Privacy Policy

This privacy policy (“Privacy Policy”) describes how Orthogonal Thinker, Inc. and its subsidiaries (together “Orthogonal,” “we,” “us,” or “our”) collect, use and disclose any personal information you provide to us when using the site, services, and applications offered by Orthogonal (the “Services”) on and through https://orthogonalthinker.com (the “Site”). By accessing the Site or using the Services, you acknowledge and consent to our practices described below. Your access to the Site, use of the Services, this Privacy Policy and all defined terms used herein are subject to and governed by our Orthogonal Terms of Service. 

We emphatically value the trust of our users. We are committed to protecting your privacy and preserving your trust. Please carefully review this Privacy Policy to learn about the choices available to you regarding our use of your information.

Information We Collect and How We Use It

We collect information that may personally identify you (“Personally Identifiable Information”), such as when you sign up for an account on the Site, make an investment, provide payment instructions, fill out bank form information, comment on the part of the Site, provide your passport or identification-document, or provide us with access to your accounts on third-party sites (“Third-Party Sites”). The personal information collected from the Third-Party Sites may be used to register you on our Site and to provide some of our Services. You may be able to revoke our access to your account on the Third-Party Sites by updating the appropriate settings in the account preferences of the respective Third-Party Sites. You understand that certain features of our Site may not be available to you if you choose to remove our access to your account with the Third-Party Sites.

Personally Identifiable Information may include, among other things, your email address, name, phone number, birthday, address, investment experience, and your educational or professional history. Suppose you choose to invest through our Site. In that case, we will collect payment information from you, such as financial account information or card payment information, and we may collect information to verify your income or net worth. Please note that we do not store your card payment information, but we do store other financial information. If you choose to add an investment entity to your account, we will also collect information about the entity. The decision to provide this information is optional; however, if you decide not to register or provide such information, you may be unable to use certain features of the Site or the Services.

We may automatically collect information that does not identify an individual user, such as IP (internet protocol) address, ISP (internet service provider), the web browser used to visit the Site, the time the Site is visited, which web pages were visited on the Site, a mobile device-type identifier, and other anonymous Site usage data. In addition, we may use third-party analytics services that provide a clearer picture of how you use the Site, such as where you click on the Site, non-sensitive text entered into the Site, and mouse movements.

We also may use cookies and web beacons. Most web browsers are initially set up to accept cookies, but you can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain Site features may not work if you delete or disable cookies. In addition, if you choose to make an account, we provide private messaging services between registered users of the Site; while we do not monitor these messages, we will periodically select a few to review for compliance and audit purposes; therefore, you should assume any message you send through the Site may later be accessed by our staff or our regulators for compliance or audit purposes.

How We Share and Use Your Information

We may share the information you provide to us with our affiliated entities. However, if the Services you use are exclusively provided by one of the entities, you have the right to limit the other affiliated entities from contacting you for marketing purposes (“Affiliate Marketing”); please see Your Choice About Your Information below for details.

We provide the Personally Identifiable Information on a confidential basis to non-affiliated companies we engage as vendors or agents (i) to facilitate the Services provided on our site, such as escrow agents, transfer agents, counsels, advisors, accountants, banks and other financial service providers, and (ii) to service our operation, such as maintaining software or servers, designing or implementing marketing initiatives on our behalf, or conducting audit or testing of any aspect of our operation or Services. Information will be shared with such parties only to the extent reasonably necessary for them to perform services for us or on our behalf and pursuant to confidentiality obligations, or in response to information requests, subpoenas, court orders, or legal processes, from law enforcement agencies, self-regulatory organizations, state, federal and foreign regulators.

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive for the following: (i) to deliver and improve our Services; (ii) to manage your account and provide you with customer support; (iii) to perform research and analysis about your use of the Services; (iv) to develop, display, and track content and advertising tailored to your interests on the Services and other sites, including providing our advertisements to you when you visit other sites or mobile application; (v) to diagnose or fix technology problems; (vi) to automatically update the Services; (vii) to verify your identify and prevent fraud or other unauthorized or illegal activity; (viii) to enforce or exercise any rights in our Terms of Service; (ix) to provide users with statistics on how they use the Site relative to other anonymous users, and (x) to perform functions or services as otherwise described to you at the time of collection.

