This Privacy Policy describes how Orion Lending ("Orion," "we," "us") collects, uses, and protects information in connection with the Orion Marketing application (the "App"). The App is an internal-use tool provided to Orion Lending employees and affiliated independent advisors to manage corporate-approved marketing content, compliance review, and publishing to connected social media accounts.
1. Scope of this Policy
This Policy applies only to data processed by the Orion Marketing App. Orion Lending's general consumer privacy notice, which governs data collected through orionlending.com and our lending products, is published separately and is not superseded by this document.
2. Information We Collect
Account information
- Name, work email address, role, and profile photo of the authorized user.
- Authentication identifiers issued by our identity provider.
Information from connected social media accounts
When a user connects a Facebook Page or Instagram Business account, Orion accesses:
- Page or account name, ID, profile picture, and category.
- The list of Pages a user manages (Facebook only).
- Permission tokens required to publish posts and read post engagement metrics.
- Posts, captions, comments, and basic insights for content the user has scheduled or published through the App.
We never access personal Facebook profiles, friend lists, private messages, or any data unrelated to the user's Business Page or Instagram Business account.
Content you submit
- Marketing copy, captions, images, and videos you upload or generate within the App.
- Compliance review notes, approvals, and rejection reasons.
- Recording session bookings and related scheduling information.
Usage data
- Log records of actions taken in the App (post submitted, approved, scheduled, published).
- Device, browser, and IP address for security and audit purposes.
3. How We Use Information
- To authenticate users and authorize access to internal features.
- To publish approved content to the user's connected Facebook Page or Instagram Business account on their behalf.
- To enable Compliance to review, approve, or reject content prior to publication.
- To display engagement metrics and post status back to the originating user.
- To maintain audit trails required by federal and state financial-services regulations.
- To diagnose errors, prevent abuse, and secure the App.
4. How We Share Information
We do not sell user data. We share data only as follows:
- Meta Platforms, Inc. — to publish content and retrieve engagement metrics from Facebook Pages and Instagram Business accounts you connect.
- Service providers — cloud hosting (Supabase / Lovable Cloud), email delivery (Resend), and video processing vendors, all under contractual confidentiality.
- Orion Lending Compliance and Marketing teams — internally, for content review and brand governance.
- Legal or regulatory authorities — when required by law, subpoena, or regulatory examination.
5. Data Retention
- Social-account access tokens are stored encrypted and refreshed automatically; tokens are deleted within 7 days of an account being disconnected by the user.
- Published-post records, compliance approvals, and audit logs are retained for the duration required by applicable financial-services recordkeeping rules (typically 5 years).
- Uploaded media is retained until the user deletes it from the Content Library or their account is deactivated.
6. Security
We use industry-standard encryption in transit (TLS) and at rest, role-based access control, audit logging, and regular security reviews. No system is perfectly secure; users should report suspected incidents to tcorbett@orionlending.com.
7. Your Rights
Authorized users of the App may, at any time:
- Disconnect any social account from the Connected Accounts page.
- Request deletion of their account and associated data — see our Data Deletion Instructions.
- Request a copy of the data we hold about them.
8. Children
The App is not directed to anyone under 18 and is restricted to authorized Orion Lending personnel.
9. Changes to this Policy
We may update this Policy from time to time. Material changes will be communicated through the App. Continued use after the effective date constitutes acceptance.
10. Contact
Questions about this Policy: marketing@orionlending.com
Orion Lending · 3070 Bristol St., Suite 200, Costa Mesa, CA 92626