A. General
The website located at https://www.orlattle.com/ (the "Site") is hosted by Orlattle, LLC (the "Company" or "our" or "we"). This Privacy Policy describes the types of information we collect on and through the Site, how we use such information and to whom and under what circumstances we may disclose it. This Privacy Policy applies to the Site and any other personal information obtained when you call, email, or otherwise communicate with the Company.
By accessing the Site on any computer, mobile phone, tablet, or other device (collectively, "Device") or otherwise interacting with the Company, you agree that you are subject to the terms of this Privacy Policy. If you do not agree with any part of the Policy, please do not use the Site. We may modify this Privacy Policy at any time, and will post the current version on the Site. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the information we collect.
I. Information that You Give Us
Here are the categories of personal information we collect, where we got it from, and with whom we have shared it:
| Category | Source | Purpose | Recipients |
|---|---|---|---|
| Contact information: name, email address, business or personal address, or phone number. | From visitors who contact us, sign up for emails, or otherwise interact with us. | To communicate with and respond to visitors about the services we provide, including verification of identity or to meet legal obligations. | We do not share this information with marketing, IT, or other third-party service providers. |
| Browsing information: IP address, MAC address, browser type, operating system, pages visited, clicks, state/country of access, date and time of visit, and referring web pages. | Our Site and your interactions with it, including through cookies and other tracking technologies. | To evaluate Site usage and improve performance; to protect the security and integrity of the Site and our business, such as preventing fraud and other criminal activity. | We do not sell this data. Our service providers for Site security, fraud protection, and analytics have access. |
| Browsing preferences: browser type, pages visited, clicks, preferred language, and browsing preferences. | Our Site and your interactions with it, including through cookies. | To store user preferences and information to personalize your experience. | We do not sell this data. Our service providers for Site security, fraud protection, and analytics have access. |
The Site and our services are directed to U.S. residents. Nonetheless, you may be viewing the Site from outside of the U.S. In some jurisdictions, such as the European Union and United Kingdom, individuals may have the right to opt-in or withdraw consent for certain uses of their personal information. If you reside in such jurisdictions, you may have additional rights which are detailed in "Access, Correction & Deletion" below.
II. Information We Collect Automatically
When you visit the Site, we may collect certain information from you, including your Internet Protocol (IP) address, MAC address, browser type, operating system, Device-identifying information, the specific web pages visited immediately preceding your connection, and the domain name from which you accessed the Site. In addition, we may collect information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Site and other clickstream data. We may also use non-personal or aggregated information for statistical analysis, research, and other internal purposes.
III. Cookie Policy
A cookie is a small data text file stored on the hard drive of your Device. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, a website's domain name, and some digits and numbers. Cookies cannot be used to run programs or deliver viruses to your Device. At no time will our cookies collect your personal information.
When you visit our Site, we may store certain types of persistent cookies on your Device in order to authorize access to our private content and to facilitate and customize your use of our Site.
Essential cookies allow us to offer you the best possible experience when accessing and navigating through our Site and using its features.
Functionality cookies let us operate the Site in accordance with the choices you make.
Analytical cookies enable us and third-party service providers to collect aggregated data for statistical purposes on how our visitors use our Site. These cookies do not contain or collect personal information and are merely used to help us improve your user experience.
If you choose, you can set your browser to reject cookies or you can manually delete individual or all cookies on your computer by following your browser's help file directions. However, doing so may impact your ability to access and use some pages and features on our Site.
IV. Email
We typically communicate through email. If you do not wish to receive communications from us, you can opt-out by following the instructions contained in the messages you receive. Even if you opt-out, we reserve the right to send you certain communications relating to the services we provide, including service announcements and administrative messages.
V. Disclosure of Information
Use of your personal information is governed by our Privacy Policy. Nonetheless, we may disclose information collected from and about you as follows: (1) to our related companies and service providers, to perform a business, professional or technical support function for us; (2) as necessary if we believe that there has been a violation of the Site Terms of Use or of our rights or the rights of any third party; (3) to respond to legal process (such as a search warrant, subpoena or court order) and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (4) in the event that our Company or substantially all of its assets are acquired, or there is a re-structuring, your personal information may be one of the transferred assets. We may also disclose your personal information with your express consent.
VI. Interest-Based Advertising
While we do not at the present use third-party companies to serve advertisements to your Device, we reserve the right to do so. If we do, these advertising companies may collect information about your visits to the Site and other websites and your interaction with our advertising and other communications. You always have the option to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in.
VII. Retention of Personal Information
We will keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this Policy. Once it is no longer necessary to retain your personal information, we will delete or anonymize it.
VIII. Security
We maintain commercially reasonable and appropriate measures designed to maintain information we collect in a secure manner. We have taken certain physical, electronic, and administrative steps to safeguard and secure your personal information, including limited employee access and two-factor authentication. Even though we follow commercially reasonable procedures to try to protect your information in our possession, no security system is perfect and we cannot guarantee, and you should not expect, that your information will be secure in all circumstances.
IX. Children
The Site is not directed to children (anyone under 13 years of age), nor do we knowingly solicit or collect any personal information from children without verifiable parental consent. If we discover that we have received any personal information from a child, we will investigate promptly and then delete such information from our system if warranted. If you are a parent or legal guardian and you become aware that your child has provided us with personal information, please contact us promptly using the contact information in the "Contact Us" section below.
X. Third Party Websites
The Site may contain links to third-party websites which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these third-party websites. Accordingly, we recommend that you review the privacy policies posted on any external website before disclosing any personal information.
