Last Updated: April 2026
WELCOME TO ORBIT. YOUR PRIVACY IS IMPORTANT TO US. THIS PRIVACY NOTICE SETS OUT HOW WE PROCESS PERSONAL DATA ABOUT YOU WHEN YOU USE ANY PART OF THE ORBIT MOBILE APPLICATION (THE “APP”, OR “ORBIT”) AND ALL SERVICES, CONTENT AND MEDIA PROVIDED TO YOU FROM TIME TO TIME ON THE APP (THE “SERVICES”). THIS PRIVACY NOTICE SHOULD BE READ ALONGSIDE OUR TERMS OF SERVICE.
The App is brought to you by Marvell St Assetco Pty Ltd (t/a Orbit) with registered office is at 268 Canterbury Road, Surrey Hills Victoria Australia with ACN 691 913 158 (“we”, “us”, “our”) and sets out how we use and protect your personal data.
This Privacy Notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. You must be at least 18 years old to access and use the App and Services; the App is not intended for children and we do not knowingly collect data relating to children.
We are a data controller of the personal data we process and are therefore responsible for ensuring our systems, processes, suppliers and staff comply with data protection laws in relation to the information we handle. If you do not agree with this Privacy Notice, you should not submit information to us or the App.
You can find out more about our responsibilities and about how and why we collect and use your personal data by reading this Privacy Notice. However, if anything is unclear or if you have any questions about this Privacy Notice, please contact us at admin@orbitapp.co.uk or through the App’s settings.
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes information that may be required to create your account such as first name, last name, any previous names, username or similar identifier, date of birth and gender.
Contact Data will include at least your telephone number and may include your home address and email address.
Financial Data for the purposes of paying for your subscription directly with Orbit, which may include payment card details.
Device Data which may include the type of mobile device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.
Interaction Data personal data included in your inputs, chats with the App’s artificial intelligence (“AI”), outputs, file uploads (including photographs, audio or video), feedback or other communications and information you provide to the App. This data falling within this category is dependent on the extent of your interactions with the AI and may therefore include information that would fall within other categories.
Facial Data means any data derived from the analysis of photographs or images of your face that you upload to the App, including but not limited to facial features, facial geometry, facial expressions and visual likeness characteristics. Facial data is extracted by our AI systems solely for the purpose of learning your visual appearance in order to improve the accuracy of our matchmaking services. Facial data does not include the photographs themselves (which are classified as Profile Data or Interaction Data, as applicable) but refers specifically to the computational data derived from those photographs.
Profile Data when creating your account, you may (at your discretion) share your sexual orientation, ethnicity, religious beliefs and political opinions. You can choose whether or not to make these details visible to other users and change your settings at any time. You will also have the choice to share photos, images, (or, in the future, which may require you to allow us access to your camera, photo album). Profile Data will also include your username and password, your interests, preferences, feedback and survey responses (if applicable).
Session Data when you log on to and interact with the App, we automatically collect information about your use of the App including details of your visits such as pages viewed and the resources that you access. This information will include traffic data, location data, IP address, browser, operating system, length of visit, clickstream data and other communication data.
Location Data. We also use GPS technology, Bluetooth, crowd-sourced Wi-Fi hotspots and other sensors (such as accelerometers) to determine your current location. Our services require your location data for the feature to work. If you wish to use the App, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings, however you will not be able to access the App.
Technical Data. Each time you visit the App we will automatically collect personal data including device, content and usage data. We collect this data using cookies and other similar technologies.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific feature in order to analyse general trends in how users are interacting with the App to help improve the App and our service offering.
Given the sensitive nature of Facial Data, we provide the following additional information about how we collect, use, store and delete it.
Collection
When you upload photographs or images containing your face to the App (whether as part of your profile or through interactions with the AI), our AI systems will analyse those images to extract Facial Data. This processing occurs automatically upon upload. You will be asked to provide your explicit consent to the collection and processing of your Facial Data before any such processing takes place. You may withdraw your consent at any time (see "Your Choices Regarding Facial Data" below), although this may affect the quality of the matchmaking Services available to you.
Use: We use your Facial Data solely for the following purpose:
Matchmaking improvement: to enable the App's AI to learn what you look like so that it can improve the accuracy and relevance of the users presented in your Orbit(s). This includes enabling the AI to understand your visual appearance as one factor (among others, such as your stated preferences, interests and interaction history) in identifying potentially compatible users.
We do not use your Facial Data for: (a) facial recognition or identification of you in contexts outside the App; (b) advertising, profiling for advertising purposes or sale to third parties; (c) generating new or altered images of you; or (d) any purpose other than as expressly stated above.
