Orbital Privacy Notice

We take your privacy seriously. Please read this Privacy Notice and any other privacy notice or fair processing notice we may provide on specific occasions carefully, as it is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export and delete your information. 

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This Privacy Notice has been drafted to be applied to personal information processing activities globally. The processing activities may be more limited in some jurisdictions due to the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we may adjust our internal policies and/or practices to adapt to the requirements of local law.

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This Policy supplements our other notices and is not intended to override them.

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Please read the Privacy Notice carefully. By using the Website, you accept and agree to be bound and abide by our Privacy Notice. All information we collect on this Website is subject to our Privacy Notice. If you do not want to agree to the Privacy Notice, you must not access or use the Website.

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Important information and who we are

Orbital Materials is an industrial technology developer that is harnessing the power of AI to redefine the development of advanced materials and climate technologies at the pace our planet demands. We have offices in the US and UK. Orbital Materials, Inc. with office at 360 N Sepulveda Blvd #2000, El Segundo, CA 90245, USA) and Orbital Materials Ltd with registered office in the UK at Oak House, Tanshire Park, Shackleford Road, Elstead, Surrey, United Kingdom, GU8 6LB and Company Number 14332843). ‍

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Our contact details 

Please in the first instance contact us via our Privacy Team by email at info@orbitalmaterials.com 

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You can also contact us by mail at the following postal addresses: 

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If you are located in the UK:  Oak House, Tanshire Park, Shackleford Road, Elstead, Surrey, United Kingdom, GU8 6LB

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If you are located in the US/California: 360 N Sepulveda Blvd #2000, El Segundo, CA 90245, USA‍

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What is meant by personal data or personal information

Personal data (also called personal information) is information which identifies you as an individual. 

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Some examples are outlined below:

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Personal data is anything which may identify you, for example, your name, address, bank account details, internet protocol (IP) address, username or another identifier.

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Some personal data is unique to you and therefore requires greater protection. This data is referred to as sensitive or special category data which includes information regarding your health, religious or philosophical beliefs, race, or ethnicity to provide a few examples.‍

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How we get the information about you 

In order for us to operate effectively, we may request and collect information about you. We collect personal data from you: 

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- directly, when you provide us with information about you. This will occur when you enter or send us information, such as when you contact us (including via email or customer contact forms), send us curriculum vitaes, and participate in a recruitment process.

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- indirectly, when we receive information about you from a third party. This can occur when engaging with marketing agencies, using social media such as LinkedIn, Facebook, in the framework of our relationship with our partners.

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The data we collect about you

We collect personal information from the visitors to our website, our subscribers and from the job candidates who apply to our vacancies. We may collect, use, store and transfer different kinds of personal information about you depending on our relationship with you:

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Identity data: Personal identifiers, contacts and characteristics and any other identity data that you may include in your communication with us.‍

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Contact data:  this includes email address, name and address, telephone number(s) and addresses. ‍

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Location data: We may record your location or collect information on your country, state, county, region.‍

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Technical data: We may collect your IP address, your login data, browser type and version, time zone setting and location, browser plugin types and versions, operating system, and other technology on the devices you use to access our website.

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‍Usage data: Includes information about how you use our website.

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Candidate data: Includes information you have provided to us in your curriculum vitae, covering letter and/or collected during the application and interview process, including name, title, address, telephone number(s), personal email address, date of birth, job title, job role, location, employment history, qualifications, areas of specialisms and registrations with professional bodies.‍

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Marketing and communications data: Includes your preferences in receiving marketing from us, your newsletter subscription preference and our third parties and your communication preferences

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Sensitive or Special category Data

Sensitive or Special Category Data is personal data that needs more protection because it is sensitive, and we do not intend or wish to collect this type of personal data from you in the course of providing our services or during our interactions with you.

Where you choose to provide us with this information in your communication with us, we will only process that sensitive personal information in such jurisdiction if and to the extent permitted or required by applicable law.

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How we process and use your information

We need your personal information to conduct our business and provide you with our services. Most commonly we will use your personal information in the following circumstances:

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- Where you have consented before the processing.

