Privacy Policy

Last Revision Date: 06/12/26

  • INTRODUCTION

  • WHO IS COLLECTING DATA

  • DATA WE COLLECT

  • PROCESSING OF PERSONAL DATA

  • HOW DATA IS PROCESSED

  • STORAGE OF PERSONAL DATA

  • DISCLOSURE/SHARING OF PERSONAL DATA

  • CROSS-BORDER TRANSFERS

  • YOUR RIGHTS

  • AUTOMATED DECISION MAKING

  • PROVIDING INFORMATION TO VAN ORTON

  • THIRD PARTY WEBSITES OR SERVICES

  • CONTACT US

Introduction

Van Orton Recovery, LLC ("Van Orton," "we," or "us") is committed to complying with the applicable data privacy and security requirements in the jurisdictions in which it operates. Van Orton complies with internationally recognized standards of privacy protection, and with applicable privacy laws including, but not limited to, the EU General Data Protection Regulation (GDPR). This Privacy Notice applies when Van Orton provides case assessments, asset tracing, fraud investigation, recovery coordination, and related intelligence services (the "services") to its clients, and to visitors of our website at vanortonrecovery.com (the "Site").

This Privacy Notice is incorporated by reference into our Terms of Use.

Who is Collecting Data?

Data will be collected by Van Orton Recovery, LLC. This policy applies to personal data which is collected and/or used by Van Orton in its capacity as a data controller, as that term is defined in the GDPR and similar privacy laws, for the purposes set out below under Processing of Personal Data.

In the course of providing the services, Van Orton also processes personal data relating to individuals other than its clients — for example, individuals connected to a matter under investigation — obtained from public and third-party sources. Van Orton processes such data as described in this Notice, in connection with the investigation of suspected fraud, the establishment, exercise, or defense of legal claims, and the reporting of suspected criminal activity to competent authorities.

Data We Collect

Van Orton collects the following categories of personal data:

Contact data: We may collect information such as name and email address in order to communicate with clients and potential clients and to facilitate the provision of our services. All communications with Van Orton take place through email.

Case and services data: Personal data may be provided to us by clients to the extent required to perform the services. This may include descriptions of the suspected fraud, communications with suspected perpetrators, transaction records, account and wallet identifiers, loss documentation, supporting evidence, and identity verification documents where required. Van Orton may also acquire personal data from third parties as required to perform the services.

Investigative data: In the course of investigations, we collect information from sources other than the data subject, including public records, open-source intelligence, public blockchain ledgers, court filings, exchanges, financial institutions, and law enforcement. This may include personal data about individuals connected to a matter under investigation.

Billing data: Information necessary to administer engagements, invoicing, and installment payment plans. Payment card processing is handled by our payment service providers; Van Orton does not store full payment card numbers.

Marketing information: We may collect information to respond to inquiries regarding our services or to provide you with information or updates by email.

Website visitor information: When you visit the Site, we may collect information about your visit such as your IP address, device and browser type, the pages you visited, and the source of your visit (for example, that your visit originated from one of our advertisements), through cookies and similar technologies used for functionality, analytics, and advertising measurement. You can control cookies through your browser settings; disabling them may affect Site functionality.

Clients and other third parties who provide personal information to Van Orton must do so in compliance with applicable data privacy regulations.

Processing of Personal Data

We collect personal data to offer and administer our services. The data you provide to us will be processed in accordance with the purposes specified in this notice, namely:

  • For complying with obligations provided by laws, current regulations and legislation (e.g., tax regulations, anti-money laundering and sanctions regulations)

  • Where the processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract (e.g., where you request a free case assessment or engage the services under a signed case agreement)

  • Where the processing is necessary for our legitimate business interests in conducting and managing our business, including:

    • To perform the services requested by clients pursuant to a signed case agreement, including asset tracing, investigation, documentation, and the preparation of case reports and filings

    • To submit investigative findings to relevant law enforcement agencies and to coordinate recovery efforts with exchanges, custodians, financial institutions, and — for civil recovery matters — courts and locally qualified legal professionals

    • To investigate suspected fraud and to support the establishment, exercise, or defense of legal claims, including the processing of investigative data relating to individuals connected to a matter

    • To communicate with you about your matter by email, including monthly status reports

    • For improving Van Orton's communications with you. Emails sent to you by Van Orton may include standard tracking, including open and click activities

    • For operating, improving, and securing the Site, including measuring the performance of our advertising

    • For security purposes, including protecting Van Orton and its clients against security breaches, impersonation, and fraud

  • For marketing purposes. For example, we may use your information to further discuss your interest in the services and to send you information regarding Van Orton by email.

    • If you are located in the EU or UK, we will only send you marketing communications with your prior consent or based on our and your legitimate interests where permitted. In either case, you can withdraw your consent or opt out of receiving such communications at any time.

    • If you are located elsewhere, you may opt out of receiving marketing communications at any time.

    • You can manage your receipt of marketing communications by clicking on the "unsubscribe" link located at the bottom of Van Orton's marketing emails. Additionally, you may send a request to hello@vanortonrecovery.com.

