Privacy Policy
This Privacy Policy explains how we collect, use, and protect your personal data when you use Orpail (the "Service") at orpail.com.
Who we are
Orpail is operated by TurnR Ltd trading as Orpail, a company registered in England and Wales (company number 13855020), registered address 124 City Road, London EC1V 2NX, United Kingdom.
For the purposes of UK data protection law (the UK GDPR and the Data Protection Act 2018), TurnR Ltd trading as Orpail is the data controller for personal data processed through Orpail.
If you have any questions about this policy or your data, contact us at hello@orpail.com.
What data we collect
At this stage, Orpail collects a limited amount of personal data:
- Email address — when you sign up to our early-access / newsletter waitlist.
- Technical and security data — when you visit the Service, our infrastructure providers may automatically process limited technical information such as IP address, browser type, and request metadata. This is used to deliver the site securely and to protect against abuse and bots (for example, via Cloudflare and Cloudflare Turnstile). We do not use this data to build advertising profiles.
- Website analytics data — if you consent via our cookie banner, Google Analytics 4 collects aggregated information about how the site is used: pages viewed, approximate location (country / region), device and browser type, referrer, and time on site. We use this only to understand which pages are useful so we can improve them. If you do not consent, Google Analytics runs in cookieless mode (Google Consent Mode v2) and does not set cookies or share personal identifiers.
We do not run advertising trackers or build profiles of you. If that ever changes, we will update this policy and ask for your consent first.
How and why we use your data
| Purpose | Data used | Lawful basis |
|---|---|---|
| Sending you early-access updates and our newsletter | Email address | Consent (you opt in, and confirm via double opt-in) |
| Operating and securing the website | Technical/security data | Legitimate interests (keeping the Service available and free from abuse) |
| Understanding how the site is used so we can improve it | Aggregated analytics data (Google Analytics 4) | Consent (you choose via the cookie banner; you can reject without losing any functionality) |
We use double opt-in: after you submit your email, you receive a confirmation email and are only added to our list once you click to confirm. You can unsubscribe at any time using the link in any email we send you.
Who processes your data (sub-processors)
We use trusted third-party providers to run the Service. These act as our data processors and only process your data on our instructions:
- Kit (ConvertKit) — email list management and delivery (newsletter / waitlist).
- Vercel — hosting of the website.
- Cloudflare — content delivery, DNS, and security, including Turnstile bot protection.
- Hetzner — backend infrastructure.
- Google (Google Analytics 4) — aggregated website analytics, only when you consent via the cookie banner.
Some of these providers are based outside the UK/EEA (for example, in the United States). Where data is transferred internationally, it is protected by appropriate safeguards such as the providers' adequacy decisions or Standard Contractual Clauses.
How long we keep your data
We keep your email address for as long as you remain subscribed. If you unsubscribe or ask us to delete your data, we will remove it from our active list without undue delay (subject to any limited records we must keep for legal or accounting reasons).
Cookies
Orpail uses two categories of cookies and similar technologies.
Strictly necessary cookies are set by our infrastructure providers (Cloudflare and Cloudflare Turnstile) to deliver the site securely and protect against automated abuse. Under UK PECR, these do not require consent.
Analytics cookies are set by Google Analytics 4, which we use to understand how visitors find and use the site so we can improve it. These require your consent before they are set. When you first visit the site you see a cookie banner where you can accept or reject analytics; your choice is stored in your browser and respected on every page. If you reject, Google Analytics runs in cookieless mode under Google Consent Mode v2 and does not store anything on your device or share personal identifiers, so the analytics cookies (_ga, _ga_<id>) are never set.
We do not use advertising or tracking cookies and have no plans to. If that ever changes, we will update this policy and ask for your consent first.
Your rights
Under UK data protection law you have the right to:
- Access the personal data we hold about you
- Ask us to correct inaccurate data
- Ask us to delete your data ("right to erasure")
- Withdraw consent at any time (e.g. by unsubscribing)
- Object to or restrict certain processing
- Lodge a complaint with the UK regulator
To exercise any of these rights, email hello@orpail.com.
You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk if you believe we have mishandled your data, though we would appreciate the chance to address your concerns first.
Important note on the Service
Orpail provides informational and educational data about publicly available social media and news activity. It is not investment advice and is not a recommendation to buy, sell, or hold any security or digital asset. This Privacy Policy concerns only how we handle your personal data.
Changes to this policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above. Material changes will be communicated where appropriate.
Contact
TurnR Ltd trading as Orpail 124 City Road, London EC1V 2NX, United Kingdom Email: hello@orpail.com