- Where we need to perform a contract, we are about to enter or have entered 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.

- Where we need to comply with a legal or regulatory obligation.

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We will only collect, process and/or use the personal information where we are satisfied that we have an appropriate legal basis to do so. 

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If you are located in the EEA and UK: For more information on how we use and process your information, see the section called “UK and EEA Below”.

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If you are located in US/California: For more information on how we use and process your information see the section called “US/California Below".

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Withdrawing Consent

If we rely on your consent to process your personal information, which may be express or implied consent according to the applicable law, you have the right to withdraw consent at any time. You can withdraw your consent by contacting us at  info@orbitalmaterials.com

Please note that this will not affect the lawfulness of the processing before the withdrawal, nor when applicable law allows, will it affect the processing of your personal information on the basis of any other lawful ground other than consent.

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Safeguarding your personal information

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will review, monitor and update these security measures to meet our business needs, changes in technology and regulatory requirements. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties that have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. 

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Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we do not have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. 

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We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.‍

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Keeping your personal information

We will keep your personal information, in line with our retention policy and applicable law and for no longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. 

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To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

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Information Sharing

Insofar as reasonably necessary for us in delivering our products and services to you and for the purposes set out in this Privacy Notice, we may share your personal information with the below parties that help us manage our business and deliver our products, or services:

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- companies we work in partnership with 

- third parties we use to help deliver our products and services to you;

- other third parties we use to help us run our business, e.g. consultancies, marketing agencies or website hosts;

- third parties approved by you, eg social media sites you choose to link your account 

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We only allow those organisations to handle your personal information if we are satisfied, they take appropriate measures to protect your information. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

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We or the third parties mentioned above occasionally also share personal data with:

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- our and their external auditors, e.g., in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;

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- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;

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- law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations;

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- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including an investment, merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

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We will not share your personal data with any other third party without your consent.

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The specific kind of information we share will depend on your activities with us and only to the extent as required or permitted by law, and/or with your consent.

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Please note however that this Privacy Notice does not apply to sharing of personal information by third party providers who may collect personal information from you and may share it with us. In these situations, we strongly advise you to review the applicable third party provider’s privacy notice before submitting your personal information.

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Transferring your information overseas

We do business globally and may centralise certain aspects of our information processing activities and data storage in different countries. We may therefore have to share and transfer your personal information from one country to another, or even across multiple jurisdictions. Your personal information may therefore be subject to privacy laws that are different from those in the country where the personal information is collected or those in your country of residence. 

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We will ensure your personal information has an appropriate level of protection and will undertake appropriate due diligence and risk assessments prior to transferring the information. We will ensure the transfer of your personal information in line with applicable Data Protection Law. Often, this protection is set out under a contract with the organisation that receives your personal information. You can find more details of the protection given to your information when it is transferred overseas by contacting us.‍

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Third-party services, websites and plugins 

Please note however that this Privacy Notice does not apply to sharing of personal information by third party providers who may collect personal information from you and may share it with us. In these situations, we strongly advise you to review the applicable third-party provider’s privacy notice before submitting your personal information.

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You should be aware that information about your use of our website (including your IP address) may be retained by your ISP (Internet Service Provider), the hosting provider and any third party that has access to your Internet traffic.

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Our Website may contain links to third-party websites and plugins. If you choose to use these websites, plugins, or services, you may disclose your information to those third parties.  

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We are not responsible for the content or practices of those websites, plugins, or services. The collection use and disclosure of your personal information will be subject to the privacy notices of these third parties and not this Privacy Notice. We urge you to read the privacy and cookie notices of the relevant third parties.

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What Happens If you Don’t Provide your Information 

You may always choose what personal information (if any) you wish to provide to us. Please note, however, some of our products and services to you may be affected if you choose not to provide certain details, for example, we cannot reply to you without contact details.

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We also need your personal information to be able to assess your application for our vacant job roles.

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Opting out of Marketing 

If you provide us with your contact details (e.g., email address), we may contact you to let you know about the products, services, promotions, and events offered that we think you may be interested in. 