  • With your consent. Van Orton also processes your data for other purposes if you have provided us consent for such specified purposes, where such other purposes will be clearly provided at the time you provide consent.

Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests — we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to this processing if you wish.

How Data is Processed

Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and in compliance with current regulations. We permit only authorized Van Orton personnel and third-party processors to have access to your information. Such personnel and third-party processors are appropriately designated and instructed to process data only according to the instructions we provide them, with safeguards proportionate to the sensitivity of the data we handle.

Storage of Personal Data

Van Orton will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for the period necessary to comply with applicable legal, tax, and regulatory requirements, and where recovery, asset distribution, forfeiture, or related legal proceedings remain ongoing. When information is no longer needed, we delete or de-identify it.

Disclosure/Sharing of Personal Data

We only share your personal data with your consent or in accordance with this policy. We do not sell personal data, and we will not otherwise share or distribute any of the information you provide to us except as described in this Privacy Notice.

  • A core component of our methodology is the submission of investigative intelligence to relevant law enforcement agencies, and cooperation with prosecutors, regulators, and asset-forfeiture processes. By engaging the services, you authorize this sharing in connection with your matter.

  • We share personal data with recovery counterparties — exchanges, custodians, financial institutions, and parties responsible for distributing recovered funds — where doing so serves the recovery effort in your matter.

  • For civil recovery engagements, we share relevant case data with independent, locally qualified legal professionals in the applicable jurisdiction, acting on your behalf.

  • Van Orton may share your information with external third parties, such as vendors and service providers performing certain services on behalf of Van Orton, including website hosting, customer relationship management, electronic signature, payment processing and installment plans, email delivery, and analytics and advertising services. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable service contract, and not for any other purpose. Van Orton requires these third parties to undertake security measures consistent with the protections specified in this notice.

  • Van Orton may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

  • If Van Orton's business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.

Cross-Border Transfers of Personal Data

The nature of cross-border fraud recovery means that personal data may be transferred, accessed, and stored in countries other than your own — including jurisdictions where assets were traced or where recovery proceedings take place — as necessary for the uses stated above, in accordance with this notice and in compliance with applicable regulations.

Personal data may be transferred to or processed in locations outside of the European Economic Area (EEA), some of which have not been determined by the European Commission to have an adequate level of data protection. In that case, for personal data subject to European data protection laws, we take measures designed to provide the level of data protection required in the EU, including ensuring transfers are governed by the requirements of the Standard Contractual Clauses adopted by the European Commission, or another adequate transfer mechanism, and limiting what is shared to what the matter requires.

Where we receive requests to disclose personal data from law enforcement or regulators outside the scope of a client engagement, we validate these requests, including reviewing the legality of any order, before any personal data is disclosed.

Your Rights

Depending on the laws of the jurisdiction governing the processing of your personal data, you may have certain rights under applicable data protection laws including:

  • Access: You have the right to access personal information that Van Orton holds about you.

  • Rectification: You have the right to ask us to rectify information Van Orton holds about you if it is inaccurate or not complete.

  • Erasure: You can request that Van Orton erase your personal data. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

  • Restrict Processing: You have the right to ask Van Orton to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.

  • Object to processing: Where processing is based on legitimate interests, you have the right to object to Van Orton processing your data. Van Orton will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing.

  • Portability: Where processing is based on consent or performance of a contract, you have the right to data portability with respect to personal data that you have provided to Van Orton as the data controller.

Please contact hello@vanortonrecovery.com to exercise any of these rights. All rights requests are handled by email. Please note that Van Orton cannot facilitate the exercise of your rights without proper verification of your identity.

Subject to legal considerations or certain exemptions, we may not always be able to address your request — for example, if it would impact the duty of confidentiality we owe to others, if the data must be retained for ongoing legal, forfeiture, or law enforcement processes, or if we are legally entitled to deal with the request in a different way. The rights of individuals whose data is processed as investigative data may be limited under applicable law where the processing relates to the prevention and detection of crime or to legal claims.

Automated Decision Making

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

Van Orton does not make automated decisions using personal data. If automated decisions are to be made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.

Providing Information to Van Orton

If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the assessment of your matter, the execution of a case agreement, or the provision of the services, and we may not be able to provide you with some services.

Third Party Websites or Other Services

We are not responsible for the privacy practices of any non-Van Orton operated websites or other digital services, including those that may be linked through the Site, and we encourage you to review the privacy policies or notices published thereon.

Contact Us

Please contact us with questions, concerns, or complaints. All communications with Van Orton take place through email; please use email to ensure your request is received and handled in a timely manner. Genuine communications from Van Orton are sent only from email addresses ending in @vanortonrecovery.com.

Van Orton Recovery, LLC 131 Continental Drive Newark, Delaware 19713, United States [hello@vanortonrecovery.com]

For data subjects located in the EU or UK: if we are not able to satisfactorily resolve your questions, concerns, or complaints, or if you believe that the processing of your personal data infringes on your rights under applicable data protection laws, you have the right, without prejudice to any other administrative or judicial remedies, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement.