Privacy Policy

This Privacy Policy describes how orbitledgeris AG ("we", "our", or "us") collects, uses, and protects your personal information when you use our banking services and visit our website. We are committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Last updated: January 2026

Data Controller Information

orbitledgeris AG is the data controller for the personal information we collect and process. Our contact details are:

Data Collection

We collect personal data that you provide to us directly and automatically when you use our services. The data we collect includes:

• Identity Information: Name, date of birth, nationality, identification documents
• Contact Information: Address, email address, telephone numbers
• Financial Information: Bank account details, transaction history, credit information
• Technical Information: IP address, browser type, device information, website usage data
• Communication Data: Records of correspondence and communications with us
• Marketing Preferences: Your preferences for receiving marketing communications

How We Use Your Information

We use your personal data for the following purposes, based on legitimate legal grounds under GDPR:

• Service Provision: To provide banking services, process transactions, and manage your accounts
• Legal Compliance: To comply with regulatory requirements, anti-money laundering laws, and other legal obligations
• Risk Management: To assess and manage credit risk, prevent fraud, and ensure security
• Customer Service: To respond to enquiries, provide support, and improve our services
• Marketing: To send you relevant information about our products and services (with your consent)
• Website Improvement: To analyse website usage and improve user experience

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please see our Cookie Policy.

Data Sharing and Disclosure

We may share your personal data with:

• Service Providers: Third-party companies that provide services on our behalf
• Regulatory Authorities: Government agencies and regulators as required by law
• Financial Institutions: Other banks and financial institutions for transaction processing
• Legal Authorities: Courts and law enforcement when legally required
• Professional Advisors: Lawyers, auditors, and other professional service providers

We do not sell your personal data to third parties for marketing purposes.

Data Retention

We retain your personal data for as long as necessary to fulfil the purposes outlined in this policy and to comply with legal obligations. Generally, we retain customer data for up to 10 years after the end of our business relationship, or as required by applicable banking regulations. Marketing data is retained until you withdraw consent or for a maximum of 3 years.

Your Rights

Under GDPR, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate personal data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of processing in certain circumstances
• Right to Data Portability: Request transfer of your data to another organisation
• Right to Object: Object to processing of your personal data in certain circumstances
• Right to Withdraw Consent: Withdraw consent for processing based on consent

Data Security

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, secure data transmission, and regular security assessments. However, no method of transmission over the internet or electronic storage is completely secure.

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as adequacy decisions by the European Commission or appropriate contractual clauses.

Contact Information

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

Complaints

If you believe we have not handled your personal data in accordance with this policy or applicable data protection laws, you have the right to lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde) or your local supervisory authority.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

Governing Law

This Privacy Policy is governed by Austrian law and EU regulations, including the General Data Protection Regulation (GDPR). Any disputes arising from this policy will be subject to the exclusive jurisdiction of Austrian courts.