Privacy Policy

Last updated: February 19, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application refers to Project Orca, the software program provided by the Company.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Project Orca.

• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Country refers to: Ohio, United States

• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual.

  We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.

• Service refers to the Application or the Website or both.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Website refers to Project Orca, accessible from orca614.com.

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Phone number
• Business name and contact information (for business accounts)
• Email address (for business account applications)

SMS and MMS Communication Data

When you interact with our Service via SMS or MMS (text messages), We collect and process the following information:

• Incoming Messages: All SMS and MMS messages you send to our Service are automatically logged with full metadata including:
  • Your phone number
  • Message content and keywords
  • Timestamp of message
  • Media attachments (images sent via MMS)
  • Twilio message SID and delivery status
  • Complete message payload for compliance and campaign tracking
• Outgoing Messages: All messages We send to you are logged with timestamps, delivery status, and Twilio's response data
• Image Processing: When you send images via MMS:
  • Images are uploaded to our cloud storage provider (Backblaze B2) located in the United States
  • Images are automatically analyzed for inappropriate content using Sightengine's AI service
  • NSFW-flagged images are stored temporarily but not immediately deleted (see retention policy below)
  • Image URLs and analysis results are stored in our database linked to your campaign
• Automated SMS Workflows: By sending a message containing a deal keyword to our Service, you consent to receive automated SMS communications related to that specific campaign, including:
  • Campaign instructions and progress updates
  • Coupon redemption links
  • Expiration warnings
  • Error notifications
• Opt-Out Rights: You can opt out at any time by replying "STOP" to any of our messages. Your phone number will be added to our permanent suppression list to ensure compliance with your request.

SMS Terms and TCPA Compliance

By participating in SMS-based campaigns with our Service, you acknowledge and agree to the following:

• Standard Rates: Standard messaging and data rates apply based on your mobile carrier's plan
• Message Frequency: Message frequency varies based on campaign activity. A typical campaign involves 3-7 messages total, sent over days or weeks depending on your participation
• Automated Messages: Messages are sent automatically in response to your actions (sending images, reaching milestones, etc.)
• Consent Scope: Your consent is limited to communications about the specific deal campaign you initiated by sending a keyword. We will never use your number for unrelated marketing
• Opt-Out Instructions: Reply "STOP" at any time to stop receiving messages. You will receive a confirmation message and your number will be suppressed
• Help: Reply "HELP" for customer support contact information
• Re-Enrollment: After opting out, you may reply "START" to re-enable messaging, but any in-progress campaigns will be terminated and progress lost

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

IP Address Usage: We collect and store your IP address for multiple purposes:

• Household Limits: To enforce deal redemption limits (e.g., maximum 3 secondary coupons per IP address per deal)
• Campaign Tracking: To count unique impressions when friends view your shared campaign link
• Fraud Prevention: To detect suspicious patterns and prevent abuse of the referral system
• Security Monitoring: To identify and block malicious activity

IP addresses used for enforcement (household limits, fraud detection) are stored in dedicated tracking tables linked to specific deals and are retained for the duration of the associated deal campaign plus 90 days after deal expiration, or until fraud investigation is resolved, whichever is longer.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Campaign Participation Data

When you participate in a deal campaign through our Service, We collect and store:

• Campaign Progress: Impression counts, click-through counts, campaign status, and completion dates
• Campaign Expiration: Each campaign has a limited time to complete requirements (set by the business when creating the deal). We will send you an expiration warning 3 days before your campaign expires. If your campaign expires, your progress is lost and cannot be recovered. All impression and campaign data are retained for analytics purposes even after expiration.
• One Campaign Rule: You may only have ONE active campaign at a time across all deals. You must complete or terminate your current campaign before starting a new one.
• Shared Links: When you share a campaign link with friends or family, we track all web requests (impressions) including IP addresses, timestamps, user agents, and referrer information

Secondary Deal Redemptions (Friend Referrals)

When someone shares a campaign link with you and you claim a secondary deal:

• If you enter your phone number to claim a secondary deal, we store your phone number
• We check if you've already claimed a coupon for this specific deal
• You can only receive one secondary coupon per deal (per phone number)
• We send you an automated SMS with your coupon redemption link
• Your phone number is linked to the campaign creator's account for attribution
• Your IP address is tracked to enforce household limits (typically 3 coupons per IP per deal)

