Privacy Policy

Introduction

Welcome to the orangehat.dev privacy policy.

orangehat.dev is a reference to orangehat.dev Limited (a company incorporated in England and Wales under company registration number 16478872). References to the “Site” in this privacy policy are to orangehat.dev’s website. References to the “Services” in this privacy notice are to services performed by orangehat.dev from time to time.

orangehat.dev respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how orangehat.dev looks after your personal data when orangehat.dev receives it as a result of your use of the Site (regardless of where you visit it from) and/or as a result of providing the Services. This privacy policy tells you about your privacy rights and how the law protects you.

1. Important information and who orangehat.dev is

Purpose of this privacy policy

This privacy policy aims to give you information on how orangehat.dev collects and processes your personal data through your use of the Site and/or the Services, including any data you may provide when you use the Site and/or the Services.

The Site and the Services are not intended for use by children and orangehat.dev does not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy orangehat.dev may provide on specific occasions when orangehat.dev is collecting or processing personal data about you so that you are fully aware of how and why orangehat.dev is using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

orangehat.dev is the controller and responsible for your personal data, unless it is acting as a processor on behalf of a third party controller or processor.

orangehat.dev has appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or orangehat.dev’s privacy practices, please contact orangehat.dev’s data privacy manager in the following ways:

Email address: data@orangehat.dev.

Postal address: Capel Moreia, South Penrallt, Caernarfon, Gwynedd, LL55 1NS.

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the United Kingdom (“UK”) regulator for data protection issues (www.ico.org.uk). orangehat.dev would, however, appreciate the chance to deal with your concerns before you approach the ICO and so please contact orangehat.dev in the first instance.

Changes to the privacy policy and your duty to inform orangehat.dev of changes

orangehat.dev keeps its privacy policy under regular review. This version was last updated in June 2025.

It is important that the personal data orangehat.dev holds about you is accurate and current. Please keep orangehat.dev informed if your personal data changes during your relationship with orangehat.dev.

Third-party links

The Site may include links to third-party websites, plug-ins and applications (including those of third parties for the purposes of taking payments). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. orangehat.dev does not control these third- party websites, plug-ins or applications and is not responsible for their privacy statements. When you leave the Site, orangehat.dev encourages you to read the privacy policy of every website, plug-in and application you visit.

2. The data orangehat.dev collects about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

orangehat.dev may collect, use, store and transfer different kinds of personal data about you which orangehat.dev has grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes email address and telephone numbers.
• Digital Data includes video and audio recordings.
• AI Detection and Photographs includes photographs to identify users.
• Technical Data includes internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site.
• Profile Data includes your username and password, preferences, feedback and survey responses.
• Usage Data includes information about how you use the Site.
• Marketing and Communications Data includes your preferences in receiving marketing from orangehat.dev and orangehat.dev’s third parties and your communication preferences.

orangehat.dev may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, orangehat.dev may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Site. However, if orangehat.dev combines or connects Aggregated Data with your personal data so that it can directly or indirectly identify you, orangehat.dev treats the combined data as personal data which will be used in accordance with this privacy policy.

With the exception of Digital Data and AI Detection and Photographs, orangehat.dev does not collect any Special Categories of 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). Nor does orangehat.dev collect any information about criminal convictions and offences.

If you fail to provide personal data

Where orangehat.dev needs to collect personal data by law, or under the terms of a contract orangehat.dev has with you, and you fail to provide that data when requested, orangehat.dev may not be able to perform that contract and may not be able to provide you with access to the Site and/or the Services.

3. How is your personal data collected?

orangehat.dev may use different methods to collect data from and about you including through:

• Direct interactions. You may give orangehat.dev your Identity and Contact Data by filling in forms (including through the Site) or by corresponding with orangehat.dev by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply to use the Site;
  • create an account on the Site; or
  • give orangehat.dev feedback or contact orangehat.dev.
• Automated technologies or interactions. As you interact with the Site, orangehat.dev may automatically collect Technical Data about your equipment, browsing actions and patterns. orangehat.dev may use serving cookies and other similar technologies to do this. orangehat.dev may also receive Technical Data about you if you visit other websites, plug-ins or applications employing orangehat.dev’s cookies.
• Third parties. orangehat.dev may receive personal data about you from third parties. orangehat.dev may also record telephone conversations it has with you.

4. How orangehat.dev uses your personal data

orangehat.dev will only use your personal data when the law allows orangehat.dev to. Most commonly, orangehat.dev will use your personal data in the following circumstances:

• Where orangehat.dev needs to perform a contract orangehat.dev has with you.
• Where it is necessary for orangehat.dev’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where orangehat.dev needs to comply with a legal obligation.

Refer to the Glossary to find out more about the types of lawful basis that orangehat.dev will rely on to process your personal data.

Generally, orangehat.dev does not rely on consent as a legal basis for processing your personal data although orangehat.dev will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting orangehat.dev.

Purposes for which orangehat.dev will use your personal data

orangehat.dev uses the information collected for the following purposes:

• Improving the overall functionality and security of the Site.
• Otherwise providing you with access to the Site.
• Performing the Services.

orangehat.dev has set out below, in a table format, a description of all the ways orangehat.dev may use your personal data, and which of the legal bases orangehat.dev relies on to do so. orangehat.dev has also identified what orangehat.dev’s legitimate interests are where appropriate.

Note that orangehat.dev may process your personal data for more than one lawful ground depending on the specific purpose for which orangehat.dev is using your data. Please contact orangehat.dev if you need details about the specific legal ground orangehat.dev is relying on to process your personal data where more than one ground has been set out in the table below.

