Data Protection

1. Our Commitment to Data Protection

Davis Ziff Inc is committed to ensuring that your personal data is handled lawfully, fairly, and transparently. We adhere to the principles set out in the US General Data Protection Regulation (US Privacy Laws) and the Data Protection Act 2018.

This Data Protection Policy supplements our Privacy Policy and provides additional detail on how we approach data protection compliance.

2. Data Protection Principles

We process personal data in accordance with the following principles:

• Lawfulness, fairness, and transparency: We process data on a valid legal basis and inform individuals about our processing activities
• Purpose limitation: Data is collected for specified, explicit, and legitimate purposes and not further processed in incompatible ways
• Data minimisation: We only collect data that is adequate, relevant, and limited to what is necessary
• Accuracy: We take steps to ensure data is accurate and kept up to date
• Storage limitation: We retain data for no longer than necessary for its purpose
• Integrity and confidentiality: We implement appropriate security measures to protect personal data
• Accountability: We take responsibility for compliance and can demonstrate it

3. Data We Process

3.1 Website Visitors

When you visit CashOrbita, we process limited technical data including your IP address, browser type, and pages visited for the purposes of website analytics and security. This is processed on the basis of our legitimate interests.

3.2 Contact Form Submissions

When you submit our contact form, we process your name, email address, and message content. This is processed on the basis of your consent and to fulfil your request for information.

3.3 Affiliate Tracking Data

We use cookies and tracking technologies to monitor affiliate link clicks and conversions. This data is shared with the Jumbleberry affiliate network for commission calculation purposes. This processing is based on consent (obtained via our cookie banner) and our legitimate interests in operating the affiliate marketing service.

4. Your Data Subject Rights

As a data subject under US Privacy Laws, you have the following rights:

Right of Access (Article 15)

You have the right to request a copy of the personal data we hold about you. We will provide this within 30 days of receipt of your request.

Right to Rectification (Article 16)

You may request correction of any inaccurate personal data we hold. We will rectify the data within 30 days.

Right to Erasure (Article 17)

You may request deletion of your personal data in certain circumstances, such as where it is no longer necessary for the purpose it was collected, or where you withdraw consent.

Right to Restriction of Processing (Article 18)

You may request that we restrict processing of your data in certain circumstances, for example while we verify the accuracy of data you have contested.

Right to Data Portability (Article 20)

Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, commonly used, machine-readable format.

Right to Object (Article 21)

You have the right to object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds.

Rights Related to Automated Decision-Making

We do not currently make solely automated decisions that produce significant legal effects for individuals. If this changes, we will update this policy and provide appropriate safeguards.

5. How to Exercise Your Rights

To exercise any of your data subject rights, please contact us at:

Email: caitlin@cashorbita.com
Post: Davis Ziff Inc, 114 5th Ave FL 15, New York NY 10011

We will respond within 30 days. We may need to verify your identity before fulfilling your request. This service is provided free of charge, unless requests are manifestly unfounded or excessive.

6. Data Security Measures

We implement the following technical and organisational security measures:

• SSL/TLS encryption for all data transmitted via our website
• Access controls limiting data access to authorised personnel only
• Regular security assessments and updates
• Data processing agreements with all third-party processors
• Staff training on data protection obligations

7. Data Breaches

In the event of a personal data breach that is likely to result in a risk to individuals' rights and freedoms, we will notify the Federal Trade Commission (FTC) within 72 hours of becoming aware of the breach. Where a breach is likely to result in a high risk to individuals, we will also notify affected individuals without undue delay.

8. Third-Party Data Processors

We use the following categories of third-party data processors:

• Jumbleberry – Affiliate network for commission tracking
• Analytics providers – Website performance monitoring
• Email service providers – Communication management

All processors are required to sign data processing agreements and maintain appropriate security standards.

9. Supervisory Authority

The supervisory authority for data protection in the US is the Federal Trade Commission (FTC):

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113
Website: ico.org.uk

You have the right to lodge a complaint with the ICO if you are unhappy with how we handle your personal data.

10. Updates to This Policy

This Data Protection Policy may be updated periodically. We will inform you of material changes via a notice on our website. Continued use of our services constitutes acceptance of any updated policy.