Business Application Data

If you apply to join our Service as a business:

• Your application (business name, email, phone, referral code if used) is manually reviewed by our team
• We may verify your business through public sources (Google Business Profile, website, social media)
• Review notes are stored in our database and retained for 2 years
• If your application is rejected, we may delete your information after 90 days unless you request earlier deletion
• We generate printable deal cards (PDFs) containing your business information, stored for 90 days on our servers for re-download

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies We use include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

Where required by law, we use non-essential cookies (such as analytics, advertising, and remarketing cookies) only with Your consent. You can withdraw or change Your consent at any time using Our cookie preferences tool (if available) or through Your browser/device settings. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

  Type: Session Cookies

  Administered by: Us

  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of Our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You special offers, and general information about other goods, services and events which you have inquired unless you have opted not to continue receiving such information.

• To manage Your requests: To attend and manage Your requests to Us.

• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your Personal Data with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.
• With other users: If Our Service offers public areas, when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:

• Account Information

  • User Accounts: retained for the duration of your account relationship plus up to 24 months after account closure to handle any post-termination issues or resolve disputes.
  • Business Accounts: retained for the duration of your business relationship plus up to 24 months after account closure

• Usage Data

  • Website analytics data (cookies, IP addresses, device identifiers): retained for the duration of your account relationship plus up to 24 months after account closure to handle any post-termination issues or resolve disputes, which allows us to analyze trends while respecting privacy principles.

  • Application usage statistics: retained for the duration of your account relationship plus up to 24 months after account closure to handle any post-termination issues or resolve disputes, to understand feature adoption and service improvements.

  • Server logs (IP addresses, access times): retained for the duration of your account relationship plus up to 24 months after account closure to handle any post-termination issues or resolve disputes, for security monitoring and troubleshooting purposes.

• Campaign and Transaction Data (Exceptions to 24-month policy)

  • SMS/MMS Message Logs: Retained for duration of account relationship plus 24 months for compliance and dispute resolution
  • Campaign Images: Retained for 90 days after campaign completion, then deleted unless needed for fraud investigation, quality assurance, or if a legal requirement mandates retention.
  • NSFW Flagged Images: Retained for 90 days for pattern analysis, then permanently deleted
  • Credit Transaction Records (Ledger): Retained for a minimum of 7 years per tax law requirements. This is an append-only ledger that cannot be modified or deleted to maintain financial integrity.
  • Fraud Investigation Data: Retained indefinitely until investigation is resolved and for 2 years thereafter for legal compliance
  • IP Address Enforcement Records: Retained for duration of associated deal campaign plus 90 days after deal expiration
  • Anonymized Analytics Data: Campaign impressions and metrics are anonymized (personally identifiable information removed) and may be retained indefinitely for business analytics

• SMS Opt-Out Data

  • Suppression List: Phone numbers of users who replied "STOP" are retained indefinitely to ensure compliance with opt-out requests. Reply "START" to remove your number from the suppression list, or contact us to request manual removal.
  • Campaign Data After Opt-Out: Campaign data (impressions, images) is retained per standard retention policy even after opt-out, but your phone number is permanently suppressed from receiving new messages.

Usage Data is retained in accordance with the retention periods described above, and may be retained longer only where necessary for security, fraud prevention, or legal compliance.

We may retain Personal Data beyond the periods stated above for different reasons:

• Legal obligation: We are required by law to retain specific data (e.g., financial records for 7 years for tax authorities).
• Legal claims: Data is necessary to establish, exercise, or defend legal claims.
• Your explicit request: You ask Us to retain specific information.
• Technical limitations: Data exists in backup systems that are scheduled for routine deletion.
• Fraud prevention: Data is necessary for ongoing fraud investigations or prevention of future fraud.

You may request information about how long We will retain Your Personal Data by contacting Us at contact@orca614.com.

When retention periods expire, We securely delete or anonymize Personal Data according to the following procedures:

• Deletion: Personal Data is removed from Our systems and no longer actively processed.
• Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance.
• Anonymization: In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the ability to delete or anonymize or request that We assist in deleting or anonymizing the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may delete or anonymizeYour information at any time by sending an RCS or SMS message containing only the word "DELETE" to the phone number our service has used to send you SMS or RCS messages. Upon receipt of such a message, We will delete or anonymize the data associated with Your account. Please note that this action is irreversible and will permanently delete or anonymizeall of Your information from our systems, including any points, awards or credits you have earned.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Usage, Performance and Miscellaneous

We may use third-party Service Providers to maintain and improve our Service.