Cookies

orangehat.dev may use cookies to monitor how users use the Site. This helps orangehat.dev to understand how users use the Site so orangehat.dev can improve things like layout, function and design.

A cookie is a piece of information stored on your computer’s hard drive that records how you have used a website, plug-in or application. The next time you visit that website, application or plug-in, it can tailor your options based on the information it has stored about your last visit.

You can set your browser to refuse all or some browser cookies, or to alert you when websites, plug- ins or applications set or access cookies. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly.

Change of purpose

orangehat.dev will only use your personal data for the purposes for which orangehat.dev collected it, unless orangehat.dev reasonably considers that orangehat.dev needs to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact orangehat.dev.

If orangehat.dev needs to use your personal data for an unrelated purpose, orangehat.dev will notify you and orangehat.dev will explain the legal basis which allows orangehat.dev to do so.

Please note that orangehat.dev may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

orangehat.dev does not sell, trade or otherwise transfer your information to third parties except as set out in this privacy notice. Your personal data is only disclosed in accordance with this privacy notice, applicable laws or with your explicit consent.

6. International transfers

orangehat.dev may transfer your personal data to countries outside the UK. Although such countries may not be subject to the same data protection laws as organisations based in the UK, orangehat.dev will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law. By submitting your personal information to orangehat.dev, you agree to this transfer, storing or processing at a location outside the UK.

Whenever orangehat.dev transfers your personal data out of the UK, orangehat.dev will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• orangehat.dev will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where orangehat.dev uses certain service providers, orangehat.dev may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact orangehat.dev if you want further information on the specific mechanism used by orangehat.dev when transferring your personal data outside of the UK.

7. Data security

orangehat.dev has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, orangehat.dev limits access to your personal data to those employees, clients, agents, contractors and other third parties who have a business need to know. They will only process your personal data on orangehat.dev’s instructions and they are subject to a duty of confidentiality.

orangehat.dev has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where orangehat.dev is legally required to do so.

8. Data retention

How long will orangehat.dev use your personal data for? orangehat.dev will only retain your personal data for as long as reasonably necessary to fulfil the purposes orangehat.dev collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. orangehat.dev may retain your personal data for a longer period in the event of a complaint or if orangehat.dev reasonably believes there is a prospect of litigation in respect to orangehat.dev’s relationship with you.

To determine the appropriate retention period for personal data, orangehat.dev considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which orangehat.dev processes your personal data and whether orangehat.dev can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law orangehat.dev may have to keep basic information about users of the Site (including Contact and Identity Data) for 6 years after the cessation of a relevant client relationship for tax and other purposes.

In some circumstances you can ask orangehat.dev to delete your data: see your legal rights below for further information.

In some circumstances orangehat.dev may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case orangehat.dev may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to exercise any of these rights, please contact orangehat.dev.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, orangehat.dev may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, orangehat.dev could refuse to comply with your request in these circumstances.

What orangehat.dev may need from you

orangehat.dev may need to request specific information from you to help orangehat.dev 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. orangehat.dev may also contact you to ask you for further information in relation to your request to speed up orangehat.dev’s response.

Time limit to respond

orangehat.dev will try to respond to all legitimate requests within 1 month. Occasionally it could take orangehat.dev longer than a month if your request is particularly complex or you have made a number of requests. In this case, orangehat.dev will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of orangehat.dev’s business in conducting and managing orangehat.dev’s business to enable orangehat.dev to give you the best service/product and the best and most secure experience. orangehat.dev makes sure orangehat.dev considers and balances any potential impact on you (both positive and negative) and your rights before orangehat.dev’s processes your personal data for orangehat.dev’s legitimate interests. orangehat.dev does not use your personal data for activities where orangehat.dev’s interests are overridden by the impact on you (unless orangehat.dev has your consent or is otherwise required or permitted to by law). You can obtain further information about how orangehat.dev assesses orangehat.dev’s legitimate interests against any potential impact on you in respect of specific activities by contacting orangehat.dev.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that orangehat.dev is subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the group of companies to which orangehat.dev belongs acting as joint controllers or processors.

External Third Parties

• Service providers acting as processors based inside and outside of the UK.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data orangehat.dev holds about you and to check that orangehat.dev is lawfully processing it.

Request correction of the personal data that orangehat.dev holds about you. This enables you to have any incomplete or inaccurate data orangehat.dev holds about you corrected, though orangehat.dev may need to verify the accuracy of the new data you provide to orangehat.dev.

Request erasure of your personal data. This enables you to ask orangehat.dev to delete or remove personal data where there is no good reason for orangehat.dev continuing to process it. You also have the right to ask orangehat.dev to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where orangehat.dev may have processed your information unlawfully or where orangehat.dev is required to erase your personal data to comply with local law. Note, however, that orangehat.dev may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where orangehat.dev is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where orangehat.dev is processing your personal data for direct marketing purposes. In some cases, orangehat.dev may demonstrate that orangehat.dev has compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask orangehat.dev to suspend the processing of your personal data in the following scenarios:

• If you want orangehat.dev to establish the data's accuracy.
• Where orangehat.dev’s use of the data is unlawful but you do not want orangehat.dev to erase it.
• Where you need orangehat.dev to hold the data even if orangehat.dev no longer requires it as you need it to establish, exercise or defend legal claims.
• You have objected to orangehat.dev’s use of your data but orangehat.dev needs to verify whether orangehat.dev has overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. orangehat.dev will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for orangehat.dev to use or where orangehat.dev used the information to perform a contract with you.

Withdraw consent at any time where orangehat.dev is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, orangehat.dev may not be able to provide continued access to the Site and/or the Services to you. orangehat.dev will advise you if this is the case at the time you withdraw your consent.