Privacy Policy

1. Introduction and Scope

Orion Private Wealth Consulting LLC ("Orion," "we," "us," or "our") respects your privacy and is committed to protecting the personal data of individuals who visit our website, submit an inquiry, or otherwise interact with our services. This Privacy Policy explains what information we collect, how we use it, and the rights available to you under applicable data protection laws, including the EU General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act.

2. Data Controller

For the purposes of the GDPR and other applicable privacy laws, the data controller is Orion Private Wealth Consulting LLC, a Florida limited liability company. Contact details for privacy-related matters are provided in Section 17 below.

3. Information We Collect

We may collect: (a) information you provide directly, such as your name, email address, phone number, country of residence, and the content of any inquiry or partnership application submitted through our contact and partner forms; (b) technical information collected automatically, such as IP address, browser type, device identifiers, and pages visited, gathered through cookies and similar technologies; and (c) information you choose to share during subsequent correspondence, calls, or meetings.

4. How We Use Your Information

We use the information we collect to: respond to inquiries and facilitate introductions consistent with our success-fee referral model; operate, maintain, and improve our website; communicate with prospective clients and partners; comply with legal, tax, and anti-money-laundering obligations; and, where you have consented, send occasional updates about our services.

5. Legal Basis for Processing (GDPR)

Where the GDPR applies, we process personal data on the following legal bases: performance of steps requested by you prior to entering into a referral relationship (Art. 6(1)(b)); our legitimate interests in operating and promoting our business, provided these are not overridden by your interests or fundamental rights (Art. 6(1)(f)); compliance with legal obligations, including AML and sanctions screening (Art. 6(1)(c)); and your consent for optional marketing communications (Art. 6(1)(a)), which you may withdraw at any time.

6. Cookies and Tracking Technologies

Our website uses cookies and similar technologies, including Google Analytics and Google Tag Manager, to understand site usage and improve user experience. We operate under Google's Consent Mode v2 framework: non-essential cookies remain disabled by default until you provide affirmative consent through our cookie banner. You may withdraw or adjust your consent at any time through your browser settings or the cookie preferences link in our website footer.

7. Data Sharing and Disclosure

We do not sell personal data. We may share information with: (a) our carefully selected network of asset and referral partners, but only to the extent necessary to facilitate an introduction you have requested or consented to; (b) service providers who support our website, communications, and business operations (e.g., hosting, analytics, email delivery) under contractual confidentiality obligations; (c) professional advisors (legal, accounting) as needed; and (d) regulators, courts, or authorities where required by law, or to comply with AML, sanctions, or other legal obligations.

8. International Data Transfers

As a US-based company serving clients across the UAE, Switzerland, France, and other jurisdictions, we may transfer personal data internationally. Where personal data originating in the European Economic Area or United Kingdom is transferred to a country not deemed to offer adequate protection, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses, or your explicit consent where applicable.

9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, including any period required to comply with legal, accounting, tax, or anti-money-laundering obligations. Inquiry data from individuals who do not become clients or partners is generally retained for a limited period and then deleted or anonymized, unless a longer retention period is required by law.

10. Data Security

We implement reasonable technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Your Rights Under GDPR

If the GDPR applies to you, you have the right to: request access to your personal data; request correction of inaccurate data; request erasure of your data; request restriction of processing; object to processing based on legitimate interests or for direct marketing; request data portability; and lodge a complaint with your local supervisory authority. To exercise these rights, contact us using the details in Section 17.

12. Your Rights Under CCPA

If you are a California resident, you have the right to: know what personal information we have collected about you; request deletion of your personal information, subject to certain exceptions; opt out of the sale or sharing of personal information (Orion does not sell personal information); and not be discriminated against for exercising these rights. To exercise these rights, contact us using the details in Section 17.

13. EU Representative and Occasional Processing

Orion's processing of personal data originating in the EU is occasional, does not include large-scale processing of special categories of data, and is unlikely to result in a risk to the rights and freedoms of data subjects, taking into account the nature, context, scope, and purposes of the processing. On this basis, Orion relies on the exemption available under Article 27(2)(a) GDPR and has not appointed a formal EU representative. This position will be reassessed if the nature or scale of our EU-related processing changes materially.

14. Children's Privacy

Our services are directed to adults engaged in high-value transactions and are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected such data, we will take steps to delete it promptly.

15. Marketing Communications and Unsubscribe

Where you have consented to receive marketing communications from us, you may withdraw that consent at any time by clicking the unsubscribe link included in any such communication, or by contacting us directly using the details in Section 17. Withdrawing consent does not affect communications necessary to respond to an active inquiry or partnership relationship.

16. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where required by applicable law, within 72 hours of becoming aware of the breach. Where a breach is likely to result in a high risk to your rights and freedoms, we will also notify affected individuals directly and without undue delay, describing the nature of the breach and the measures taken or proposed in response.

17. Changes to This Policy; Governing Language; Contact

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date of the most recent revision will be indicated at the top of this page. This Privacy Policy is drafted in English; in the event of any conflict or ambiguity between the English version and a translated version, the English version shall prevail. For any questions or to exercise your rights, please contact us at admin@orionprivatewealthconsulting.com.