Last updated September 26, 2024

This Privacy Policy (“Policy”) describes how Patriot Way Services, LLC d/b/a Orion Expert Network (“OEN,” “we,” “our” or “us”) obtains, utilizes, shares and safeguards information collected from you via the website, https://www.orionexpertnetwork.com (the “Website”). For purposes of this Policy, “Personal Information” means any information that identifies or could be used to identify an individual living person. Your use of the Website constitutes your acknowledgment and/or consent to the practices described in this Policy, which is incorporated into our Terms of Use (https://www.orionexpertnetwork.com/terms-of-use/)

If you are a California resident, please also read Appendix A “Privacy Information for California Residents” for supplemental California-specific privacy information.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it, including any rights you may have. By visiting or using our Website, or by uploading or submitting any information through the Website to OEN, you consent to the collection, use and transfer of your information pursuant to the terms of this Privacy Policy. If you do not agree with our Policy, your choice is not to use our Website. This Policy may change from time to time. Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

INFORMATION COLLECTION

Information We Collect About You. In the course of using our Website, OEN may ask users for their name, contact information, employment information, biographical information, information regarding your areas of expertise, statement of qualifications, fee schedule, references, and any feedback you provide, or any other information you provide through the Website.

Information Collected Automatically. We may collect additional information from you automatically. This information is referred to herein as “Usage Information.” Such Usage Information may include information that we automatically collect when you use the Website, such as your IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, similar information concerning your use of the Website, and information about your online activities over time and across third-party websites or other online services.

COOKIES AND OTHER DATA TRACKING TECHNOLOGY

We may use cookies (small text files that are stored on browsers or devices by websites, apps, online media, and advertisements) and other automated data collection technologies (e.g., web beacons, pixels), and electronically gather information about your use of the Website. We use cookies and similar technologies for purposes such as remembering user preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, and analyzing traffic to our Website. You may be able to decline our cookies through your browser settings; however, this may interfere with your ability to use the Website or certain features of the Website. We may also use Google Analytics or a similar service that uses cookies to help us analyze how users use the Website.

Information We Receive from Other Sources. From time to time, we may also receive information about you from our third-party service providers, affiliates, customers, and partners, including our marketing, conference, and advertising partners and social media networks. We may also collect information about you from publicly available sources, including social media or information transmitted by other users of the Website or third parties.

INFORMATION USAGE

The personal information that you provide to OEN may be stored, processed, and used by OEN and its affiliates for the following purposes:

  1. To provide our products and services and present our Website and its content to you;
  2. To provide you with information that you request from us, including updates, notifications, and details of any offers or promotions;
  3. To provide you with notices about your account;
  4. To comply with our legal obligations or requests from law enforcement and government agencies;
  5. To analyze information for trends and statistics;
  6. To enforce or protect the terms of our services, rights, property, safety, or that of our users or third parties;
  7. As part of due diligence for, or the consummation or, a transaction involving the merger, sale, divestiture, or other transaction involving the equity or assets or OEN;
  8. To match you with consulting opportunities if applicable;
  9. To match an expert with your consulting requirements if applicable;
  10. To provide you with information about our products and services or to send you surveys, promotional materials, newsletters, or special offers; and
  11. For any other purpose with your consent.

DISCLOSURE OF YOUR INFORMATION

OEN may disclose your information with third parties as follows:

  1. With our affiliates;
  2. With experts or clients, as the case may be, in an effort to make an engagement possible;
  3. To our partners and service providers that assist us in providing services offered through the Website, including, but not limited to, services related to processing payments, background checks, providing marketing assistance, information technology support, and customer service;
  4. To the extent permitted by law, we may also disclose personal information and the Usage Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of OEN or others;
  5. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the personal information and Usage Information may be disclosed or a part of the transferred assets; or
  6. In accordance with the consent you’ve provided.

In addition, in an ongoing effort to better understand users of our Website, we might analyze the Usage Information in aggregate form in order to operate, maintain, manage, and improve the Website. This aggregate information does not identify you personally. We may share this aggregate data for any legal purpose. For example, we may disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.