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You can unsubscribe from our marketing and promotional communications by contacting us at info@orbitalmaterials.com

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You will then be removed from the marketing list; however, we may still communicate with you for example to send you product related messages that are necessary to respond to your requests or for other non-marketing related purposes.

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Cookies and other tracking technologies

Each time you interact with our website, we may, depending on the consent provided and your jurisdiction, automatically collect personal information, including technical data about your device, your browsing actions and patterns, content and usage data. We collect this data using Cookies, server logs and other similar technologies like pixels, tags and other identifiers in order to remember your preferences, to understand how our website is used, and to customise our marketing offerings. 

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Please see more information in our Cookie Notice here.

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What are your Rights

In some regions and states, such as the EEA and UK, you have rights that allow you greater control of and access to your personal information.

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These rights may include the right:

- To request and obtain a copy of your personal information

- To request rectification and/or erasure

- To restrict processing of your personal information

- Data portability (if applicable)

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In certain circumstances you may also have the right to object to the processing of your personal data. You can make a request to exercise your rights by contacting us at info@orbitalmaterials.com  

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We will consider and act upon any requests in accordance with applicable data protection laws.

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Further information for EEA and UK 

We are subject to the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the UK and European Economic Area (EEA).

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Processing your personal information

Details about our processing of your personal information

The list below describes the ways we plan to use your Personal Data, and which Lawful Basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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Contracts

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Lawful Basis: We use your personal information on the basis that it is necessary for us to evaluate applications and candidates for a vacant role prior to entering into an employment contract for that role with the most suitable candidate.

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Examples include:

- Recruitment of candidates (contractors, employees and providers): We will use the personal information we collect about you to assess your skills, qualifications, and suitability for the role for which you applied. We may use the following personal data: Identity data, Contact data, Location data, Candidate data

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Legitimate interest

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Lawful Basis: When we rely on this, we will carry out a Legitimate Interests Assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under Data Protection Law.  Our legitimate business interests do not automatically override your interests – we will 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.  

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Examples:

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- Managing our business: We process Personal Data for our own legitimate business interest. This relates to us managing our business to enable us to maintain and monitor the performance of our website and to constantly look to improve the website, including when we respond to your queries and complaints. We may use the following personal data: Identity data, Contact data, Technical data, Marketing and communications data 

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- Provide and maintain our Websites: To provide and maintain our Website, including to monitor the usage of these, troubleshooting, data analysis, network security and system testing necessary for our legitimate interests in maintaining the useability, security and integrity of our website. We may use the following personal data: Identity data, Location data, Transaction data, Technical data

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- Recommendations and marketing: To make recommendations to you about the products or services that may interest you. We may use the following personal data: Identity data, Contact data, Technical Data, Marketing and communications data, Usage data. To measure and analyse the effectiveness of the advertising we serve you. We may use the following personal data: Identity data, Contact data, Location data, Technical Data, Marketing and communications data, Usage data. To make suggestions and recommendations to you about products or services that may be of interest to you and necessary for our legitimate interests (to develop our products/services and grow our business). We may use the following personal data: Identity data, Contact data, Location data, Technical Data, Marketing and communications data, Usage data

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- Rights and claims: To enforce or apply our Website terms of use, our policy terms and conditions, or other contracts. To exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with. We may use the following personal data: Identity data, Contact data, Transaction data, Technical data, Profile data, Usage Data.

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- Data subject rights: Verifying your identity when you exercise your data subject rights. Fulfilling data subject rights requests. We may use the following personal data:Identity data, Contact data, Location data, Technical data, Usage Data, Candidate Data.

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Legal obligations

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Lawful Basis: We may use your Personal Data to comply with laws (for example, if we are required to co-operate with a police investigation after a court order orders us to).

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Examples:

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- Legal requirement: The processing is necessary for compliance with legal obligations, such as but not limited security requirements. To comply with applicable law, for example in response to a request from a court or regulatory body, where such request is made in accordance with the law.

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- Criminal activity: To detect fraudulent or criminal activity, we may share information with forces such as the police.