XI. Changes to This Privacy Policy
We may change this Privacy Policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on our Site. If we change the policy in a material and retroactive manner, we will attempt to provide appropriate notice to you.
XII. Basis for Processing Personal Data
We may process personal data under the following conditions:
- Consent: You have given your consent for processing personal data for one or more specific purposes.
- Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations.
- Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which the Company is subject.
- Legitimate interests: Processing personal data is necessary for the purposes of legitimate business or commercial interests pursued by the Company.
| What we use your personal information for | Our reasons |
|---|---|
| To provide services to you. | Performance of our contract(s) with you or to take steps at your request before entering into a contract. |
| To prevent and detect fraud against you or our Company. | Legitimate interests — to minimize fraud that could be damaging for us and for you. |
| Gathering information required by audits, enquiries or investigations by regulatory bodies. | To comply with our legal and regulatory obligations. |
| Operational reasons, such as improving efficiency, training and quality control. | Legitimate interests — to be as efficient as we can. |
| Statistical analysis to help us manage our business. | Legitimate interests — to be as efficient as we can. |
| Preventing unauthorized access and modifications to systems. | Legitimate interests — to prevent and detect unauthorized and/or criminal activity. |
| Updating and enhancing customer records. | Performance of our contract(s) with you. |
| To comply with our legal and regulatory obligations. | Legal obligations. |
| Marketing our existing and new products and services to existing, former, and prospective customers. | Legitimate interests — to promote our business to existing and former customers. |
XIII. Where Your Personal Information is Held
Personal information may be held at our offices and those of our third-party service providers, representatives and agents as described above (see "Disclosure of Information"). Some of these third parties may be based outside of the U.S.A.
XIV. Transferring Your Personal Information between the U.S. and the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information between the U.S.A. and the European Economic Area (EEA). Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you submit any personal information to us, you expressly acknowledge and consent to this Privacy Policy, including our ability to transfer your personal information between jurisdictions. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
XV. Access, Correction, & Deletion
We respect your right to access and correct your personal information. You may exercise your rights, subject to applicable laws, to request that we delete or restrict access to your personal data. We may need to retain it for legally permitted purposes and this will be explained to you if necessary. Please contact us using the contact information in the "Contact Us" section below.
XVI. U.S. State Privacy Laws
a. California Privacy Rights (CCPA / CPRA / CalOPPA)
If you are a California resident, you have the right to know what personal information we have collected, used, disclosed and sold about you; the right to request deletion of your personal information; and the right not to be discriminated against for exercising these rights. To submit a request, please use the contact information in "Contact Us" below. You may only make a CCPA-related data access or portability request once within any 12-month period.
b. Connecticut Data Privacy Rights
Connecticut residents have the right to access, correct, delete, and obtain a copy of personal data we collect, and to opt out of the processing of personal data for targeted advertising or profiling.
c. Utah Consumer Privacy Rights
Utah residents have the right to access and delete personal data, to opt out of the collection and use of personal data for certain purposes, and to obtain a copy of their personal data.
d. Virginia Consumer Data Privacy Protection Act
Virginia residents may request that we confirm whether we are processing their personal data, correct inaccuracies, delete personal data, obtain copies of their data, or opt out of processing for targeted advertising or profiling.
e. Colorado Protect Personal Data Privacy Act
Colorado residents have the right to access and delete personal data and to opt out of the collection and use of personal data for certain purposes.
f. Delaware Personal Data Privacy Act
Delaware residents have the right to know what information is collected, to see it, correct inaccuracies, or request deletion.
g. Iowa Consumer Data Protection Act
Iowa residents have the right to know what information is being collected, to see and correct it, or request deletion.
h. Montana Consumer Data Privacy Act
Montana residents must provide clear consent before we process their personal information. Montana residents also have the right to access, correct, delete, and obtain a copy of personal data, and to opt out of targeted advertising.
i. Oregon Consumer Privacy Act
Oregon residents have the right to access and delete personal data, to opt out of the collection and use of personal data for certain purposes, and to obtain a copy.
j. Texas Data Privacy and Security Act
Texas residents may request confirmation of processing, correction of inaccuracies, deletion, copies of their data, or opt out of processing for targeted advertising or profiling.
XVII. Your Rights
We want you to be in control of how your personal information is used by us. Depending on your jurisdiction, you may have the right to be informed of, and request access to, the personal data we process about you; update and correct inaccuracies; have the information restricted or deleted; object or withdraw your consent to certain uses of data; and lodge a complaint with your local data protection authority. We will not discriminate against you for the exercise of these rights.
To exercise any of these rights, please send us a request using the contact information in "Contact Us" below, indicating the right you would like to exercise and your jurisdiction. We may ask for additional information to confirm your identity before disclosing information to you.
XVIII. How to Exercise Your Rights
Please contact us using the information detailed in the "Contact Us" section below. Please be reminded that you may only make a CCPA-related data access or data portability disclosure request once within any 12-month period.
When contacting us directly, please provide:
- Enough information to identify you (e.g., your full name, address, and customer or matter reference number);
- Proof of your identity and address (e.g., a copy of your driving license or passport); and
- A description of what right you want to exercise and the information to which your request relates.
XIX. Right to Lodge Complaints
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us first. To the extent you believe we have not addressed your concerns, you have the right to lodge a complaint with a supervisory authority in the country where you reside.
If you are a United States resident, you may contact the U.S. Federal Trade Commission. For more information, please see: ftc.gov.
XX. Contact Us
If you have questions or concerns about this Privacy Policy or how we collect and use your information, please contact us:
Orlattle, LLC
ATTN: Data Control Officer
80 M St SE #100
Washington, DC 20003
Ph.: (650) 430-7795