OrcaBe Limited – Legal Policies

​

​

Effective Date: June 2025

Last Updated: June 2025

 

 

Privacy Policy

 

 

OrcaBe Limited (referred to as “OrcaBe”, “we”, “us” or “our”) is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and retain personal data when you use the OrcaBe lifestyle app (the “App”) or visit our website. OrcaBe Limited is the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018 . Our registered address is [Registered Address TBC, United Kingdom].

 

Personal Data We Collect: When you register for and use the App, we collect certain personal data about you. This includes:

 

• Account Information: The name, email address and home/work address you provide when creating or managing your account. We also store a hashed password or authentication token for login purposes.

• Location and Proximity Data: The GPS location of your device and Bluetooth Low Energy (BLE) proximity signals while you use location-aware features of the App. (The App does not share or broadcast your live location to other users.)

• Device and Network Data: Your IP address, device identifiers, operating system and app version, and other diagnostic information collected automatically when you use the App.

 

 

All of the above information qualifies as personal data under UK GDPR because it relates to an identified or identifiable individual . For example, your name, address, GPS coordinates, IP address and BLE beacons are identifiers or factors that can directly or indirectly identify you . We do not collect any special categories of data (such as health or financial details) and we do not record any information about criminal convictions.

 

How We Use Your Data: We process your personal data for specific purposes, including:

 

• Providing the App’s core functionality (such as account access, personalization, and App features).

• Enabling location-based services (such as maps or local suggestions), while storing any location or proximity data only in anonymised form for analysis. We do not use your location or BLE data to identify you personally.

• Sending you account-related communications (security alerts, updates) via email.

• Improving and analysing our services (e.g. to optimise App performance and user experience through usage statistics).

• Detecting and preventing fraud or security issues (by analysing device/network patterns).

• Complying with legal obligations (for example, responding to lawful requests, court orders or regulatory requirements).

 

 

We will not process your personal data for any purposes other than those explained in this Policy. We do not sell or rent your personal data to third parties under any circumstances.

 

Lawful Basis: Under UK GDPR, we rely on lawful bases to process your data. Typically, processing is necessary for the performance of our contract with you (providing the App features), or it is in our legitimate interests (for instance, improving services, ensuring security, or enforcing our rights). When required by law, we rely on your consent (for example, if we were to send marketing emails or use analytics cookies in future), which you may withdraw at any time.

 

Disclosure to Third Parties: To provide the App, we share certain personal data with trusted service providers. These include: Amazon Web Services (AWS) for cloud hosting and storage; Google Maps and Apple Maps for mapping and location services; mobile platform APIs (Android and iOS location services, notifications, etc.); Zoho Mail (or a similar provider) for sending emails; and any authentication/one-time password services used for account verification. These providers act as data processors on our behalf and help us provide the service. We have assessed their privacy and security measures and require them to implement appropriate safeguards for your data . We remain responsible for ensuring your data is handled in compliance with law. In any case, we do not share your personal data with advertisers or third parties for their marketing purposes.

 

Cookies and Tracking: We use browser cookies and similar tracking technologies on our website and web portal to enable essential features (such as remembering your login session or language preferences). These are strictly necessary cookies required for the operation of our services. We do not currently use analytics or advertising cookies. If we introduce any analytics, performance or marketing cookies in the future, we will only do so after obtaining your explicit consent, as required by UK law (the Privacy and Electronic Communications Regulations) . Under these regulations, we must give clear information about our cookies and obtain opt-in consent for any non-essential cookies . You can control cookies via your browser or device settings (for example, reject or delete cookies). Disabling cookies may affect your ability to use certain features of our services.

 

International Data Transfers: Your personal data may be accessed, stored and processed in countries other than the United Kingdom (for example, by our cloud provider or external processors). Where we transfer personal data outside the UK or European Economic Area, we will ensure appropriate safeguards are in place (for example, using UK/EU Standard Contractual Clauses or transferring to countries approved by the UK as providing adequate protection). For example, the European Commission has determined that the UK provides an adequate level of protection, allowing free flow of data from the EU to the UK . When transferring data to countries without an adequacy decision (such as the US), we implement approved safeguards (e.g. standard contractual clauses) to ensure legal compliance.