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Consent

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Lawful Basis: We may have to get your consent to use your Personal Data, such as information about you or when we want to send you marketing. Wherever consent is the only reason for using your Personal Data, you have the right to change your mind and/or withdraw your consent at any time by clicking the Unsubscribe button at the bottom of an applicable email or by contacting us.

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Examples: 

- Marketing: To measure and analyse the effectiveness of the advertising we serve you. We may collect IP addresses and store Cookies on visitors’ devices. We may use the following personal data, depending on what you consent to: Identity data, Contact data, Location data, Technical data, Marketing and communications data, Usage data, Candidate data.

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- Data analytics: We use data analytics to improve our website, products/services, marketing, customer relationships and experiences. We may use the following personal data: Identity data, Transaction data, Technical data, Profile data, Usage data ‍

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Your Rights

Please see more details about your rights below. In most circumstances, you do not need to pay any charge for exercising your rights. We have one month to respond to you.  

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1. Right to be informed: We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal information and our use of it. We have written this notice to do just that, but if you have any questions or require more specific information.

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2. Right of access: You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information. When you request this data, this is known as making a data subject access request (DSAR). In most cases, this will be free of charge; however, in some limited circumstances, for example repeated requests for further copies, we may apply an administration fee. 

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3. Right to rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. 

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4. Right to erasure: You have the right to ask us to erase your personal information in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the Personal Data for one of the following reasons:

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- To exercise the right of freedom of expression and information.

- To comply with a legal obligation.

- To perform a task in the public interest or exercise official authority.

- For archiving purposes in the public interest, scientific research, historical research or statistical purposes.

- For the exercise or defence of legal claims.

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5. Right to restriction of processing: You may ask us to stop processing your Personal Data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:

- The accuracy of the Personal Data is contested.

- Processing of the Personal Data is unlawful.

- We no longer need the Personal Data for processing, but the Personal Data is required for part of a legal process.

- The right to object has been exercised and processing is restricted pending a decision on the status of the processing.

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6. Right to object to processing: You have the right to object to processing in certain circumstances. You can also object if the processing is for a task carried out in the public interest, the exercise of official authority vested in you, or your legitimate interests (or those of a third party).

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7. Right to data portability: This right only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated.

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Complaints

We hope that we can resolve any query or concern you raise about our use of your information. Please contact us at info@orbitalmaterials.com first and title your email “Complaint”. All complaints will be treated in a confidential manner, and we will try our best to deal with your concerns.

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You have the right to lodge a complaint with a supervisory authority in the EEA member state where you work or normally live, or where any alleged infringement of Data Protection Law occurred. 

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The details of European supervisory authorities can be found here: Our Members | European Data Protection Board (europa.eu)

The supervisory authority in the UK is the ICO, which may be contacted at https://ico.org.uk/concerns or by telephone on 0303 123 1113. 

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Further information for US/California

Data Subject Rights (California)

We do not sell your personal information.

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Under California’s “Shine the Light” law, website visitors who are located in California may request and obtain a notice once a year about the personal information we share with other businesses for their direct marketing purposes. Such a notice includes a list of the categories of personal information that was shared (if any), and the names and addresses of all third parties with which the personal information was shared (if any). The notice covers the preceding calendar year. To obtain such a notice, please contact us as previously described. 

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Verified California data subjects have the right to:

- Request and receive a copy of the personal information we have collected about them during the prior 12 months, we will endeavour to provide the information in a format that is readily usable, including by mailing you a paper copy or providing an electronic copy.

- Request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose

- Request that we not sell personal information about them, and

- Request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.

For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

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In order to make a request for disclosure, data subjects located in California may contact us at info@orbitalmaterials.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. 

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For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.

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We will not discriminate against you as a result of your exercise of any of these rights.

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In addition, under this law you are entitled to be advised how our site handles “do not track” browser signals. We do not use technology recognising do-not-track signals from your browser. ‍

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Questions or Concerns

If you have any questions, concerns, or complaints about this Privacy Notice, or our privacy practices in general, please email us at info@orbitalmaterials.com. ‍

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Change to this privacy notice 

This notice was last updated on 4 September 2024. We have the right to update from time to time at our own discretion and that the policy takes effect immediately.

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