YOUR CHOICES

You can opt out of Google Analytics by:

  • Changing your settings at Google’s Ad Settings at: http://www.google.com/settings/ads
  • Installing an opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/
  • Adjusting the settings on your web browser: See http://www.google.com/intl/en/policies/technologies/managing

Opt-Out. You may choose not to receive marketing materials regarding from OEN by simply notifying OEN at info@orionexpertnetwork.com. Upon receipt and processing of an “opt-out” request, OEN will, within a commercially reasonable amount of time, remove your information from any future unsolicited marketing communications. Your request regarding marketing materials will not apply to information that you request to receive or that is transactional.

LINKS TO OTHER WEBSITES

The Website may contain links to other websites or may otherwise provide access to other sites that are not operated or controlled by OEN. OEN is not responsible for the information collected on any such sites, the privacy policies or terms of use on those sites. We encourage you to review any privacy policies or terms of use posted on any of these sites. You agree to look solely to the third party site owners in the event of any claims related to use of your information on those sites and waive any such claims against OEN.

INFORMATION SECURITY

We use commercially reasonable physical and technological security measures designed to protect your information both online and offline from unauthorized access, processing, accidental loss, and damage. However, we cannot guarantee the security of data sent over the internet.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

POLICY UPDATES

OEN may update this Policy from time to time. We will notify you of any material changes by posting a notice on the Website. Any changes to our Privacy Policy will become effective upon notice. Your continued use of the Website will indicate your agreement to such changes.

CONTACT US

We welcome all requests, suggestions and questions concerning our use of your information. All such communication should be directed to: info@orionexpertnetwork.com.

APPENDIX A

Privacy Information for California Residents

This Appendix applies solely to individuals who reside in the State of California (“consumers” or “you”). This Appendix complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Appendix. This Appendix applies to consumer information collected by OEN both through the Website and offline. This Appendix does not apply to personal information outside the scope of the CCPA.

  1. Orion Expert Network as a Service Provider

When OEN acts as a service provider for its business customers, it collects some personal information on behalf of its customers subject to its contractual obligations. When OEN acts as a service provider for its business customers, it follows the instructions of its customer on how to process personal information on its customer’s behalf. The provisions of this Appendix do not apply to the personal information that OEN processes on behalf of our business customers.

  1. Disclosures

In addition to any of the practices described above, the below chart lists the categories of personal information that OEN may collect or has collected in the past 12 months and how it discloses such information. In addition, we may also disclose your personal information to a third party, upon your request or at your direction. To the extent you use OEN’s services and agree to have your personal information shared with others to use the products or services, we shall share your personal information accordingly. For example, if you are an expert, we may match you with our client customers through our services.

CATEGORIES OF PERSONAL INFORMATION:

Identifiers. This may include a real name, alias, address, email address, phone number, online identifier, IP address, account username and password, or other similar identifiers.

Internet and network information. This may include information on your interaction with a website, application, or advertisement, such as browsing history and how you use your account.

Device information. This may include the operating system of your device, device identifier, the type of device you are using, or your geolocation information.

Other information you submit to OEN or its service providers. This may include requests or communications you submit to us, emails, ratings, or any other communications.

Inferences about you. This may include information about your preferences, characteristics, predispositions, behavior, or other trends that help us identify which products or services you may be interested in.

Professional or employment related information. This may include work history, technical skills, educational background, professional certifications, licensing and registrations, and language capabilities.

  1. Sources of Information

OEN collects personal information from the following sources: you, your agents, through our third-party service providers, your references, your employer, and public sources, such as social media networks.

  1. Sensitive Personal Information

Sensitive Personal Information consists of: (1) government identifiers, such as Social Security Numbers and drivers’ license numbers; (2) account log-in information (e.g., financial account or credit card numbers in combination with any required access codes or passwords); (3) precise geolocation information; (4) racial or ethnic origin, religious or philosophical beliefs, or union membership; (5) content of postal mail, email, and text messages, unless the business is the intended recipient of the subject communications; (6) genetic data; and (7) biometric information that uniquely identifies a consumer or information concerning a consumer’s health, sex life, or sexual orientation. To the extent we collect information that is considered Sensitive Personal Information under CCPA, it is listed in the chart below.

HOW WE DISCLOSE YOUR INFORMATION

We may disclose your Personal Information with the following recipients.

