Privacy Policy

Orion Ventures, LLCEffective Date: August 5, 2026Last Updated: August 5, 2026

1. Introduction

Orion Ventures, LLC ("Orion Ventures," "we," "us," or "our") operates the website located at https://orion-ventures.com (the "Site"). We provide defense technology assessment, engineering analysis, test data evaluation, and full life cycle cost analysis services to government and commercial clients.

This Privacy Policy explains what information we collect through the Site, how we use and protect it, and the choices available to you. It applies to the Site only. It does not apply to information governed by a separate non-disclosure agreement, consulting agreement, government contract, or subcontract between you and Orion Ventures, which will control over this Policy with respect to information exchanged under it.

Please read Section 9 (Export Control and Confidential Information) before submitting any information to us. The Site is not an approved channel for controlled technical data or classified information.

By using the Site, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are

Orion Ventures, LLC is a limited liability company with offices in the Commonwealth of Virginia, United States, and in Kyiv, Ukraine.

CAGE Code: 7FQG4
Unique Entity Identifier (UEI): N896J49MC616

We are the controller responsible for personal data collected through the Site. For privacy inquiries, contact us using the details in Section 15.

3. Information We Collect

3.1 Information You Provide Directly

We collect information you choose to submit to us, which may include:

Identity and contact details — name, job title, organization or agency, business email address, business telephone number, and country or region.
Correspondence content — the substance of messages you send through any contact form on the Site or by email, including any attachments.
Business context — information about your program, requirement, procurement timeline, or area of interest that you elect to share.

You are not required to provide any of this information to browse the Site. You provide it only if you choose to contact us.

3.2 Information Collected Automatically

The Site is a single-page informational website with a contact form. When you visit it, our hosting infrastructure automatically records the following in ordinary server logs:

Internet Protocol (IP) address and approximate geographic location derived from it
Browser type, version, and language settings
Operating system and device type
Referring URL and pages viewed on the Site
Date, time, and duration of your visit
Server log data, including HTTP request and error records

3.3 Cookies and Similar Technologies

The Site uses only strictly necessary cookies — those required for the Site to load correctly, for the contact form to function, and for spam and abuse protection on that form. These cannot be disabled through the Site because the Site cannot operate without them.

We do not use:

Analytics or performance cookies
Advertising, retargeting, or conversion-tracking cookies
Social media trackers or embedded third-party widgets that set cookies
Any cross-site or cross-context behavioral tracking technology

Because we set no non-essential cookies, there is no cookie consent banner on the Site and no tracking for you to opt out of.

We do review aggregate server log data (Section 3.2) to understand overall traffic volume, diagnose errors, and detect abuse. This is server-side, involves no cookies, and does not follow you across other websites.

You can control cookies through your browser settings, including blocking or deleting them. Blocking strictly necessary cookies may prevent the contact form from working.

If we introduce analytics or any other non-essential technology in the future, we will update this Policy and, where the law requires it, obtain your consent before doing so.

3.4 Information We Do Not Knowingly Collect

We do not seek, and ask that you do not submit through the Site:

Government-issued identification numbers, including Social Security numbers
Financial account or payment card information
Security clearance details, investigation records, or personnel security data
Health information
Biometric data
Precise geolocation data
Classified information or Controlled Unclassified Information (CUI)
Export-controlled technical data (see Section 9)

4. How We Use Information

We use the information described above for the following purposes:

Purpose	Information Used
Responding to your inquiry and corresponding with you	Identity and contact details, correspondence content
Evaluating a potential engagement, teaming arrangement, or subcontract	Identity and contact details, business context
Establishing a non-disclosure agreement before substantive discussion	Identity and contact details
Operating, securing, and maintaining the Site	Automatically collected data, server logs
Detecting and preventing fraud, abuse, intrusion, and unauthorized access	Automatically collected data, server logs
Understanding aggregate traffic volume and improving Site content	Server log data
Complying with legal, regulatory, contractual, and export control obligations	Any of the above, as required
Screening against restricted-party and sanctions lists where required by law	Identity and organization details

We do not use information submitted through the Site to train machine learning models, and we do not use it for automated decision-making that produces legal effects concerning you.

5. Legal Bases for Processing

Where the EU or UK General Data Protection Regulation applies to our processing, we rely on the following legal bases:

Legitimate interests (Art. 6(1)(f)) — responding to business inquiries, operating and securing the Site, and pursuing business development in a proportionate manner.
Performance of a contract, or steps prior to entering one (Art. 6(1)(b)) — where your inquiry concerns a prospective or existing engagement.
Consent (Art. 6(1)(a)) — for non-essential cookies and analytics where consent is required. You may withdraw consent at any time.
Compliance with a legal obligation (Art. 6(1)(c)) — including export control, sanctions screening, and records retention requirements.

Where the Law of Ukraine "On Personal Data Protection" (No. 2297-VI) applies, we process personal data on the basis of consent, performance of a contract, or another ground permitted under that law.

6. Disclosure of Information

We do not sell personal information, and we do not share it for cross-context behavioral advertising or targeted advertising.

We disclose information only as follows.

6.1 Service Providers

We use third-party providers to operate the Site and our business, including web hosting, email and productivity services, domain and DNS services, and spam filtering. These providers process information on our instructions under contractual confidentiality and security obligations, and are not permitted to use it for their own purposes.

6.2 Within Orion Ventures

Information may be accessed by our personnel and authorized contractors in Virginia and in Kyiv, Ukraine, on a need-to-know basis for the purposes described in Section 4.

6.3 Teaming and Business Partners

Where you have contacted us regarding a specific opportunity, we may share limited contact and business context information with a prospective teaming partner, prime contractor, or subcontractor, subject to a non-disclosure agreement. We do so only where reasonably necessary to respond to your inquiry.

6.4 Legal and Regulatory Disclosure

We may disclose information where we believe in good faith that disclosure is required or permitted by law, including:

In response to a subpoena, court order, warrant, or other lawful request from a government authority, regulator, law enforcement agency, or national security authority of the United States, Ukraine, or another competent jurisdiction
To comply with export control, sanctions, anti-corruption, or government contracting obligations
To establish, exercise, or defend legal claims
To protect the rights, property, safety, or security of Orion Ventures, our clients, our personnel, or the public

6.5 Corporate Transactions

If Orion Ventures is involved in a merger, acquisition, reorganization, financing, or sale of assets, information may be transferred as part of that transaction, subject to the receiving party honoring commitments materially consistent with this Policy.

7. International Transfers of Information

Orion Ventures operates in both the United States and Ukraine. Information you provide may be transferred to, stored in, and processed in either country, and in other countries where our service providers operate.

These countries may not provide the same level of data protection as your country of residence. Where we transfer personal data out of the European Economic Area, the United Kingdom, or Switzerland, we implement an appropriate transfer mechanism, such as the European Commission's Standard Contractual Clauses, together with supplementary technical and organizational measures where warranted.

Transfers between our Virginia and Kyiv operations are subject to internal confidentiality, access control, and security requirements, and are further constrained by applicable export control law (see Section 9).

You may request further information about our transfer safeguards using the contact details in Section 15.

8. Data Retention

We retain information only as long as necessary for the purposes for which it was collected, and thereafter as required by law or contract.

Category	Retention Approach
Inquiries that do not lead to an engagement	Retained for a reasonable business development period, then deleted, unless a legal hold or contractual requirement applies
Inquiries and correspondence relating to an engagement	Retained for the duration of the engagement and afterwards in accordance with applicable government contracting, export control, and records retention requirements
Server logs and security records	Retained for a limited period appropriate to security monitoring and incident investigation
Contact form submissions	Retained in our email and records systems on the same basis as the corresponding inquiry above

Records subject to government contract, export control, or litigation hold requirements may be retained for longer periods where the law requires it.

9. Export Control and Confidential Information

This Section is important. Please read it before sending us anything.

Orion Ventures performs export-controlled work in compliance with all applicable United States and international export control regulations, including the International Traffic in Arms Regulations (ITAR, 22 C.F.R. Parts 120-130), the Export Administration Regulations (EAR, 15 C.F.R. Parts 730-774), and applicable sanctions programs administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC).

