Privacy Policy

ORANCO LLC · Effective 6 October 2026 · Version 2.0

PRIVACY POLICY SETTING OUT THE CATEGORIES OF PERSONAL INFORMATION COLLECTED BY ORANCO LLC, THE PURPOSES AND LEGAL BASES OF PROCESSING, THE CATEGORIES OF RECIPIENT TO WHOM SUCH INFORMATION IS DISCLOSED, THE PERIODS OF RETENTION APPLIED, THE MEASURES ADOPTED TO SECURE THE SAME, AND THE RIGHTS AVAILABLE TO DATA SUBJECTS IN RESPECT THEREOF. ARTICLE 11 SETS OUT HOW TO EXERCISE THOSE RIGHTS. ORANCO LLC DOES NOT SELL PERSONAL INFORMATION.

1. Scope and controller

1.1 ORANCO LLC, a limited liability company organised under the laws of the State of Georgia (the “Company”), is the controller of, and determines the purposes and means of processing in respect of, the Personal Information described herein. This Policy applies to the Company’s collection, use, disclosure and retention of Personal Information in connection with the Digital Properties and with the Field Services, and constitutes the Company’s privacy policy for the purposes of Cal. Bus. & Prof. Code § 22575 et seq. and such other Applicable Law as may require the publication of a privacy policy.

1.2 This Policy is incorporated by reference into the Company’s Terms of Use for the purposes stated therein. Capitalised terms used but not defined herein have the meanings given in those Terms.

1.3 Notwithstanding the formality of its expression, nothing in this Policy shall be construed to derogate from any right conferred upon a data subject by Applicable Law, and in the event of any inconsistency between this Policy and such a right, such right shall prevail.

2. Definitions

2.1 “Digital Properties”
means the website at orancoclean.com and each subdomain thereof, together with each application, interface and utility made available thereby, including those made available to Personnel.
2.2 “Field Services”
has the meaning given in the Terms of Use, being the exterior cleaning and allied services performed by the Company at a Subject Property.
2.3 “Personal Information”
means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household. It does not include information that has been aggregated or deidentified such that it cannot reasonably be used to infer information about, or otherwise be linked to, a particular natural person.
2.4 “Personnel”
means a natural person who is an employee, prospective employee, or engaged contractor of the Company.
2.5 “Processor”
means a Person that processes Personal Information on behalf of and at the direction of the Company pursuant to a written instrument restricting such processing to the purposes specified by the Company.
2.6 “Sensitive Information”
means Personal Information comprising a social security number, a financial account number, a driver’s licence or state identification number, or an account credential, in each case whether alone or in combination with any security or access code.
2.7 “Telemetry”
means the usage measurements described in Article 9.

3. Categories of Personal Information collected

3.1 In the preceding twelve (12) months the Company has collected, and may continue to collect, the following categories of Personal Information:

IdentifiersGiven name and surname; postal address of a Subject Property and, where distinct, of the data subject; telephone number; electronic mail address; and, in respect of Personnel, an account identifier.
Commercial informationServices requested, quoted, performed or declined; amounts quoted, invoiced and received; scheduling particulars; notations made by the data subject or by the Company’s personnel in connection with an Engagement; and, where applicable, a payment instrument retained at the data subject’s request.
Property characteristicsAttributes of a Subject Property derived from remotely sourced data, together with photographic records of surfaces treated or to be treated. Such photographic records are of real property and are not directed at natural persons.
GeolocationThe coordinates of a Subject Property, and, where a canvassing record is created, the coordinates at which it was created.
Internet activityTelemetry as described in Article 9.
Professional informationIn respect of applicants and Personnel only: employment history, qualifications, responses to application questions, and any curriculum vitae submitted.
Sensitive InformationIn respect of Personnel only, and in respect of a retained payment instrument only: as defined in Section 2.6, subject to Article 12.

3.2 The Company does not collect, and does not seek to collect, Personal Information revealing racial or ethnic origin, religious or philosophical belief, health status, sexual orientation or union membership, save for the voluntary self-identification responses described in Section 13.2, which are collected solely for the purposes there stated.

