Privacy policy

Van Orton Recovery, LLC. Last revised 12 June 2026.

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, and with applicable privacy laws including, but not limited to, the EU General Data Protection Regulation (GDPR). This 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"). It is incorporated by reference into our Terms of Use.

Who is collecting data

Data is collected by Van Orton Recovery, LLC, acting as a data controller. 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, in connection with the investigation of suspected fraud, the establishment or defense of legal claims, and the reporting of suspected criminal activity to competent authorities.

Data we collect

• Contact data: name and email address, to communicate with clients and potential clients. All communications with Van Orton take place through email.
• Case and services data: 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.
• Investigative data: information from public records, open-source intelligence, public blockchain ledgers, court filings, exchanges, financial institutions, and law enforcement, including data about individuals connected to a matter.
• Billing data: information to administer engagements, invoicing, and installment plans. Payment card processing is handled by our payment service providers; Van Orton does not store full payment card numbers.
• Marketing information: information to respond to inquiries or to provide updates by email.
• Website visitor information: IP address, device and browser type, pages visited, and the source of your visit (for example, that it originated from one of our advertisements), through cookies and similar technologies. You can control cookies through your browser settings.

How we process your data

We collect personal data to offer and administer our services. We process it to comply with legal obligations; to perform a contract or take steps at your request before entering one (such as a free case assessment); for our legitimate business interests in conducting and managing our business; for marketing purposes; and with your consent where required.

Legitimate-interest processing includes performing the services under a signed case agreement; submitting investigative findings to law enforcement and coordinating recovery with exchanges, custodians, financial institutions, and courts; investigating suspected fraud and supporting legal claims; communicating with you, including monthly status reports; operating, improving, and securing the Site, including measuring the performance of our advertising; and protecting against security breaches, impersonation, and fraud. Whenever we rely on legitimate interests, we balance any impact on you and your rights, and you have the right to object.

Marketing

We may use your information to discuss your interest in the services and to send you information about Van Orton by email. If you are in the EU or UK, we send marketing communications only with your prior consent or on the basis of legitimate interests where permitted. You can withdraw consent or opt out at any time using the "unsubscribe" link in our marketing emails, or by emailing hello@vanortonrecovery.com.

How data is processed and stored

Personal data is processed manually and electronically in compliance with current regulations. Only authorized Van Orton personnel and appropriately instructed third-party processors have access. We retain personal data for a reasonable period taking into account legitimate business needs and legal, tax, and regulatory requirements, and for the period during which recovery, asset distribution, forfeiture, or related legal proceedings remain ongoing. When information is no longer needed, we delete or de-identify it.

Disclosure and sharing

We only share your personal data with your consent or in accordance with this policy, and we do not sell personal data. 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. We share data with recovery counterparties (exchanges, custodians, financial institutions, and parties distributing recovered funds), with locally qualified legal professionals for civil recovery, and with vetted vendors and service providers (hosting, CRM, e-signature, payment processing and installment plans, email delivery, analytics and advertising). We may disclose data in response to lawful requests by public authorities, and in the event of a merger or joint venture.

Cross-border transfers

The nature of cross-border fraud recovery means personal data may be transferred, accessed, and stored in countries other than your own, including jurisdictions where assets were traced or recovery proceedings take place. For personal data subject to European data protection laws, we take measures designed to provide the level of protection required in the EU, including Standard Contractual Clauses or another adequate transfer mechanism, and we limit what is shared to what the matter requires.

Your rights

Depending on the laws governing the processing of your data, you may have rights to access, rectification, erasure, restriction of processing, objection to processing, and data portability. Please contact hello@vanortonrecovery.com to exercise any of these rights. All rights requests are handled by email, and we cannot act without proper verification of your identity. Some requests may be limited where they would affect duties of confidentiality owed to others, where data must be retained for ongoing legal, forfeiture, or law enforcement processes, or where the processing relates to the prevention and detection of crime.

Automated decision making

Van Orton does not make decisions about individuals based solely on automated processing that produce legal or similarly significant effects. If such decisions are ever introduced, affected persons will be given an opportunity to express their views and to object.

Providing information to Van Orton

If you choose not to provide certain personal information, it may impede the exchange of information necessary to assess your matter, execute a case agreement, or provide the services, and we may not be able to provide you with some services.

Third-party websites

We are not responsible for the privacy practices of any non-Van Orton websites or services, including those linked through the Site, and we encourage you to review their privacy notices.

Contact us

Please contact us with any questions, concerns, or complaints. All communications take place through email, sent only from addresses ending in @vanortonrecovery.com or @example.vanortonrecovery.com. Van Orton Recovery, LLC, 169 Madison Ave STE 49282, New York, NY 10016, United States, hello@vanortonrecovery.com. Data subjects in the EU or UK also have the right to lodge a complaint with a supervisory authority.