Disclosure and Sharing
Currently, Facial Data is processed exclusively on our own servers using locally hosted machine learning models. Facial Data is not transmitted to, accessed by, or processed by any third-party artificial intelligence or large language model provider.
Your Facial Data may be shared with the following categories of third-party processors, solely for the purpose of providing the matchmaking Services described above:
LLM Provider: Currently Facial Data is processed exclusively on Orbit's own servers using locally hosted machine learning models, and is not transmitted to any third-party AI or large language model ("LLM") provider. However, in the future, we may transmit Facial Data to our third-party LLM provider via a secure API connection for the purpose of AI-powered analysis. In these circumstances, your Facial Data will not be used by the LLM provider for the training of its own models or for any purpose other than performing services on our behalf.
Cloud Infrastructure Provider: Facial Data is stored on servers operated by our cloud infrastructure provider pursuant to a data processing agreement that includes appropriate technical and organisational security measures.
We do not sell, rent, license or otherwise make your Facial Data available to any third party for that third party's own purposes. Your Facial Data is never explicitly disclosed to other users of the App.
Storage
Facial Data is stored on encrypted servers maintained by our cloud infrastructure provider. We implement appropriate technical and organisational measures to protect your Facial Data against unauthorised access, alteration, disclosure or destruction, including encryption at rest and in transit, access controls and regular security audits.
Retention and Deletion
Your Facial Data is retained only for so long as is necessary for the purpose described above. Specifically:
When you replace or delete a photograph from which Facial Data has been derived, the Facial Data associated with that photograph will be permanently deleted from our systems within 30 days of the replacement or deletion.
When you delete your account, all Facial Data associated with your account will be permanently deleted from our systems within 30 days of account deletion.
If you withdraw your consent to Facial Data processing, we will cease processing your Facial Data immediately. Your Facial Data will remain stored (but unprocessed) in our systems until your account is deleted, at which point it will be permanently deleted within 30 days.
If your account is treated as expired pursuant to this Privacy Notice, all Facial Data associated with your account will be permanently deleted at the same time as your other personal data.
For the avoidance of doubt, where Facial Data is deleted, it is permanently and irreversibly removed from our active systems, backups and archives. Facial Data is not retained in anonymised or aggregated form following deletion.
Your Choices Regarding Facial Data
You have the following rights in relation to your Facial Data, in addition to the general rights set out in section 10:
· Consent: You may withdraw your consent to the processing of Facial Data at any time by contacting us through the App’s settings. Upon withdrawal of consent, we will cease processing your Facial Data. However, please note that withdrawal of consent does not automatically delete your Facial Data from our systems. Your Facial Data will remain stored (but unprocessed) until you delete your account, at which point it will be permanently deleted within 30 days. If you wish to have your Facial Data fully deleted, you must delete your account (see below). Withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal.
· Access and Portability: You may request a copy of the Facial Data we hold about you by contacting us through the App’s settings.
· Deletion: Due to the architectural integration of Facial Data with your account, deletion of Facial Data requires deletion of your account. When you delete your account, all Facial Data is permanently deleted within 30 days. If you wish to stop Facial Data processing without deleting your account, you may withdraw your consent as described above, which will cease all processing of your Facial Data but will not remove it from our systems until your account is deleted.
We will collect and process the following data about you:
Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App and for the Services, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our Services, search for the App or Service, share data via an App's functions, and when you report a problem with the App or our Services. If you contact us, we will keep a record of that correspondence.
Information we have received from others. Other users may provide us with your personal data as they use the App if, for example, they contact us about your conduct.
Automatically collected information. Information such as Device Data, Usage Data and Location Data will be collected automatically while the App is actively running.
Information you provide us by interacting with the App’s AI. This includes preferences, interests, hobbies and information you provide when interacting with the App’s AI chatbot.
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Explicit consent: We process your Facial Data and any special category data (such as data concerning your sexual orientation, religious beliefs or sex life) only where you have provided your explicit, informed and freely given consent to such processing for the specific purposes described in this Privacy Notice.
We have set out below a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose: To install the App and register you as a new App user (including any verification of your identity and location).
Lawful Basis for Processing: Performance of a contract with you.
· Identity
· Contact
· Device
· Location
Purpose: To facilitate the payment for the Services (not applicable to users making payments via a third party app store).
Lawful Basis for Processing: Performance of a contract with you.
· Identity
· Contact
· Financial
Purpose: To deliver our Services to you (including to facilitate matching opportunities with other users of the App).
Lawful Basis for Processing: Performance of a contract with you.
· Identity
· Contact
· Device
· Interaction
· Location
Purpose: To enable the App's AI to learn your visual appearance in order to improve the accuracy of our matchmaking Services.