  • With Our Vendors and Service Providers. We may share your Personal Information with third parties who perform services on our behalf. For example, this may include cloud storage providers, advertising and analytics platforms and payment processors. It may also include companies that send emails on our behalf or help us run our Website.
  • With Our Business Partners and Clients. For example, this may include clients who are interested in retaining your services.
  • With Any Successors to All or Part of Our Business or One of Our Brands. For example, if we merge with, acquire or are acquired, or sell a brand or part of our business to another business entity. This may include an asset sale, corporate reorganization or other change of control, or in the unlikely event of a bankruptcy. This may also include selling databases that contain your Personal Information as a standalone asset.
  • To Fulfill Our Legal Obligations or Defend Our Rights. We may share your Personal Information in response to a court order or subpoena, or at the demand of a government agency or other investigatory body. We may also share your Personal Information with consultants, lawyers, accountants, or other professional service providers.

MINORS

The Website is intended for use by individuals over 18. We do not knowingly collect Personal Information from individuals under the age of 18. If you are under the age of 18, please do not use or access the Website. If you are a parent or guardian and discover that your child under the age of 13 has provided us with Personal Information without your consent, please contact us using the contact information below to request that we delete the information from our systems. You can also write to us at the address listed at the end of this Policy.

OUR COLLECTION, USE, AND RETENTION OF PERSONAL INFORMATION

  1. Sales and Sharing of Personal Information. We do not and have not sold any categories of Personal Information to third parties or shared any categories of Personal Information for the purpose of cross-context behavioral advertising purposes.
  2. Collection, Sources and Use of Personal Information. During the 12-month period prior to the “last updated” date of this CA Privacy Notice We have collected and used the following categories of Personal Information for the following purposes:
  • To provide our products and services and present our Website and its content to you;
  • To provide you with information that you request from us, including updates, notifications, and details of any offers or promotions;
  • To provide you with text communications which may include marketing materials with your consent;
  • To provide you with notices about your account;
  • To comply with our legal obligations or requests from law enforcement and government agencies;
  • To analyze information for trends and statistics;
  • To enforce or protect the terms of our services, rights, property, safety, or that of our users or third parties;
  • As part of due diligence for, or the consummation or, a transaction involving the merger, sale, divestiture, or other transactions involving the equity or assets or OEN;
  • To match you with consulting opportunities if applicable;
  • To match an expert with your consulting requirements if applicable;
  • To provide you with information about our products and services or to send you surveys, promotional materials, newsletters, or special offers; and
  • For any other purpose with your consent.

WHAT CATEGORIES OF PERSONAL INFORMATION DO WE COLLECT

Category Examples Collected
Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name YES
Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, and employment history YES
Protected classification characteristics under California or federal law Gender and date of birth YES
Commercial information Transaction information, purchase history, financial details, and payment information NO
Biometric information Fingerprints, voiceprints, or facial recognition NO
Internet or other similar network activity. Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements YES
Geolocation data Device location YES
Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video, or call recordings created in connection with our business activities NO
Professional or employment-related information Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us YES
Education information Student records and directory information NO
Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics YES

 

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information. OEN has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

Right to Request Deletion of The Data—Request to Delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to Be Informed—Request to Know

Depending on the circumstances, you have a right to know:

  • Whether we collect and use your personal information
  • The categories of personal information that we collect
  • The purposes for which the collected personal information is used
  • Whether we sell your personal information to third parties
  • The categories of personal information that we sold or disclosed for a business purpose
  • The categories of third parties to whom the personal information was sold or disclosed for a business purpose
  • The business or commercial purpose for collecting or selling personal information

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

VERIFICATION PROCESS

Upon receiving your request, we will need to verify your identity to determine if you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

OTHER PRIVACY RIGHTS

  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict.

You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at info@orionexpertnetwork.com, by calling us at: 617-528-0055, by visiting https://www.orionexpertnetwork.com/contact-us/, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our team by email at info@orionexpertnetwork.com, by phone at 617-528-0055, or by post to:

Orion Expert Network
Scott Rousseau
444 Broadway / Martignetti Center
Suite B #1001
Saugus, MA 01906
United States

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact our team, by email at info@orionexpertnetwork.com, by phone at 617-528-0055, or by post to:

Orion Expert Network
Scott Rousseau
444 Broadway / Martignetti Center
Suite B #1001
Saugus, MA 01906

United States