Privacy Policy

Effective date: July 15, 2026 · Last updated: July 15, 2026

Orion Data Services ("Orion," "we," "us," or "our") provides a software development kit (the "Orion SDK") that application developers and partners ("Partners") may choose to embed in their apps. This Privacy Policy explains what information is involved when the Orion SDK operates, what we collect from visitors to this website, and the choices and rights available to end users and website visitors. It applies to orion-data.net and to the Orion SDK as distributed to Partners.

1. What the Orion SDK Does

The Orion SDK allows an end user of a Partner's app to voluntarily and explicitly opt in to share a small, limited amount of their device's idle, unused internet bandwidth. When an end user opts in, that bandwidth capacity is used to route network traffic on behalf of Orion's enterprise clients, who use it for purposes such as web intelligence, price comparison research, ad verification, and brand protection monitoring. Orion is compensated by its enterprise clients for this network capacity, and in turn compensates Partners based on the number of opted-in daily active users their app generates.

2. What the SDK Does Not Collect

The Orion SDK is designed to avoid collecting personal or identifying information. Specifically, the SDK does not:

• Collect the end user's name, email address, phone number, or government-issued identifiers;
• Access, log, or transmit the end user's personal browsing history, search history, or app usage within their own device;
• Read the content of the end user's personal communications, files, photos, or messages;
• Set or read cookies on the end user's behalf for advertising, tracking, or profiling purposes;
• Track the end user's precise real-time location for any purpose unrelated to basic network routing (such as country-level network diagnostics);
• Sell personal information, because no personal information of this kind is collected in the first place.

The traffic routed through the SDK belongs to Orion's enterprise clients and their own requests (for example, a request to check a publicly available product price or verify where an advertisement is being displayed) — it is not traffic generated by or reflective of the end user's own personal browsing activity.

3. Technical Data Involved in SDK Operation

To operate the network routing function and to pay Partners accurately, the SDK and its backend systems process limited technical data, which may include:

• A device or installation identifier used to measure daily active opted-in users;
• Coarse network information (such as connection type and approximate, non-precise geographic region at a country/region level) needed for network routing and quality purposes;
• Aggregate bandwidth contribution and uptime statistics used for Partner payment calculations;
• SDK version and basic diagnostic/error information to maintain service reliability.

This technical data is used to operate, secure, and pay for the network, and is not used to build advertising profiles of individual end users.

4. Consent and Opt-In Model

Participation in bandwidth sharing through the Orion SDK is strictly opt-in. Partners integrating the SDK are contractually required to present a clear consent flow to the end user before any bandwidth sharing begins, explaining that idle bandwidth will be shared and for what general purpose. Sharing does not begin unless and until the end user affirmatively agrees.

End users may withdraw consent and opt out of bandwidth sharing at any time, through the settings provided within the Partner's app or by uninstalling the app. Once an end user opts out, the SDK ceases routing network traffic for that installation.

5. Information We Collect from Website Visitors

When you visit orion-data.net or contact us, we may collect:

• Server logs: standard web server logs such as IP address, browser type, referring page, and timestamps, used for security, abuse prevention, and basic site analytics;
• Contact information you provide: if you email us or submit a contact form, we retain the email address and message content you send us in order to respond.

This section applies to our corporate website and does not describe the SDK's end-user data practices, which are addressed above.

6. How We Use Information

• To operate, maintain, and improve the Orion SDK and network routing service;
• To calculate and issue payments owed to Partners based on opted-in daily active users;
• To detect, investigate, and prevent fraud, abuse, or violations of our Terms of Service;
• To respond to inquiries sent to us through this website;
• To comply with applicable law and enforce our agreements.

7. Sharing of Information

We do not sell personal information. Aggregate, non-identifying bandwidth and usage statistics may be shared with enterprise clients and Partners for reporting and payment purposes. We may share information with service providers who assist us in operating our business (such as hosting or payment processing providers), under confidentiality obligations, or when required by law, legal process, or to protect the rights, safety, or property of Orion, our Partners, or others.

8. Data Retention

We retain technical and payment-related data for as long as necessary to operate the service, calculate Partner payments, meet accounting and legal obligations, and resolve disputes, after which it is deleted or anonymized in the ordinary course of business.

9. Your Rights (GDPR)

If you are located in the European Economic Area or United Kingdom, you may have the right to request access to, correction of, deletion of, or restriction on the processing of your information, to object to certain processing, and to receive a copy of your data in a portable format, subject to applicable legal exceptions. To exercise these rights, contact us at [email protected].

10. Your Rights (CCPA/CPRA)

If you are a California resident, you may have the right to know what personal information we hold about you, to request deletion of that information, to correct inaccurate information, and to not be discriminated against for exercising these rights. Orion does not sell personal information and does not share personal information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA. To submit a request, contact us at [email protected].

11. Children's Privacy

The Orion SDK and our services are not directed to children, and we do not knowingly collect personal information from children. Partners are required to ensure that their own applications and consent flows comply with applicable children's privacy laws, including obtaining any legally required parental consent, and to exclude the bandwidth sharing feature from experiences directed at children where such consent cannot lawfully be obtained.

12. Security

We use commercially reasonable technical and organizational measures designed to protect information from unauthorized access, disclosure, alteration, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. International Data Transfers

Depending on where you or our service providers are located, information may be transferred to, stored, and processed in countries other than your own. Where required, we use appropriate safeguards for such transfers in accordance with applicable law.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will post the revised policy on this page with an updated "Last updated" date. Material changes may be communicated to Partners through additional notice where appropriate.

15. Contact Us