Privacy policy

REFUND PROCESSING

Approved refunds are returned to the original payment method within 5–10 business days. Where the original payment method is unavailable (closed account, expired card), we will arrange an alternative refund route via bank transfer on receipt of valid banking details.

"ACTIVATION" DEFINITION FOR DIGITAL GOODS

For the purposes of the 14-day cooling-off exemption under the UK Consumer Contracts Regulations 2013, "activation" of a digital product means any of: (a) installing the Pine Script on your TradingView account, (b) downloading the Nebula installer, (c) attending the first mentorship session, or (d) accessing gated educational PDFs. By proceeding with any of these actions during the 14-day cooling-off window, you expressly consent to commencement of the digital service and waive your right to a refund under the cooling-off period.

SUBSCRIPTION CANCELLATIONS

You may cancel any monthly subscription (Money In/Money Out, Order Flow, COT Display, Protocol 7) at any time through your customer dashboard. Cancellation stops future billing immediately. You retain access until the end of the current billing period. We do not offer pro-rated refunds for mid-period cancellation.

LAWFUL BASIS FOR PROCESSING (UK GDPR Article 6)

We process your data under the following lawful bases:

— Contract performance: to fulfil orders, provide product access, and deliver mentorship sessions you purchase.
— Legitimate interest: to detect fraud, prevent abuse, improve our products, and send service-related communications (e.g. product updates, security notices).
— Consent: for marketing emails, optional analytics cookies, and any data processing not strictly necessary for the contract.
— Legal obligation: to retain accounting records for HMRC (6 years), respond to lawful requests from authorities, and meet AML/KYC obligations if applicable.

DATA RETENTION SCHEDULE

— Order and transactional data: 6 years (UK HMRC requirement)
— Customer account data: retained while account is active, deleted within 30 days of account closure unless legal hold applies
— Marketing data: deleted on unsubscribe or after 24 months of inactivity, whichever is sooner
— Support correspondence: 2 years from last interaction
— Server logs and security data: 90 days

COOKIES & TRACKING

We use the following cookie categories:
— Strictly necessary (no consent required): cart, session, authentication
— Analytics: Shopify Analytics, optional consent
— Marketing: Meta Pixel, TikTok Pixel, Google Ads — consent required, opt-in via the cookie banner
You can manage your preferences at any time via the cookie banner footer link or by clearing cookies in your browser.

DATA PROTECTION CONTACT

Data protection enquiries: hello@orionrfx.com
Postal: 58 Barnes Way, Herne Bay, Kent, CT6 6RX, United Kingdom
You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.