Privacy Policy

Orion Air Holdings, its subsidiaries and affiliates (collectively, "Orion Air Holdings", "we", "us" and "our") take protection of personal data very seriously. This policy explains our practices related to personal data privacy and security including:

• Types of personal information we collect;
• How we use the information;
• Who we share it with;
• Rights you may have about the use of your personal information;
• Security measures we implement to protect the security of your information; and

This policy applies to information you provide, or we collect from you, such as when you purchase goods or services from us, or when you get in touch with us with enquiries.

1. What is personal data?

Personal data is information that can be used to identity or which relates to a living individual, such as your name, address, telephone number, and email address. It could also include other types of information associated with you, such as your IP address.Orion Air Holdings does not collect sensitive personal data from persons who are not colleagues (such as health data).

If you do not agree with this privacy policy, you must not send us any information or use this website.

Under data protection laws, we shall ensure that your personal data is:

• used lawfully, fairly and in a transparent manner;
• collected only for the purposes which we have explained to you and not used in any other manner;
• only collected and used where it is relevant to the purposes we have told you about;
• accurate and kept up to date;
• kept only as long as is necessary; and
• kept securely.

2. Which data subjects do we process personal data on?

In general, we process personal data related to staff members of organizations we have dealings with, such as customers, vendors, end users, non-stock suppliers, regulators and tax authorities.

3. Collection of personal information

Orion Air Holdings collects and stores business contact information from or about you when:

• you make an enquiry or request information from us;
• we fulfill an order for your organization;
• your information is provided to us in the course of doing business or where we otherwise have dealings with your organization;
• we collect your information as part of our onboarding procedures before we trade with you;
• you have requested marketing communications be sent to you;
• we get in touch with you about products and services that may be of interest;
• we carry out a joint-marketing exercise with your organization (for example, Orion Air Holdings contacts your own customers on your behalf to promote a particular product or service);
• you create an account on one of our websites;
• you subscribe to our publications;
• you have attended an event which we have organized;
• you give us feedback;
• you enter one of our competitions;
• you complete a survey we send you; and
• we receive personal data about you from third parties, for example if we were provided with your details by one of our partners as part of a joint marketing campaign.

The personal information that Orion Air Holdings may collect, or that you may choose to provide, includes:

• Business contact information, including your job title, business address, e-mail address, phone number, department and name of organization;
• Identity data, including your name and title;
• Profile data, including your username and password, your preferences, feedback and survey responses;
• Marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences;
• Content you provide (such as photographs, comments or other information provided via webforms); and
• Information about your own customers, where such information is required by you to provide goods and services which we are supplying you with (for example, e-mail addresses of the staff members of end users required for the issuance of software licenses by Orion Air Holdings' vendors), or where you have provided information to us about types of products your customers may be interested in purchasing.

Information you provide to third party service providers retained by us. Where you provide information to us in this way, you will be subject to the relevant service provider's privacy policy.Orion Air Holdings is not responsible for how those site owners collect and handle your data.

Technical data: we and our third-party service providers may use a variety of technologies that automatically or passively collect certain information when you interact with us. These may include collecting information on the browser and operating system you are using, your browser plugin types and versions, the URLs of the pages you visited, your time zone and location, the time of day you visited our websites, your public IP address ("Usage Information"). Usage Information may also include the unique identifier ("Device Identifier"), automatically assigned to any computer, mobile phone, tablet or other device used to access our websites. Our servers identify your device by its Device Identifier. On occasions, we may supplement the information we collect about you with outside records from third parties, to provide you with the information, services or goods which you have requested and to enhance our ability to serve you.

We do not collect any sensitive 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).

Orion Air Holdings websites may also use cookies when you visit our websites.

4. How we use personal information collected

Orion Air Holdings may use personal information it collects from you or about you to / for:

• establish, develop and preserve our relationship with your organization and other organizations with whom we deal;
• create, establish and administer your organization's accounts;
• respond to your inquiries;
• provide products or services which your organization has purchased;
• marketing and promotional purposes, product development and content improvement. Where required by law, we will obtain your consent before we sent you communications related to marketing and promotions;
• authenticate the identity of persons contacting Orion Air Holdings remotely by telephone, electronic means or otherwise;
• allow us and our business partners who provide delivery fulfillment services to meet contractual requirements relating to the products and services provided to customers;
• ask for feedback on our services and products;
• conduct research and analysis and to monitor and improve the services we provide, including recording your visits to our websites. In these circumstances, we or our agents acting on our behalf, may contact you by email or telephone to ask you for your feedback and comments on our services;
• operate our business (including developing new products and services; conducting research; managing our communications; producing training materials and programmes; determining the effectiveness of and optimizing our advertising; analyzing our products, services, and performing accounting, auditing, billing, and reconciliation activities);
• solve technical problems; and
• meet our legal and regulatory requirements.