 

Data Retention and Deletion: We retain your personal data only as long as necessary to fulfill the purposes described above, and to comply with legal or contractual obligations . Specifically:

 

• All personal data associated with your account is kept while your account is active. When you delete your account or request deletion, we will erase your personal data from our active systems without undue delay .

• We will promptly delete or anonymise any personal data that is no longer needed for the purposes set out in this policy .

• Some data may be retained in anonymised or aggregated form even after account deletion (for example, anonymised location statistics or usage metrics). This data cannot be linked back to you individually and is used only for improving the service.

 

 

We have a formal retention schedule to govern how long different categories of data are kept . For example, backup or log records may be retained for a specified period (such as 1-2 years) for security or troubleshooting, provided they are anonymised. We regularly review the data we hold and delete or anonymise any data that is no longer needed, in accordance with UK GDPR’s storage limitation principle .

 

Data Security: We protect the security of your personal data using reasonable technical and organisational measures. For example, we encrypt all data at rest using industry-standard encryption provided by AWS . We also use secure network protocols (such as HTTPS/TLS) to transmit data. Access to personal data within our systems is restricted to authorised personnel only. While we strive to keep your data secure, no method of transmission or storage can be guaranteed to be 100% secure. In the event of a personal data breach, we will comply with our legal obligations. In particular, we will notify the UK Information Commissioner’s Office of a notifiable breach without undue delay and within 72 hours of becoming aware of it , and we will inform affected individuals when required by law.

 

Your Rights: You have rights regarding your personal data under the UK GDPR . In particular, you have the right to:

 

• Access: Obtain a copy of the personal data we hold about you.

• Rectification: Request correction of any inaccurate or incomplete data.

• Erasure (Right to be Forgotten): Request deletion of your personal data when it is no longer needed .

• Restriction: Request that we limit how we use your data.

• Objection: Object to our processing of your data (for example, for direct marketing or based on legitimate interests).

• Portability: Receive your personal data in a structured, machine-readable format and transfer it to another controller if desired.

• Withdrawal of Consent: Where processing is based on consent, withdraw your consent at any time.

• Complaints: Lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your data protection rights have been infringed .

 

 

To exercise any of these rights, please contact us using the details below. We will respond to your request without undue delay and, in any event, within the timeframes required by law (generally within one month) .

 

Children’s Data: The App is intended for users aged 16 or over. We do not knowingly collect personal data from children under 16. If we learn that we have inadvertently collected data from someone under 16, we will delete that data promptly.

 

No Automated Decisions: We do not use your personal data for any fully automated decision-making or profiling that has legal or significant effects on you. Any analytics or decisions derived from your data are made only with human oversight, and you have the rights listed above.

 

Changes to This Policy: We may modify this Privacy Policy at any time. We will indicate the last updated date at the top of this Policy and (if appropriate) notify you through the App or by email of material changes. Please review this Policy periodically. Your continued use of the App after any updates signifies your acceptance of the updated Policy.

 

Contact: If you have any questions or requests regarding your personal data or this policy, please contact our Data Protection Officer at hello@orcabe.com, or write to us at [Registered Address TBC, United Kingdom]. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) via https://ico.org.uk/concerns/ if you are unsatisfied with our handling of your data.

 

 

Terms of Use

 

 

Effective Date: June 2025

 

Please read these Terms of Use (“Terms”) carefully. By downloading, installing or using the OrcaBe app (the “App”) or accessing any OrcaBe website or service, you agree to be bound by these Terms and by our Privacy Policy and Cookie Policy. If you do not agree with these Terms, you must not use the App or related services.

 

Definitions: In these Terms, “you” or “your” refers to the user of the App, and “we”, “us” or “our” refers to OrcaBe Limited. “Personal data” has the meaning given in data protection law (information relating to an identifiable person ). “Privacy Laws” refers to the UK GDPR and Data Protection Act 2018.

