Privacy Policy

This Privacy Policy describes how Orthogonal Thinker, Inc. ("The Company") collects, uses, and handles personal information through www.orthogonalthinker.com and its investor portal (the "Site"). It describes what is actually collected, where it goes, who receives it, and how long it is retained. This policy reflects the actual scope and technical implementation of the Site as of its effective date.

Information We Collect Directly — Public Website

We collect information you voluntarily submit through forms on the public website.

Contact inquiries. When you contact us, we collect your full name, email address, and message.

Founder applications. When you submit a founder application, we collect your name, email address, company website, company name, sector, stage of development, and narrative responses about your company's traction, technology or product advantage, market position, strategic fit with The Company, and long-term ownership potential.

Manifesto interest. If you submit your email address on the Manifesto page, we collect that email address.

NDA and restricted access (when enabled). If The Company enables a restricted offering area, submitting an NDA acknowledgment will collect your full legal name, entity or organization name (optional), any additional notes you provide, your IP address at the time of submission (to record acknowledgment of the agreement), and a timestamp. This feature is not currently active.

All forms transmit data by POST over HTTPS. Personal information does not appear in any URL.

Information We Collect — Investor Portal

The investor portal is an access-controlled area of the Site available to authorized investors. The following categories of personal information are collected and stored in connection with the portal.

Authentication. Access to the portal requires your email address. An authentication code is sent to that address each time you sign in. Session state is maintained by our authentication provider for the duration of your session.

Account and profile information. Once signed in, you may provide your full name, mailing address, phone number, and an Ethereum wallet address. This information is stored in our database and used to maintain your account and associate you with investment records.

Investment records. The portal displays cap table and investment information associated with your account, including names, contact details, and investment details. This information is managed by The Company and displayed only to authenticated users associated with those records.

Documents. You may upload, view, and download documents through the portal. Uploaded files are stored in secure cloud storage. Documents are accessible only to authenticated users with appropriate permissions.

Support requests. You may submit support requests through the portal. We collect the summary and details of each request, which are stored in our database and reviewed by The Company's team.

Account deletion. You may request deletion of your account through the portal settings. Upon confirmed deletion, your authentication record and profile data are removed from our systems, subject to any retention obligations described below.

Information Collected Automatically

Analytics. The Site uses Google Analytics (Google LLC) to collect anonymous usage data. This includes pages visited, time on page, approximate geographic region, browser type, device type, and referrer. This data is not linked to any form submission or account data and does not identify you personally.

Web fonts. The public website loads fonts from Google Fonts, operated by Google LLC. When your browser requests a font file, Google's servers receive your IP address and browser information. We do not control this processing; Google's privacy policy governs it.

Hosting and server logs. The Site is hosted on Vercel's infrastructure. Vercel's servers generate standard request logs that include IP addresses, browser information, URLs requested, and timestamps. These logs are retained and processed by Vercel according to its privacy policy.

Cookies and Browser Storage

Analytics cookies. Google Analytics places persistent analytics cookies on your browser to distinguish visitors and track usage sessions. These cookies remain active for approximately two years.

Authentication cookies. The investor portal uses secure session cookies to maintain your authenticated session. These are managed by our authentication provider and are cleared when you sign out or your session expires.

Temporary browser storage. The public website uses temporary browser session storage for non-sensitive UI state — such as whether an intro animation has already played. This data never leaves your device and is cleared when you close the browser tab.

We do not use advertising cookies, remarketing pixels, or behavioral tracking technology beyond Google Analytics. You can opt out of Google Analytics data collection by installing the Google Analytics Opt-out Browser Add-on, or by configuring your browser to block third-party cookies. Opting out does not affect your ability to use the Site.

How We Use Your Information

We use form submissions to respond to inquiries, evaluate founder applications, and manage access to restricted materials. We use investor portal data to provide and maintain the portal, display investment records, enable document management, and respond to support requests. We use analytics data to understand how the Site is used and to improve it. We do not use your information for advertising, behavioral profiling, or resale. We do not add you to any mailing list on the basis of a contact or application submission.

Confidentiality of Submissions

All information submitted through the Site is treated as confidential and reviewed only by The Company's team. We do not publish, share, or distribute it to unauthorized parties. If you execute a non-disclosure agreement in connection with accessing restricted materials, the terms of that agreement govern the handling of information exchanged under it.

Third-Party Service Providers

We use the following third-party providers that may receive or process personal information on our behalf or in connection with operating the Site:

Google LLC — Google Analytics (anonymous usage data) and Google Fonts (font delivery). Google's privacy policy: policies.google.com/privacy.

Formspree, Inc. / Tally — receives and delivers form submissions from the contact form, founder application, and manifesto interest form. Submissions are transmitted over HTTPS and forwarded to us by email. Either or both services may be in use at a given time.

Supabase — provides authentication, database storage, and file storage for the Site. Account data, investment records, documents, and support requests are stored on Supabase infrastructure.

Vercel — hosts and delivers the Site. Generates server-side request logs as described above.

We do not sell personal data. We do not share personal data with any third party for advertising or marketing purposes.

Data Retention

Form submissions are retained for as long as operationally relevant, and typically for no more than two years unless a longer period is required for a specific business or legal purpose. Analytics data is retained for 24 months. Account and profile information is retained for the duration of your access relationship with The Company and for as long as required for legal or regulatory purposes. Investment records are retained as required by applicable law and business necessity. Documents you upload are retained until you delete them or your account is closed. Support request records are retained for as long as operationally necessary. NDA submission records are retained for as long as required to document the agreement.

Security

We use commercially reasonable measures to protect personal information, including encrypted transmission (HTTPS) for all data in transit and access controls that limit sensitive data to authenticated, authorized users. No method of internet transmission is completely secure, and we cannot guarantee absolute security. In the event of a confirmed data breach involving personal information, we will notify affected individuals as required by applicable law.

Your Rights and Choices

You may request access to, correction of, or deletion of personal data we hold about you by contacting us at info@orthogonalthinker.com. Investor portal users may also update or delete their profile data directly through the portal settings. We will respond to data requests within 30 days. You may also opt out of Google Analytics as described in the Cookies section above.

California Privacy Rights

California residents may have rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). We do not sell personal data. We do not share personal data with third parties for cross-context behavioral advertising. California residents may contact us at info@orthogonalthinker.com to request information about personal data we hold or to request deletion.

European Users

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have rights under applicable data protection law, including rights of access, rectification, erasure, restriction of processing, and data portability. To exercise your rights or make a data-related request, contact info@orthogonalthinker.com.

We process personal data on the basis of legitimate interests (site analytics and improvement, server logging inherent to web hosting, and evaluating business inquiries) and, for investor portal users, on the basis of our relationship with you as an investor. For transfers of personal data from the EEA, UK, or Switzerland to the United States, we rely on applicable transfer mechanisms. We require third-party processors to maintain appropriate data protection safeguards.

Children

The Site is not directed to individuals under the age of 16. We do not knowingly collect personal information from minors. If you believe we have inadvertently received personal information from a minor, contact us at info@orthogonalthinker.com and we will delete it promptly.

Changes to This Policy

We may update this policy from time to time. The effective date below reflects when this version was last updated. We will post the revised policy on this page. Continued use of the Site after an update constitutes your acknowledgment of the revised policy.

Contact

Questions about this Privacy Policy: info@orthogonalthinker.com.

Effective Date

This Privacy Policy was last updated on September 8, 2026.