is a corporate customer of Orbian and signs you up as an account manager for training.

2.5. What Happens If You Don’t Give Us Your Data

You can enjoy much of Orbian’s web content without giving us your personal data. Much of the information on the Orbian Websites is available even to those who are not customers. You can even enter only the minimal amount of information (name and contact information) to access information. Some personal information is necessary so that Orbian can supply you with the services you requested and contracted, and to authenticate you so that we know it is you and not someone else. You may manage your account subscriptions and opt-out of receiving marketing communication at any time.

Use of Orbian Websites

Orbian websites include orbian.com, orbiansupplier.com, orbiancardservices.com, and scfsupplier.com (the “Orbian Websites”). If any websites are added in the future, this notice will apply to any such websites.

As is true of most other websites, the Orbian Websites collect certain information automatically and store it in log files. The information may include the region or general location where your computer or device is accessing the internet, browser type, operating system, and other usage information about the use of the Orbian Websites, including a history of the pages you view.

We use this information to help us design our sites to better suit our users’ needs. We may also use this information to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences. The Orbian Websites also use session cookies, and persistent cookies related to analytics. The Orbian Websites do not track users when they cross to third party websites, do not provide targeted advertising to them, and therefore do not respond to Do Not Track (DNT) signals.

The Orbian Websites use cookies to improve the user experience and ensure that they are functioning effectively.

4.1. What are Cookies?

To provide you with a more personalized and responsive service we need to remember and store information about how you use the Orbian Websites. This is done using small text files called cookies. Cookies contain small amounts of information and are downloaded to your computer or other device by a server for the Orbian Websites. Your web browser then sends these cookies back to the Orbian Websites on each subsequent visit so that it can recognize you and remember things like your user preferences. You can find more detailed information about cookies and how they work at http://www.aboutcookies.org/.

Whenever you use the Orbian Websites, cookies and other technologies may collect information. By using the Orbian Websites you agree to our use of cookies as described in this Cookie Notice.

4.2. What Cookies Do We Use and Why?

Some of the cookies we use are necessary to enable you to move around the Orbian Websites and use their features such as accessing secure areas that may contain content for registered users.

We also use functional cookies to record information about the choices you have made and to allow us to tailor the Orbian Websites to our users. This information is usually anonymized and is not used for any purpose unrelated to the Orbian Websites. We or our service providers also use analytic services to help us understand how effective our content is, what interests our users have, and to improve how the Orbian Websites work. The Orbian Websites do not use targeting cookies to deliver targeted advertising on the Orbian Websites.

Please contact us by emailing [email protected] if you would like more detailed information on the cookies we use.

4.3. How to Control Cookies

By using the Orbian Websites you agree that we can place cookies on your computer or device as explained above. However, you can control and manage cookies in various ways. Please bear in mind that removing or blocking cookies can impact on your user experience and parts of the Orbian Websites may no longer be fully accessible.

4.4. Do Not Track and Browser Controls

Orbian does not track its customers when they cross to third party websites and does not provide targeted advertising, and therefore our websites do not respond to Do Not Track (DNT) signals.

However, most browsers will allow you to see what cookies you have and delete them on an individual basis or block cookies from particular or all websites. Be aware that any preference you have set will be lost if you delete all cookies, including your preference to opt-out from cookies as this itself requires an opt-out cookie to have been set. For more information on how to modify your browser settings to block or filter cookies, see http://www.aboutcookies.org/or http://www.cookiecentral.com/faq/.

4.5. Managing Analytics Cookies

You can opt-out of having your anonymized browsing activity within websites recorded by analytics cookies. We use Google Analytics, and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on following link: http://www.google.com/analytics/learn/privacy.html.

Privacy Policies of Other Websites

This website contains links to other websites. Our Privacy Policy applies only to Orbian websites, so if you click on a link to another website, you should read their privacy policy.

When and How We Share Information with Others

Information you provide to open an Orbian account is maintained in association with your Orbian customer account. The personal information Orbian collects from you is stored in one or more databases hosted by third parties located in the United States and the United Kingdom. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval.

We do not otherwise reveal your personal data to third parties for their independent use unless:

(1) You request or authorize it;

(2) It’s in connection with Orbian-hosted Events described above;

(3) The information is provided to comply with the law (for example, to comply with a search warrant, subpoena or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others;

(4) The information is provided to our agents, vendors or service providers who perform functions on our behalf;

(5) To address emergencies or acts of God; or

(6) To address disputes, claims, or to persons demonstrating legal authority to act on your behalf.

We may also gather aggregated data about our customers and site visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers and/or other third parties for marketing or promotional purposes.

Transferring Personal Data from the European Union to the United States

Orbian has its headquarters in the United States. Information we collect from you will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (GDPR). Orbian relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, Orbian collects and transfers personal data to the United States only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Orbian in a manner that does not outweigh your rights and freedoms. Orbian endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Orbian and the practices described in this Privacy Policy. Orbian also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.