 

Eligibility: The App is intended for users who are at least 16 years old. By using the App or creating an account, you represent and warrant that you are 16 or older. We do not knowingly allow anyone under 16 to register or use the App. If you are between 16 and 18, you confirm that you have parental consent to use the App.

 

Use of the App: OrcaBe grants you a limited, personal, revocable, non-exclusive, non-transferable license to use the App on your compatible device for your personal, non-commercial use only. You may not sublicense, distribute or transfer the App or your rights under these Terms. You agree not to copy, reproduce, modify or create derivative works of the App or circumvent any protection measures. You agree not to reverse engineer, decompile, or disassemble the App, or attempt to do so.

 

User Conduct: You agree to use the App in compliance with all applicable laws and these Terms. In particular, you will not:

 

• Harass, stalk, defraud, or harm others.

• Transmit any unlawful, infringing, defamatory, obscene, or otherwise objectionable content.

• Attempt to gain unauthorized access to any part of the App or its related systems.

• Impersonate any person or entity, or misrepresent your affiliation with any person or entity.

 

 

Account and Security: If you register an account, you are responsible for maintaining the confidentiality of your login credentials. You agree to provide accurate and up-to-date registration information. You are responsible for all activities that occur under your account. OrcaBe reserves the right to suspend or terminate your account if you breach these Terms or if we suspect fraudulent or illegal activity.

 

External Links: The App may include links to third-party websites or services for your convenience. OrcaBe is not responsible for the content, security or privacy practices of those external sites. Any access or use of linked third-party services is at your own risk and subject to the terms and policies of those services.

 

Account Suspension and Termination: We may suspend or terminate your access to the App at any time and for any reason, including if we believe you have violated these Terms. Upon termination, your rights under these Terms will immediately cease, though provisions of these Terms intended to survive (such as Intellectual Property, Disclaimers, and Limitations of Liability) will continue to apply.

 

Intellectual Property: The App, its content, software, graphics, user interface, visual design, compilation, data, and products and services are protected by copyright, trademark, and other laws. OrcaBe and/or its licensors own all rights in the App and its contents, including all software code and graphic design. The name “OrcaBe” and our logo are trademarks of OrcaBe Limited. All other trademarks or service marks displayed in the App are the property of their respective owners. You are not granted any right, title or license to any of our intellectual property except as expressly set out in these Terms.

 

Feedback: We welcome your feedback and suggestions. Any feedback, comments, or suggestions you may provide regarding the App or its features (“Feedback”) shall be given entirely voluntarily. You grant OrcaBe a perpetual, irrevocable, worldwide, royalty-free license to use, reproduce, modify, adapt, publish, and distribute such Feedback without restriction.

 

Disclaimers: To the fullest extent permitted by law, OrcaBe disclaims all warranties, express or implied, including any warranty of merchantability, fitness for a particular purpose, or non-infringement . The App is provided on an “as is” and “as available” basis. OrcaBe does not warrant that the App will be uninterrupted, secure or error-free, or that it will meet your requirements. The App may provide lifestyle, health or wellness information for general guidance only; it is not a substitute for professional medical, health, legal or financial advice, nor should it be relied upon as such. Your use of the App is at your own risk.

 

Nothing in these Terms limits or excludes liability for death or personal injury caused by our negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by law.

 

Limitation of Liability: To the extent permitted by law, neither OrcaBe nor its officers, directors, employees, agents or affiliates will be liable for any indirect, incidental, special, consequential or punitive damages arising out of or related to your use of (or inability to use) the App, even if we have been advised of the possibility of such damages. This includes, but is not limited to, damages for loss of profits, data, goodwill, or other intangible losses. In any event, our total aggregate liability arising out of or relating to these Terms or the App will not exceed one hundred pounds (£100) or the minimum statutory amount, whichever is lower (acknowledging that the App is provided free of charge).