Lawful Basis for Processing: Explicit consent.
· Facial Data
Purpose: To manage our relationship with you including notifying you of changes to the App or any Services.
Lawful Basis for Processing: Necessary to comply with our legal obligations (to inform you of any changes to our terms and conditions).
· Identity
· Contact
· Profile
· Marketing and Communications
Purpose: To operate, develop and improve the App’s integrated AI functionality.
Lawful Basis for Processing: Necessary for our legitimate interests (to operate and improve the App and our Services).
· Identity
· Contact
· Profile
· Interaction
· Technical
Purpose: To administer and protect our business and this App including troubleshooting, data analysis and system testing and to monitor trends so we can make improvements to the App (such as the enhancement of the App through the use of new technology).
Lawful Basis for Processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security).
· Identity
· Contact
· Device
· Interaction
· Session
Purpose: To monitor the App and any investigation into any infringement of (or alleged infringement of) the Orbit Terms of Service.
Lawful Basis for Processing: Necessary for our legitimate interests (to protect our assets and other users of the App or Services).
· Identity
· Contact
· Device
· Profile
· Interaction
· Session
Purpose: To ensure legal compliance.
Lawful Basis for Processing: Necessary to comply with our legal obligations (to comply with applicable laws).
· Identity
· Contact
· Device
· Content
· Interaction
· Profile
· Session
· Location
We do not collect any cookies.
As well as sharing your personal data with other users of the App, we may share your personal data where necessary with the parties set out below for the purposes set out in the table above for which we will use your personal data above.
Other users of the App – your personal data will be shared voluntarily on the App with other users (i.e., the information on your profile).
Service providers – external third parties that we may engage to perform functions and/or provide services to us. Please note, we will use reasonable endeavours to enter into agreements with obligations of confidentiality with such service providers.
LLM Provider — we may share certain personal data (including Interaction Data and, not currently but at a point in the future, Facial Data) with our third-party LLM provider via a secure API for the purpose of powering the App's AI chatbot and matchmaking functionality. Our LLM provider acts as a data processor on our behalf.
Affiliates – other members of the Orbit group for legitimate business purposes.
Business Transfers – third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
Law enforcement / where required by applicable law – we may be required to share your personal data with law enforcement or another third party as required by applicable law.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In respect of Facial Data specifically: (a) Facial Data is never explicitly disclosed to other users of the App (noting that Facial Data may be shown through sharing of a user’s profile photo to another user on the App, or implied through suggested matching making); (b) Facial Data is only shared with our LLM provider and cloud infrastructure provider as described above; and (c) we do not sell, rent, trade or otherwise make Facial Data available to any third party for that third party's own commercial purposes.
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data to countries which have laws that do not provide the same level of data protection as Australian law.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 12 months then we will treat the account as expired and your personal data may be deleted.
Facial Data Retention
Notwithstanding the general retention periods above, Facial Data is subject to the following specific retention and deletion schedule:
Active use: Facial Data is retained for so long as the photograph from which it was derived remains on your profile or in your account.
Photo replacement or removal: When you replace or remove a photograph, the Facial Data derived from that specific photograph is permanently deleted within 30 days.
Account deletion: All Facial Data is permanently deleted within 30 days of account deletion.
Consent withdrawal: If you withdraw your consent to Facial Data processing, we will immediately cease all processing of your Facial Data. Your Facial Data will remain stored (but unprocessed) in our systems until you delete your account, at which point it will be permanently deleted within 30 days of account deletion.
For the avoidance of doubt, the general retention periods applicable to other categories of personal data (including the 12-month post-deletion retention and 7-year litigation hold) do not apply to Facial Data. Facial Data is not retained beyond the periods specified above under any circumstances.
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
· Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we 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 (including, by way of example, where we are required to retain your personal data for a purpose contemplated by section 5 or 9).
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
· Request the transfer of your personal data to you or to a third party. We 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 us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 5 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us using the contact details contained in section 17. Please be aware that exercising any of the above rights may render the App unable to provide you any Services, in which case we may close and remove your account.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Office of the Australian Information Commissioner (OAIC), the Australian regulator for privacy and data protection issues (www.oaic.gov.au). We would, however, appreciate the chance to deal with your concerns before you approach the OAIC, so please contact us in the first instance..
We keep our Privacy Notice under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
The App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App, we encourage you to read the Privacy Notice of every website you visit.
If you have any questions about this Privacy Notice or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
· Email address: admin@orbitapp.co.uk.
· Postal address: Marvell St Assetco Pty Ltd c/o 268 Canterbury Road, Surrey Hills Victoria Australia
Last updated: April 2026