Accordingly:

Do not submit export-controlled technical data through the Site's contact form or by unencrypted email. This includes technical data as defined in the ITAR and technology or software subject to the EAR. Public website forms and ordinary email are not authorized channels for such data.
Do not submit classified information or Controlled Unclassified Information (CUI) through the Site. Contact us first so that an appropriate channel can be established.
We work under NDA from first contact. If your inquiry involves proprietary, sensitive, or competition-sensitive information, contact us with only the minimum information needed to initiate discussion. We will put a non-disclosure agreement in place before substantive exchange. Information you send before an NDA is executed is not subject to NDA protection, although we will treat it with reasonable care and use it only to respond to your inquiry.
Unsolicited submissions are not received in confidence. Unsolicited ideas, proposals, designs, specifications, or technical concepts submitted through the Site create no obligation of confidentiality, compensation, or non-use on our part beyond the commitments stated in this Policy.
Screening. Where required by law, we screen inquiries and prospective counterparties against U.S. and allied restricted-party, denied-party, and sanctions lists. We may decline to respond to or engage with a party where doing so would be inconsistent with applicable law, and we may retain a record of that determination.
Access controls. Where an engagement involves export-controlled information, access is restricted to authorized personnel in accordance with our export compliance procedures, including nationality-based access restrictions where the regulations require them.

10. Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, alteration, disclosure, and destruction. These include encryption of Site traffic in transit (TLS), access controls on a need-to-know basis, authentication requirements for internal systems, logging and monitoring, and personnel confidentiality obligations.

No method of transmission or storage is completely secure. We cannot guarantee absolute security, and you transmit information to us at your own risk. Do not use the Site to transmit information that requires protection beyond what an ordinary commercial website and email system can provide.

If we become aware of a personal data breach affecting your information, we will notify you and the relevant supervisory authorities where required by applicable law and within the timeframes it prescribes.

11. Your Rights and Choices

Depending on where you reside, you may have some or all of the following rights regarding your personal information:

Access — to obtain confirmation of whether we process your personal information and a copy of it
Correction — to have inaccurate or incomplete information corrected
Deletion — to request erasure of your information, subject to legal and contractual retention requirements
Portability — to receive your information in a structured, commonly used, machine-readable format
Objection and restriction — to object to or request restriction of processing based on legitimate interests
Withdrawal of consent — to withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing
Opt out of sale, targeted advertising, and profiling — we do not engage in these activities, but you retain this right
Non-discrimination — we will not deny services, charge different prices, or provide a different quality of service because you exercised a privacy right
Appeal — where required, including under the Virginia Consumer Data Protection Act (Va. Code Section 59.1-575 et seq.), to appeal a refusal of your request

How to exercise your rights. Submit a request using the contact details in Section 15. We will respond within the period required by applicable law. We may need to verify your identity before acting, and may request additional information for that purpose. Where a request cannot be honored in full — for example, because records are subject to a government contract, export control, or legal retention requirement — we will tell you why.

Authorized agents. You may use an authorized agent to submit a request on your behalf where applicable law permits. We may require proof of the agent's authority.

Complaints. If you are in the European Economic Area or the United Kingdom, you may lodge a complaint with your local data protection supervisory authority. If you are in Ukraine, you may contact the Ukrainian Parliament Commissioner for Human Rights. We ask that you contact us first so that we can try to resolve the matter directly.

12. Do Not Track and Global Privacy Control

Some browsers transmit "Do Not Track" signals. There is no common industry standard for interpreting them, and the Site does not currently respond to them. Because we do not engage in targeted advertising or the sale of personal information, there is no such activity for these signals to disable.

13. Children's Privacy

The Site is directed to business, government, and professional audiences. It is not intended for and is not directed to children. We do not knowingly collect personal information from individuals under 16 years of age, or under 13 years of age within the meaning of the U.S. Children's Online Privacy Protection Act. If you believe a child has provided us with personal information, contact us and we will delete it.

14. Third-Party Links

The Site may contain links to third-party websites, including government procurement portals, partner sites, and reference sources. We do not control those sites and are not responsible for their privacy practices or content. Review the privacy policy of any third-party site you visit.

15. Contact Us

For questions about this Privacy Policy, to exercise a privacy right, or to request information about our data practices:

Orion Ventures, LLCAttn: Privacy InquiriesCommonwealth of Virginia, United Statesinfo@orion-ventures.com

Please do not include export-controlled, classified, or confidential information in your correspondence. See Section 9.

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. When we do, we will revise the "Last Updated" date above. If we make a material change, we will provide additional notice through a prominent statement on the Site.

Your continued use of the Site after a revised Policy takes effect constitutes your acknowledgment of the updated Policy.