We will only use your personal data when the law allows us to, in situations such as:

• where we have your consent to send you marketing communications;
• where it is in our legitimate interests (or those of a third party) and where your interests and fundamental rights do not override those legitimate interests (this will often be situations where our sales and marketing colleagues get in touch to see if you are interested in purchasing products and services similar to those you have ordered recently); and
• where we need to comply with a legal obligation (such as provision of information to our regulators).

5. Disclosure of personal information

Except as provided in this policy, or as notified to you at the time we collect your information,Orion Air Holdings will not disclose your personal information to except as follows.

• With third parties who need to be in possession of the information to undertake a transaction in which your organization is taking part in; this includes service providers performing services on our behalf, including without limitation, those that assist us in providing products and services to your organization (where you are our customer); for example, we may need to provide email addresses of the staff members of your customers so that we can obtain software licenses from our vendors; our external suppliers may also have access to your data if they are maintaining systems which your personal information is stored on;
• With third parties required to enforce any agreement we have with you; and
• Where required to by law, including where we are obliged to disclose information under a court order or to a regulator with jurisdiction; this may also include where disclosure is required in connection with a merger, acquisition, or liquidation of Orion Air Holdings, or to protect the rights or property of Orion Air Holdings.

If data is disclosed to third party contractors during data processing they shall be subject to this policy, and, if applicable, to other additional data privacy provisions whichOrion Air Holdings deems necessary to protect your personal information.

6. Rights regarding the processing of personal data

Under data protection laws, you may under certain circumstances have the following 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 of your personal data;
• Request transfer of your personal data to another provider; and
• Right to withdraw consent.

You may contact us at any time using the details below to exercise your data subject rights. 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.

If you have provided us with personal data, we will keep your information in accordance with our retention policy. You may withdraw your consent to our processing at any time by contacting us by using the below details. Except where required by applicable laws, we will cease to use your personal data in the manner that was authorized by your consent.

If statutory retention periods require us to continue storing your personal information, we will ensure records which you do not want us to process cannot be accessed in our systems.

Any personal data which we have deleted due to an instruction to erase the data, or where we have chosen to delete the data as it is no longer needed, may be retained in backup systems until the next deletion cycle.

With your consent, we may share personal information with companies, organizations or individuals outside ofOrion Air Holdings when we have your consent to do so. We require opt-in consent for the sharing of data. For example, we may provide personal information to other trusted businesses to process it for us, based on your consent and in compliance with this Global Privacy Policy.

All marketing communications we send you have a link in the footer which allows you to manage your preferences.

Orion Air Holdings complies with anti-spam laws which apply in your jurisdiction.

7. Collection of personal information from children

Orion Air Holdings does not knowingly collect information from or about children and we do not knowingly market our products and services to children. No one under the age of 13 should submit any personal information toOrion Air Holdings through our website or any other means.

8. Cross-border transfers of personal data

In some cases, personal information that we manage may be transferred, processed and stored outside of your country of residence, including but not limited to the United States and the United Kingdom. Therefore, your personal information may be available to government authorities under lawful orders for disclosure and laws applicable in such foreign jurisdictions. Countries to which your personal information is transferred may not have the same data protection laws as the country of residence. When we transfer your information to other countries, we will protect it as set out in this global privacy policy. We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries outside the country of origin.

9. Security of data

The security of individuals' personal information is important to Orion Air Holdings and we are committed to protecting the information we collect. We have put in place appropriate technical and organizational measures to protect the information you provide, or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Such measures include but are not limited to two-factor authentication, mobile device management, encryption for storage and transfer of data and virus and malware scanning. We use encryption on our websites where a transfer of personal information takes place. Our services business is accredited to the ISO 27001 standard.

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.

10. Updates to our global privacy policy

Our privacy policy may change from time to time. We will post any privacy policy changes on this page.