 

Indemnification: You agree to indemnify and hold harmless OrcaBe and its officers, directors, employees and agents from any claims, liabilities, damages, losses or expenses (including reasonable legal fees) arising out of or related to your violation of these Terms or your misuse of the App, including any content you submit or any breach of your representations.

 

Changes to the App and Terms: We may update, suspend or discontinue the App (or any feature) at any time without notice. We may also modify these Terms at any time. If we make material changes, we will notify you by revising the date at the top of these Terms or by sending a notice via the App or email. Your continued use of the App after any changes means you accept the new Terms.

 

Notice: Any notice required by these Terms or applicable law must be in writing. Notices to you may be given by email to the address you provided, or by posting in the App. Notices to OrcaBe should be sent to hello@orcabe.com or to our registered address.

 

Time to File Claims: Any claim or cause of action arising out of or related to these Terms or the App must be filed within one year after such claim arises. After one year, all such claims are barred.

 

Force Majeure: OrcaBe will not be liable for any failure or delay in performing its obligations under these Terms due to events beyond its reasonable control (e.g., acts of God, internet outages, war, strikes, or natural disasters).

 

Governing Law and Dispute Resolution: These Terms and your use of the App are governed by the laws of England and Wales. Any claim or dispute related to these Terms or the App shall be subject to the exclusive jurisdiction of the courts of England and Wales . You agree to bring any claim only in your individual capacity, not as a plaintiff or class member in any purported class action. If you have any concerns or disputes, please contact us first at hello@orcabe.com. We will try to address your concerns. If a dispute cannot be resolved informally, it will be resolved by the courts of England and Wales.

 

Governing Language: These Terms and any notices, alerts or electronic communications from OrcaBe will be in the English language. In case of any conflict, the English version will prevail.

 

Relationship: Nothing in these Terms creates a partnership, joint venture, employment or agency relationship between you and OrcaBe.

 

Assignment: You may not assign or transfer your rights under these Terms without our prior written consent. OrcaBe may assign its rights or obligations to any affiliate or successor.

 

No Third-Party Beneficiaries: These Terms are for the benefit of you and OrcaBe only. They do not create any rights for any third party.

 

Entire Agreement: These Terms (together with the Privacy Policy and Cookie Policy) constitute the entire agreement between you and OrcaBe regarding the App, and supersede any prior or contemporaneous agreements, proposals, or communications, whether oral or written.

 

Contact Information: OrcaBe Limited is a company incorporated in the UK. If you have any questions about these Terms, you may contact us at hello@orcabe.com or by mail at [Registered Address TBC, United Kingdom].

 

 

Cookie Policy

 

 

We use cookies and similar technologies on our website to distinguish you from other users and to enhance your experience . Cookies are small text files placed on your device by your browser. They can store information such as user preferences and session identifiers.

 

• Essential Cookies: These cookies are strictly necessary to provide our services (for example, to maintain your login session or remember basic settings). They enable basic functions of the site and cannot be disabled.

• Analytics and Performance Cookies: We currently do not use cookies to track analytics or performance. In the future, we may deploy such cookies (for example, to understand usage patterns) but we will only do so after obtaining your consent.

• Advertising and Marketing Cookies: We do not use cookies for advertising or marketing at this time. If we introduce any advertising cookies in the future, we will require your prior consent.

 

 

We will display a cookie banner on first visit to inform you of non-essential cookies and to request your consent. By continuing to use our website, you agree to the use of essential cookies as described. Under UK law (the Privacy and Electronic Communications Regulations) and GDPR, we must provide clear information about our use of cookies and obtain consent for non-essential cookies .

 

You can control cookies through your browser settings. For example, you can set your browser to refuse cookies, clear cookies, or alert you before accepting a cookie. Disabling or deleting cookies may affect your ability to use parts of our site. To opt out of Google Analytics cookies, you can install Google’s opt-out browser add-on or refer to https://www.allaboutcookies.org/ for guidance on managing cookies.

 

Policy Updates: We may revise this Cookie Policy at any time. When we do, we will update the “Last updated” date. Please revisit this page to stay informed of any changes.