Orthogonal does not sell any customer data to third-party firms.

Information Provided in Discussion Forums

Securities offerings on Orthogonal’s Portal all include a publicly accessible discussion forum. Other pages on the Site also allow for public comment and discussion (“Public Comment”). You should be aware that any information you provide in these forums may be read, collected, and used by the Site’s users and the general public. Information you disclose in any of these forums is unencrypted, public information. There is no expectation of privacy or confidentiality; we reserve the right to use all Public Comments on the Site for marketing purposes. Please refrain from disclosing any Personally Identifiable Information about yourself or anyone else in these discussion forums.

If you choose to post a Public Comment on the Site through whatever means provided by the Site, we may share that Public Comment through other channels, including through the Site’s social media presences, as we see fit. However, if you subsequently delete or make private your Public Comment, we will discontinue any subsequent use but cannot retract previous re-publications of your previous Public Comment.

Suppose you choose to make your investment public (“Public Investment Notice”) through whatever means provided by the Site. In that case, as we see fit, we may share that “Public Investment Notice” through other channels, including the Site’s social media presence. However, suppose you subsequently make your Public Investment Notice private or withdraw such investment. In that case, we will discontinue any subsequent use but cannot retract previous re-publications of your previously-public Public Investment Notice.

Note also that in the ordinary course of internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. Orthogonal has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of the information you would not like to share.

Your Choices About Your Information

You may decline to submit Personally Identifiable Information through the Services, in which case Orthogonal may not be able to provide certain Services. In addition, you may update or correct your account information and email preferences at any time by logging into your account. If you would like us to remove or amend your Personally Identifiable Information from our database, please send a request to team@orthogonalthinker.com; please note, as many of the Services we provide are regulated, we will not be able to remove Personally Identifiable Information, we are required to retain for audit purposes.

When you sign up for our Services, we will send periodic emails to you regarding the Services or to tell you about services we believe will interest you. You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in these emails. In addition, suppose you do not wish to receive Affiliate Marketing, or any marketing, in general. In that case, you may opt-out at any time by clicking on the unsubscribe link in any email you receive, or you can also contact us at team@orthogonalthinker.com.

Notice to California Residents

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for and applicable only to California residents. If you are not a California resident, this does not apply to you, and you should not rely on it.

The CCPA defines “personal information” as information that identifies relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. Therefore, for purposes of this “NOTICE TO CALIFORNIA RESIDENTS” section, we will refer to this information as “Personal Information.”

Right to Know About Personal Information Collected, Disclosed, or Sold

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12 months preceding your request. This right includes the right to request any or all of the following:

Specific pieces of Personal Information that we have collected about you;

Categories of Personal Information that we have collected about you;

Categories of sources from which the Personal Information was collected;

Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;

Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and

The business or commercial purpose for collecting or, if applicable, selling Personal Information.

We do not knowingly collect or sell the Personal Information of minors under 16 years of age.

Right to Request Deletion of Personal Information

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if we must maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information. You may submit a request to know or delete it by emailing team@orthogonalthinker.com.

Our Process for Verifying a Request to Know or Delete

If we determine that your request is subject to an exemption or exception, we will notify you of our determination. On the other hand, suppose we determine that your request is not subject to an exemption or exception. In that case, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such a request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.

For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable to verify identities.

For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable to verify identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Right to Opt-Out of Sale of Personal Information

If you are a California resident, you have the right to direct us to stop selling your Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section, “NOTICE TO CALIFORNIA RESIDENTS.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident. 

Your California Privacy Rights

California’s “Shine The Light” law permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the Personally Identifiable Information (if any) we disclose to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information shared and the names and addresses of all third parties with whom we shared information in the preceding calendar year. If you are a California resident and would like to make such a request, please email team@orthogonalthinker.com.

