Private by design, not by marketing copy.

1. Purpose of this policy

Ludo Leisure Suite Pty Ltd ABN 98 605 555 833 ("we", "us", or "our") has adopted this Privacy Policy to ensure that we have standards in place to protect the Personal Information that we collect about individuals that is necessary and incidental to:

• Providing the Orbit application and related services; and
• The normal day-to-day operations of our business.

This Privacy Policy follows the Australian Privacy Principles set by the Australian Government for the handling of Personal Information under the Privacy Act 1988 (Cth) ("Privacy Act").

By publishing this Privacy Policy, we aim to make it easy for our customers and the public to understand what Personal Information we collect and store, why we do so, how we receive or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.

2. Who and what this policy applies to

This policy deals with how we handle "personal information" as defined in the Privacy Act ("Personal Information").

• We handle Personal Information in our own right and also for and on behalf of our customers and users.
• This policy does not apply to information we collect about businesses or companies, but it does apply to information about the people in those businesses or companies that we store.
• This policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.
• If an individual provides Personal Information about someone other than themselves, they warrant that they have that person's consent to provide such information for the specified purpose.
• Our website and services are unavailable to children (persons under the age of 18 years) without their parent or guardian's consent.

3. The information we collect

In the Orbit app

The app is designed around local-first storage. The people you add, the notes you keep, and the events you plan are intended to stay under your control.

• People you add and how you place them in circles
• Moments, notes, reminders, and relationship context
• Events you create and the guest details you choose to include

On the website

In the course of business, we may collect the following types of information:

• Personal Information such as name and email address when you join the waitlist or contact us
• Contact Information including email address and any details you provide in support messages
• Basic server logs for security and debugging
• Statistical information for understanding how the site is used

4. How information is collected

Most information will be collected in the following ways:

• Registrations and signups. When individuals register for the beta or join the waitlist, they provide Personal Information.
• Contact. When individuals contact us through the website, email, or support channels.
• Access. When individuals access our website, basic server logs are generated.

We will ensure that individuals are aware of when their Personal Information is being collected. Where we obtain Personal Information without an individual's knowledge, we will either delete the information or inform the individual that we hold such information, following the Australian Privacy Principles.

5. When Personal Information is used and disclosed

In general, we will not use Personal Information other than for the purpose for which it was collected, except with the individual's permission. We will retain Personal Information for the necessary period, unless a longer retention period is required or permitted by law.

Information is used for purposes including:

• Providing the Orbit app and related services
• Communicating with individuals about their account or the beta program
• Responding to support or feedback messages
• Investigating complaints or unlawful activity
• As required or permitted by law

We will not disclose Personal Information to entities outside of Australia without ensuring similar privacy safeguards are in place.

6. Analytics

We use privacy-respecting analytics to understand what people read and whether the site is working. The goal is product clarity, not surveillance. We do not use third-party ad tracking or cross-site profiling.

7. Opting in or out

An individual may choose to have us collect their Personal Information or exclude themselves from some or all collection of Personal Information.

If an individual believes they received information from us without their consent, they should contact us using the details at the end of this policy.

8. Safety and security of Personal Information

• We will take reasonable precautions to protect Personal Information from unauthorized access, misuse, loss, and modification.
• We use SSL encryption to store and transfer Personal Information, but online security cannot be guaranteed.
• We are not responsible for the privacy or security practices of third parties.
• If you suspect any misuse or unauthorized access to your Personal Information, please contact us immediately.

9. Data you choose to share

If you export data, send an invite, or share something outside Orbit, that copy can then live wherever you send it. That is your choice, but it means the data is no longer only inside Orbit.

10. Your rights

Subject to the Australian Privacy Principles, individuals have the following rights:

• Access what we hold about you. We will respond to written requests within 28 days.
• Ask for corrections. We will correct errors within 7 days of receiving written notice.
• Request deletion of your Personal Information.
• Export your data from the Orbit app.
• Object to processing where applicable.

We may charge a reasonable fee for our costs incurred in meeting requests to disclose Personal Information we hold.

11. Complaints and disputes

If you have a complaint about our handling of your Personal Information, please address your complaint in writing to the contact details below.

If we have a dispute regarding your Personal Information, we must first attempt to resolve the issue directly. If we become aware of any unauthorized access to your Personal Information, we will inform you at the earliest practical opportunity once we have established what was accessed and how.

12. Contact

All correspondence regarding privacy should be addressed to:

The Privacy Officer
Ludo Leisure Suite Pty Ltd
1044A/1046A Dandenong Rd, Carnegie VIC 3163, Australia

Use the contact form on this page or on the support page to reach us.

13. Changes to this policy

If we decide to change this Privacy Policy, we will post the changes on our website. Please refer back to this policy to review any amendments.

We may do things in addition to what is stated in this Privacy Policy to comply with the Australian Privacy Principles, and nothing in this Privacy Policy shall deem us to have not complied with the Australian Privacy Principles.