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.

POLARIS SHARED LEARNING (NEBULA DESKTOP APP)

Nebula includes a shared learning network called Polaris. When it is on, the app contributes the anonymised maths behind your backtests to a community pool, and in return your local Polaris model learns from the whole community’s tests. What is shared:

— the strategy’s structure and settings, encoded as numbers (a fingerprint and numeric features — not your strategy files)
— the backtest’s outcome scores and statistics
— the market and timeframe tested, and when the test ran
— a random contributor tag generated on your device

Shared learning is on by default. The first time this applies to you, the app shows a notice where you can turn it off with one click; the durable control is in Settings → Collection → “Shared network — contribute & learn (Polaris)”. Turning it off stops all contributions immediately, and a choice to stay off is never overridden — not by updates, not by reinstalls on the same machine.

What is never shared: your name, email address or licence key; your machine id, IP-derived identity or anything computed from them; account, broker or balance details; and your live / real-money trading results. The pool’s data format has no field to hold these, and both the app and the server strip anything outside the permitted whitelist before storage.

The contributor tag is random — it is not made from your name, email, licence or machine, and no list linking tags to people exists anywhere, on your machine or on our servers. It exists so the network can show contribution totals and honour deletion requests. Because it is random and unmapped, nobody — including us — can trace a contribution back to you.

Pool data is used only to train the strategy-evaluation model that runs on each member’s own machine. It is never used to identify, profile or market to you, and we do not sell it. The pool is a rotating library of strategy maths hosted on Cloudflare (our hosting provider, acting as a processor); it has no accounts and no personal records, and older contributions rotate out automatically as the pool reaches its size limit.

Deletion: open the Polaris tab → shared network in the app — the node marked “you” shows your tag. Send that tag to hello@orionrfx.com (or the live chat) and we will delete everything stored under it. We cannot find your contributions without it — by design, nothing else in the pool points back to you.

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.