 

 

Accessibility & User Rights

 

 

Accessibility: OrcaBe is committed to making our App accessible to all users, including those with disabilities. We follow best practices such as the Web Content Accessibility Guidelines (WCAG) and consider accessibility throughout our design and development process. In the UK, the Equality Act 2010 prohibits discrimination on the basis of disability and explicitly applies to websites and mobile apps . Conformance with WCAG Level AA is strongly encouraged to meet these requirements . We aim to provide a reliable and accessible user experience.

 

We design our user interface and content to be as accessible as possible. This includes, for example, providing alternative text for non-text content (such as images), ensuring sufficient color contrast, enabling keyboard navigation, and writing clear, simple language. We test the App on multiple devices and use automated tools to check accessibility compliance where possible. While we strive for high accessibility standards, we acknowledge that perfect compliance in all cases can be challenging. If you encounter an accessibility barrier or have feedback on accessibility, please contact us at hello@orcabe.com and we will make reasonable efforts to address it.

 

User Rights (Data Protection): We respect the rights of users under the UK GDPR and Data Protection Act 2018. Data subjects have various rights regarding their personal data, including rights to access, rectification, erasure, restriction of processing, data portability, and to object to processing . We provide mechanisms for users to exercise these rights as described in our Privacy Policy above. If you wish to exercise any of your data protection rights, please contact us as described in the Privacy Policy. You also have the right to lodge a complaint with the UK Information Commissioner’s Office if you are unsatisfied with our response .

 

OrcaBe’s goal is to ensure that the App is usable by all. We continually work to improve accessibility, and we welcome any suggestions for making our App more accessible.

 

Contact: If you have any questions about accessibility or your data rights, please contact us at hello@orcabe.com or [Registered Address TBC, United Kingdom].

 

 

Data Retention & Deletion Policy

 

 

We have a formal data retention policy to ensure we do not keep personal data longer than necessary, in compliance with UK GDPR . Specifically:

 

• Active Data: We retain personal data (such as your account details and contact information) only for as long as needed to provide our services. If you request account deletion or close your account, we promptly erase your personal data from our systems .

• Location/BLE Data: Location data and Bluetooth proximity data are stored only in anonymised (pseudonymised) form for analysis. These anonymised records do not contain personal identifiers and are used only for aggregate statistics or improving services.

• No Long-Term Identifiers: We do not retain location or BLE data in a way that can identify you personally. After processing, such data is either deleted or permanently anonymised.

• Regular Review: We regularly review the data we hold and delete or anonymise any data that is no longer needed, in accordance with our retention schedule and UK GDPR principles . For example, we may delete or archive inactive accounts after extended inactivity (with notice to the user, if appropriate).

• Backups: Any backups containing personal data are stored securely. We ensure that backups are overwritten or purged according to our retention schedule so that old personal data does not remain indefinitely.

 

 

Deletion of personal data is performed securely. When you delete your account or request data erasure, we delete all personal information from our active databases. Any remaining data in backups will be deleted or overwritten as soon as reasonably practicable. Aggregated or anonymised data derived from personal information (such as usage trends) may be retained indefinitely, since it cannot be used to identify any individual .

 

We comply with UK GDPR Article 5(1)(c) and (e), which require personal data to be adequate, relevant, limited to what is necessary, and not kept longer than necessary . We periodically review our retention practices to ensure ongoing compliance. If you have questions about our retention practices or wish to request data deletion, contact us using the details below.

 

 

Third-Party Services & APIs

 

 

OrcaBe uses a variety of third-party services and APIs to provide its features. When you use the App, some of your data may be shared with these providers, but only to the extent necessary and under strict controls. Major third parties include:

 

• Amazon Web Services (AWS): We use AWS to host our servers and store data. AWS acts as our data processor, and we leverage its security features including encryption at rest . AWS is a global provider; any personal data transferred to AWS in another country is protected under UK GDPR safeguards (e.g. Standard Contractual Clauses).

