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ORBITALY  ·  PRIVACY

Privacy Policy.

What Orbitaly collects when you join the waitlist, sign in, book a trip, or talk to Momo, and what we do with it.

LAST UPDATED 2026-08-28  ·  APPLIES TO THE ORBITALY WEBSITE AND THE ORBITALY iOS APP

DRAFT This policy is a working draft, written from the product's actual data flows. It has not been reviewed by counsel. Do not treat it as final or publish it to a live app without that review.

1. Who this policy covers, and who runs Orbitaly

This policy covers the Orbitaly marketing website (where you can join the waitlist or write to us) and the Orbitaly iOS app (where you book and track trips, and talk to Momo). Orbitaly is operated by [PLACEHOLDER: legal entity name, once formed], [PLACEHOLDER: registered address for legal notices]. For the purposes of GDPR and similar laws, that entity is the data controller.

If you are in the European Economic Area, the United Kingdom, or Switzerland and Orbitaly has no local establishment, [PLACEHOLDER: confirm whether an EU/UK Article 27 representative is required and name one, or state that none is needed].

2. What we collect

On the website

  • Waitlist: the email address you submit, and (if you arrived through a referral link) which referral code brought you and how many people you have referred. Nothing else is collected on this form.
  • Contact form: the name, email address, and message you submit, so we can reply.

In the app

  • Account: your email address, used only to send a magic-link sign-in code through Supabase Auth. Orbitaly never asks for or stores a password.
  • Booking: when you book a flight, the passenger details a fare requires (typically full name, date of birth, and gender as recorded with the airline; some international fares also require passport or government ID details, collected only when the specific booking requires it) are sent to Duffel, our booking provider, to create the order. Payment card details are entered directly into Duffel's hosted payment component and never reach Orbitaly's own servers or database.
  • Trips you add or import: flight numbers, dates, and confirmation details you enter or import, so Orbitaly can track and display them.
  • Momo conversations: the messages you send Momo and the replies it gives, so it can hold context within a conversation and so we can investigate reported problems. See section 5.
  • Usage analytics: product-interaction events (for example, opening the app, adding a flight, viewing a boarding pass) tied to your account's internal user ID, never to your name or email. Collected through PostHog. See section 4.
  • Device and diagnostic data: standard crash and performance information collected by Apple's own tools (Xcode Organizer crash reporting). Orbitaly does not run a third-party crash SDK.

Orbitaly does not run advertising SDKs, does not collect an advertising identifier (IDFA), and does not track you across other companies' apps or websites. Because there is no tracking as Apple defines it, the App Tracking Transparency prompt does not appear.

3. How we use it

  • To create and secure your account, and to send the magic-link sign-in email.
  • To search fares, create and manage bookings, and service a trip (changes, cancellations, refunds where the fare allows).
  • To track a flight and keep its dossier, boarding pass, and place on the globe current.
  • To let Momo answer questions about your trips and, for trips booked through Orbitaly, to act on them.
  • To notify you about the waitlist, a booked trip, or a message you sent us.
  • To understand how the app is used in aggregate, so we can fix what is broken and build what is missing.
  • To meet legal, tax, and airline-reporting obligations tied to a booking.

We do not sell personal information, and we do not use your data to train third-party advertising models.

4. Who we share it with

Orbitaly shares data only with the providers that make the product work, each bound to use it for that purpose only.

SUPABASE
Database, authentication, and backend hosting for the app. Holds your account, trips, and booking records. [PLACEHOLDER: confirm the hosting region for the Supabase project, for data-residency disclosure].
DUFFEL
Booking provider. Receives passenger and payment details needed to search, price, and issue a fare, and to service it afterward.
ANTHROPIC
Powers Momo's language understanding. Receives the text of your conversation with Momo and the trip context needed to answer it.
POSTHOG
Product analytics, hosted in the EU. Receives usage events tied to an internal user ID, never your name or email.
APPLE
Handles App Store distribution, in-app purchases and subscriptions, and (if you opt in) push notifications. Apple's own privacy policy governs what it collects as the platform.

We may also disclose information where required by law, to enforce our terms, or to protect the rights, property, or safety of Orbitaly, our users, or the public. If Orbitaly is ever acquired or merges with another company, your information may transfer as part of that transaction, under the same protections described here.

5. Momo and AI processing

Momo is built on third-party language models (currently Anthropic's Claude, with a fallback provider for reliability). When you message Momo, that message, along with the trip context needed to answer it, is sent to the model provider to generate a response. Model providers process this data to return an answer; per their standard commercial terms, this data is not used to train their general-purpose models. Do not send Momo anything you would not want processed by an outside AI system, such as full payment card numbers or a government ID number typed directly into chat.

Momo can only take action on a trip Orbitaly actually holds the booking for. That check happens against your account record in our database, never as a judgment call by the AI itself.

6. How long we keep it

  • Waitlist emails: until you ask us to delete them, or until [PLACEHOLDER: confirm a maximum retention period, e.g. 24 months from signup], whichever comes first.
  • Contact messages: [PLACEHOLDER: confirm retention period, e.g. 12 months after resolution].
  • Account and booking records: for as long as your account is active, plus a retention period after closure to meet airline, tax, and consumer-protection recordkeeping requirements. [PLACEHOLDER: confirm the specific post-closure retention period with counsel].
  • Momo conversations: [PLACEHOLDER: confirm retention period for chat logs].
  • Payment card numbers: never. Duffel's hosted payment component keeps card data off Orbitaly's servers entirely.

7. Your rights and choices

Depending on where you live, you may have the right to access, correct, delete, or export your personal information, and to object to or restrict certain processing. California residents have equivalent rights under the CCPA/CPRA, including the right to know what is collected and to request deletion; Orbitaly does not sell personal information, so there is no sale to opt out of.

To exercise any of these rights, write to [email protected]. We will verify your identity before acting on the request and respond within the time your local law requires. You can delete your account and its data directly from the app's settings [PLACEHOLDER: confirm this control exists in-app before launch, or remove this sentence], or by asking us to do it for you.

8. Children

Orbitaly is not directed to children and is not intended for use by anyone under 16. We do not knowingly collect personal information from a child under that age. If you believe a child has created an account or been added as a passenger without appropriate parental involvement, write to [email protected] and we will investigate and remove the data as required. [PLACEHOLDER: confirm the exact age threshold and any COPPA-specific handling with counsel; some jurisdictions use 13].

9. Security

Account data and booking records are stored in Supabase, protected by row-level security policies that restrict every table to the account that owns it, plus encryption in transit (TLS) and at rest as provided by our infrastructure. Payment data is never handled by our own servers. No system is perfectly secure; if you believe your account has been compromised, contact us immediately at [email protected].

10. International transfers

Orbitaly's providers may process data in countries other than the one you live in, including the United States. Where that involves transferring personal data out of the EEA, UK, or Switzerland, we rely on the safeguards those providers make available (such as Standard Contractual Clauses). [PLACEHOLDER: confirm each subprocessor's specific transfer mechanism before this policy ships].

11. Changes to this policy

If we make a material change to how we collect or use your data, we will update the date at the top of this page and, where required, notify you directly (by email or an in-app notice) before the change takes effect.

12. Contact

Questions about this policy, or a request about your data: [email protected]. General inquiries: [email protected]. Postal address for privacy notices: [PLACEHOLDER: registered postal address]. Data protection contact / DPO, if one is required: [PLACEHOLDER: name a DPO or confirm none is required].