Your European Union Privacy Rights

Orthogonal is pleased to have Users who reside in the European Union (“EU Users”). Orthogonal has voluntarily adopted certain provisions from the European Union’s General Data Privacy Regulation 2016/679 (“GDPR”). Accordingly, by accessing this Site, EU Users; (i) agree to consent to the Terms of Service; (ii) will be informed of any instance where Orthogonal becomes aware of a data breach, when it is likely to result in a risk for EU Users rights and freedoms, notwithstanding that this provision shall in no way affect your inability to find the Company liable for the negligence of its employees, partners, agents, third-party providers or Content providers; (iii) will be able to request a copy of the personal data Orthogonal collects, free of charge, in an electronic format that is “portable” (as defined by the GDPR), (iv) may contest the validity of the data the Company holds and ask for it to be amended; (v) will be able to request Orthogonal remove their data from the Site pursuant to Section 17 of the GDPR, however due to Orthogonal’s regulated status, while Orthogonal may remove data from publicly searchable parts of the Site (i.e. mark said data as “restricted data”), however, by using the Services, you expressly agree to allow Orthogonal to maintain all necessary data to meet its regulatory obligations, specifically to the U.S. Securities and Exchange Commission, Financial Industry Regulatory Authority and any other agency authorized by law to monitor and regulate Orthogonal.

EU Users should be aware that; (i) Orthogonal requires all third-party data processors Orthogonal uses to inform them of any instance they become aware of a data breach when it is likely to result in a risk to your rights and freedoms; (ii) Orthogonal makes appropriate inquiries into the data privacy protections and policies of all third-party providers Orthogonal engages; (iii) Orthogonal will not sell your data for marketing purposes and will not utilize your data for direct marketing; (iv) Orthogonal’s Site is designed for data privacy and security. Orthogonal is always working to improve its data privacy and protection mechanisms by monitoring existing policies, procedures and programs and assessing and developing new ones.

All requests associated with the above can be made by emailing investors@ei.ventures.

Changes of Control

In the event an Orthogonal entity merges with another entity, is sold, or transfers its assets, we may disclose or transfer information we collect from you in connection with the negotiation and/or conclusion of such transaction.

Changes to Our Privacy Policy

In our sole discretion, we reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. Therefore, you should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of our Site following the posting of any changes to this Privacy Policy means you consent to such changes.

Security and Storage of Your Information

We use commercially reasonable efforts to follow generally accepted standards to protect Personally Identifiable Information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as bank account information) on our Site, we, or a Third Party, encrypt the transmission of that information using secure socket layer technology (SSL). From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware, however, that no method of transmission over the Internet, or method of electronic storage, is free of risk. Therefore, we cannot guarantee that your information will not be accessed, disclosed, altered, or destroyed by a breach of our physical, technical, or managerial safeguards. We disclaim all responsibility and liability for unauthorized access to our servers and systems.

We will retain your information for as long as your account is active or is needed to provide you with the Services and may retain your data after you discontinue the use of the Services. In addition, we will retain and use your information as necessary to comply with our legal obligations, including to meet our regulatory obligations, resolve disputes, and enforce our agreements.

The Services are maintained in the United States of America. Although we welcome users from all over the world, by accessing the Services, you consent to and authorize the export of Personally Identifiable Information to the United States and its storage and use as specified in this Privacy Policy. Note that the laws of the United States might not be as comprehensive or protective as laws in the country where you live.

Opt out of certain cookies tracking: The Site uses tools to facilitate the collection of information. For example, the Site uses Google Analytics; if you wish to disable Google Analytics from all websites you visit (not limited to this Site), you can follow this link. Please contact us if you wish to opt out of any of the tools we use. Please note that we reserve the right to add more tools or disable tools and will update this Privacy Policy to reflect these changes. Your request to disable or disabling tools may limit your ability to access and utilize the Site.

This site is protected by reCAPTCHA, and the Google Privacy Policy and Terms of Service apply.

How to Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us at team@orthogonalthinker.com.  

Effective Date

This Privacy Policy was last updated on March 8, 2023.