• Sightengine

  Purpose: NSFW content detection for images submitted via MMS

  Their Privacy Policy can be viewed at https://sightengine.com/policies/privacy

  NSFW Image Retention: If an image is flagged as NSFW, we store the image separately for review, notify you and request a different image. Flagged images are retained for 90 days for pattern analysis, then permanently deleted. You can request immediate deletion of flagged images by contacting contact@orca614.com

• Backblaze B2

  Purpose: Cloud storage for customer images submitted via MMS

  Their Privacy Policy can be viewed at https://www.backblaze.com/company/privacy.html

  Data Processing and Storage Locations: Customer images are stored on Backblaze B2 servers located in the United States. Your images may be transferred internationally as described in our "Transfer of Your Personal Data" section. Backblaze B2 complies with industry-standard security practices for cloud storage. We have executed Data Processing Agreements with Backblaze covering all data processing activities.

• Twilio

  Purpose: SMS and MMS messaging infrastructure

  Their Privacy Policy can be viewed at https://www.twilio.com/legal/privacy

  Twilio Webhook Data Processing: When you send an SMS or MMS to our Service, Twilio processes your message first and forwards it to our servers via webhook. Twilio's data retention policies apply to this transmission (see their Privacy Policy). We log the complete message payload for campaign tracking and compliance purposes.

• Stripe (Launching Soon)

  Purpose: Payment processing for business subscriptions and credit purchases

  Their Privacy Policy can be viewed at https://stripe.com/privacy

  Note: Stripe integration is planned for post-MVP. This disclosure is provided for transparency about future data processing activities.

Fraud Detection and Security

We detect and log security incidents to protect our Service and users:

• Suspicious Patterns: We monitor for referral circles (A → B → C → A), star patterns (one business referring many in short time), rate limit abuse, and unusual credit accumulation
• Fraud Attempts: All suspected fraud attempts are logged with full context including IP addresses, user IDs, business IDs, transaction amounts, and timestamps
• Kill Switch Functionality: If fraudulent activity is detected, we may immediately disable all referral codes system-wide until investigation is complete
• Retention: Security incident details are retained indefinitely until resolved and may be shared with law enforcement if illegal activity is suspected
• Thresholds: Accounts exceeding 10,000 credits per day or 5,000 credits total trigger automatic fraud investigation

Business Referral Program (Alpha Only)

During our alpha testing phase, businesses can refer other businesses:

• Referral Codes: We generate unique referral codes (format: ORCA-XXXXXXXX) linked to your business account using cryptographically secure random generation
• Referral Tracking: When another business applies using your code, we track the referral relationship, including referee business information, application date, and approval status
• Manual Review: All business applications are manually reviewed by our team. We verify business legitimacy through publicly available information (Google Business Profile, domain ownership, social media)
• Credit Rewards: Upon approval of a referred business, both businesses receive credit rewards. Credits are issued once atomically when the referee business is approved.
• Credit Expiration: Referral credits expire 90 days after our public launch date (August 15, 2026). We will send pre-expiration warnings 7 days before expiration.
• Data Retention: All referral data (codes, referee information, credit transactions) is stored in our database and retained per our standard retention policies
• Fraud Prevention: We enforce maximum referral limits (typically 3 per business), detect referral circles, and maintain kill switches for suspected fraud

Cashier and Business User Access

Cashier Authentication: Cashier users authenticate via QR code containing a unique identifier. QR codes provide ongoing access until revoked by business owner. Business owners can revoke cashier access at any time through admin panel. We log all validation attempts with timestamps and cashier IDs. If you suspect unauthorized coupon validation, contact us immediately at contact@orca614.com.

Session Management: You can log out of all devices at once from your account settings. This invalidates all active sessions immediately by incrementing your session version number.

Cashier Account Deletion: Business owners can delete cashier accounts at any time via admin panel. Validation logs are retained for accounting and fraud prevention purposes even after cashier deletion.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: contact@orca614.com