Data Subject Rights

This Privacy Policy is intended to provide you with information about what personal data Orbian collects about you and how it is used. If you have any questions, please contact us at [email protected]. If you wish to confirm that Orbian is processing your personal data, or to have access to the personal data Orbian may have about you, please contact us at [email protected].

The European Union GDPR, United Kingdom General Data Protection Regulation, and other countries’ privacy laws provide certain rights for data subjects.

If you wish to confirm that Orbian is processing your personal data, or to have access to the personal data Orbian may have about you, please contact us at [email protected].

Right to Access: You may also request information about the purpose of the processing; the categories of personal data concerned; who else outside Orbian might have received the data from Orbian; what the source of the information was (if you didn’t provide it directly to Orbian); and how long it will be stored. You may also request copies of your personal data from Orbian.
Right to Rectification: You have a right to correct (rectify) the record of your personal data maintained by Orbian if it is inaccurate.
Right to Erasure: You may request that Orbian erase that data, subject to certain exceptions.
Right to Restrict Processing: You may also request that Orbian restrict the processing of your personal data, including ceasing using your data for direct marketing purposes.
Right to Data Portability: When technically feasible, Orbian will—at your request—provide your personal data to you or transmit it directly to another controller.
Right to Object to Processing: You have the right to object to Orbian’s processing of your personal data, under certain conditions.

Reasonable access to your personal data will be provided at no cost to Orbian customers, conference attendees and others upon request made to Orbian at [email protected]. If for some reason access is denied, Orbian will provide an explanation as to why access has been denied.

If you make a request, we have one month to respond to you, under the GDPR. If you would like to exercise any of these rights, please contact us at our email: [email protected].

Supplemental Notice for California Residents

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act (CPRA). The CCPA provides California residents with the right to know what categories of personal information Orbian has collected about them, and whether Orbian disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected by Orbian

Category of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers

A real name, alias, postal address, email address, account name, or other similar identifiers.

● Service providers

● Business partners

● Affiliates

● Other users or third parties you share or interact with

● Internet service providers

● Data analytics providers

● Government entities

● Operating systems and platforms

● Social networks

Internet or other electronic network activity

Browsing history, search history, information on a consumer’s interaction with an internet website, or application.

● Internet service providers

● Data analytics providers

● Operating systems and platforms

Geolocation data

Physical location (city and country).

● Internet service providers

● Data analytics providers

● Operating systems and platforms

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “How We Collect and Use (Process) Your Personal Information” above.

9.1. “Sales” of Personal Information under the CCPA

For purposes of the CCPA, Orbian does not “sell” personal information nor do we have knowledge of any “sale” of personal information of minors under 16 years of age.

9.2. Additional Privacy Rights for California Residents

Limit Use and Disclosure of Sensitive Personal Information. California residents may request that use of their sensitive personal information be limited.
Non-Discrimination. California residents have the right not to receive discriminatory treatment for the exercise of their rights conferred by the CCPA.
Right to Correct. California residents may request that we correct inaccurate personal information, using commercially reasonable efforts.
Right to Delete. California residents may request that we delete personal information that we collected from you and to tell our service providers to do the same. However, there are exceptions that may allow Orbian to keep your personal information.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.
Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

9.3. California Shine the Light. The California “Shine the Light” 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.

9.4. Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly viewable portions of the Services by contacting us directly as set forth in “Contact Us” below. However, Orbian does not offer or anticipate use of any Orbian Websites by anyone under the age of 21.

Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact Us” below.

Security of Your Information

To help protect the privacy of data and personally identifiable information you transmit to us, we maintain physical, technical, and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to only those employees who need to know that information to provide our services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

Data Storage and Retention

Your personal data is stored by Orbian on its servers, and on the servers of the cloud-based database management services Orbian engages located in the United States and in the United Kingdom. Orbian retains data for the duration of the customer’s business relationship with Orbian. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact Orbian’s data protection officer at [email protected].

Changes and Updates to the Privacy Policy

As Orbian and its services change from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy at this site. We may email periodic reminders of our notices and terms and conditions and will email Orbian customers of material changes thereto, but you should check Orbian Websites frequently to see the current Privacy Policy that is in effect and any changes that may have been made to it.

The provisions contained herein supersede all previous notices or statements regarding our privacy practices. This Policy was last updated on 21 November 2022.

Contact Us

If you have any questions, concerns, or complaints, please contact Orbian’s data protection officer:

Patrick Clark
Chief Legal Officer
2nd Floor, 34-37 Liverpool Street
London EC2M 7PP
United Kingdom
[email protected]
+44 (0) 208 051 8890

How to Contact the Appropriate Authority

If your personal information is subject to the applicable data protection laws of Australia, Brazil, Canada, the European Economic Area, Switzerland, or the United Kingdom, or the state of Virginia, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.

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