• Mapping and Location Services: We use the Google Maps API and Apple Maps API to provide map displays and location search. When you use mapping features, your GPS coordinates (and search queries) are sent to these services. Google and Apple process this data under their own privacy policies. We have assessed these providers and require them to protect your data . In particular, we do not allow them to use your data for their own unrelated purposes.

• Mobile Platform APIs: The App uses built-in features of Android and iOS (such as GPS, Bluetooth, and push notifications) to deliver functionality. Any personal data accessed via these platform APIs stays on your device or is sent through secure channels specified by the platform. We do not share your mobile platform data beyond what is needed for App functionality.

• Email and Communications: We use a third-party email service provider (such as Zoho Mail) to send account-related emails (password resets, notifications). We share your email address with this provider solely to enable email delivery. We ensure that the provider uses the data only for this purpose and complies with privacy obligations.

• One-Time Password (OTP) Verification: If the App uses OTP for login or security, we use a reputable third-party service (such as Twilio) to deliver codes. Your phone number or email may be shared with that provider solely to send you the verification code.

• Bluetooth Low Energy (BLE) Proximity: The App uses BLE technology to detect nearby devices or beacons for proximity-based features. This involves scanning for BLE signals. The BLE identifiers collected are not personal data unless linked to a known user. We treat BLE data as personal where it might indirectly identify you and handle it accordingly (encrypting and storing it in anonymised form).

 

 

We do not share your personal data with advertising networks or third parties for marketing. All third-party vendors acting as processors are under contract to protect personal data and follow data protection laws. We conduct due diligence on these partners and require that they implement security measures comparable to our own. For example, any analytics data we collect will be used only in aggregated form. Government guidance on analytics tools notes that analytics providers should not use collected data for their own purposes .

 

We currently do not integrate with any social media logins (such as Facebook Login) or advertising SDKs. If we add any new third-party integration or API in the future, we will update this policy with details and ensure compliance with all privacy and consent requirements.

 

If you choose to use any third-party websites or services linked from the App, those services’ own terms and privacy policies will apply. OrcaBe is not responsible for the practices of external sites.

 

 

Legal Notice & Dispute Resolution

 

 

Legal Notice: The content provided through the App (including text, graphics, and other materials) is for general informational purposes only. OrcaBe makes no representations about the accuracy or completeness of any content, and you should not rely on it as professional advice. All content is provided “as is” without warranty. You are responsible for your use of the App and any actions you take based on its content.

 

Trademarks: All product names, logos, and brands are the property of their respective owners. The name “OrcaBe” and its logo are trademarks of OrcaBe Limited. Any other trademarks or service marks referenced are used only for identification and belong to their respective owners.

 

Governing Law: These legal policies, and any dispute arising from them, are governed by the laws of England and Wales. Any claim or dispute related to these policies or the App shall be subject to the exclusive jurisdiction of the English courts . You consent to this jurisdiction by using the App.

 

Dispute Resolution: If you have any concerns or complaints about the App, please contact us first at hello@orcabe.com. We will attempt to address your concerns. If a dispute cannot be resolved informally, the parties agree that any unresolved dispute shall be resolved by the courts of England and Wales, as above.

 

Changes to Policies: We may update these policies. When we do, we will revise the effective date above. If we make major changes that affect your rights, we will also attempt to notify you (for example via email). Please review these policies periodically to stay informed. Continued use of the App after updates signifies acceptance of the updated policies.

 

Severability and Waiver: If any provision of these policies is held invalid or unenforceable, the remaining provisions will continue in full force. No failure or delay by OrcaBe in exercising any right shall waive that right.

 

Consumer Rights: These policies do not affect any statutory rights that cannot be excluded. If you are a consumer in the UK, nothing here restricts your rights under consumer protection law.

 

Language: These policies are drafted in English. If translations are provided, the English version will prevail in case of any discrepancy.

 

Contact: If you have any questions or disputes regarding these policies, you may contact OrcaBe at hello@orcabe.com or by mail at [Registered Address TBC, United Kingdom]. OrcaBe is a company based in the UK. We will attempt to resolve any issues in good faith before resorting to legal action.