4. Sources

4.1 Personal Information is obtained (a) directly from the data subject, upon submission through the Digital Properties, in the course of telephonic or in-person dealings, or upon engagement of the Company; (b) from the operation of the Digital Properties, in the form of Telemetry; (c) from commercially available geospatial and property-characteristic sources, in respect of a Subject Property identified by the data subject; and (d) from employment marketplaces, where an application is submitted by that route.

4.2 The Company does not acquire Personal Information from data brokers and has not done so.

5. Purposes of processing and bases therefor

5.1 Personal Information is processed for the following purposes and no others: the generation of an Indicative Estimate; the formation, scheduling, performance, invoicing and settlement of an Engagement; the maintenance of a record of work performed and amounts charged; communication with the data subject in respect of the foregoing, including the follow-up sequence described in Section 8.3; the administration, security and improvement of the Digital Properties; the administration of the employment relationship; compliance with obligations imposed by Applicable Law; and the establishment, exercise or defence of legal claims.

5.2 Where Applicable Law requires a legal basis for processing, the Company relies upon (a) the necessity of such processing for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (b) the consent of the data subject, in respect of electronic communications within Article 8 and the voluntary responses within Section 13.2; (c) compliance with a legal obligation to which the Company is subject; and (d) the legitimate interests pursued by the Company in operating, securing and improving a small local enterprise, save where such interests are overridden by the interests or fundamental rights of the data subject.

5.3 The Company does not employ Personal Information to effect automated decision-making producing legal or similarly significant effects in respect of a data subject. The generation of an Indicative Estimate is algorithmic but is preliminary, non-binding and subject to human determination, as set out in the Terms of Use.

6. Disclosure to third parties

6.1 The Company discloses Personal Information to the following categories of recipient, and in each case only such information as is necessary to the purpose stated. Each Processor is engaged under an instrument restricting processing to the Company’s purposes and prohibiting use for the Processor’s own.

InfrastructureHosting, storage and database services. Receives all categories in Article 3, as the medium in which they subsist. Presently Cloudflare, Inc.
GeospatialResolution of an address to a location and derivation of property characteristics. Receives the address of a Subject Property. Presently Google LLC.
Productivity and backupElectronic mail, calendaring and a periodic encrypted-at-rest snapshot of the Company’s records to private storage. Presently Google LLC.
MessagingTransmission and receipt of short message service traffic. Receives telephone number and message content. Presently Quo.
Electronic mail deliveryTransmission of transactional mail. Receives electronic mail address and message content. Presently Resend, Inc.
Image correspondenceDetermination of which photographic record of a surface taken after treatment corresponds to which taken before. Receives the photographic records and no other Personal Information. Presently Anthropic PBC, which does not employ such material to train models.
AccountingMaintenance of the Company’s books. Receives identifiers and commercial information pertaining to invoicing and settlement. Presently Intuit Inc.
Employment marketplaceReceipt of applications. Receives the particulars submitted by the applicant through that marketplace. Presently Indeed, Inc.

6.2 The identity of the Processor presently engaged in each category is stated for the avoidance of doubt and may be varied by the Company upon substitution of an equivalently bound Processor.

6.3 The Company further discloses Personal Information where compelled by Applicable Law, by subpoena or by order of a Governmental Authority; where necessary to establish, exercise or defend a legal claim; and to its professional advisers under duties of confidence.

7. No sale or sharing of Personal Information

7.1 The Company does not sell Personal Information, has never sold Personal Information, and does not share Personal Information for purposes of cross-context behavioural advertising. The Company receives no monetary or other valuable consideration in respect of any disclosure described in Article 6, each of which is a disclosure to a Processor for a business purpose or a disclosure compelled by law.

7.2 Accordingly, no mechanism for the exercise of a right to opt out of sale or sharing is provided, there being no such sale or sharing to opt out of. Should that cease to be the case, the Company shall amend this Policy, state the change upon this page, and provide such mechanism before any such sale or sharing occurs.

8. Electronic communications

8.1 Where a data subject furnishes a telephone number capable of receiving short message service traffic, the Company may transmit transactional and service-related messages concerning an Indicative Estimate, an Engagement, scheduling and performance. Message frequency varies. Message and data rates may apply.

8.2 A data subject may revoke such consent at any time by replying STOP to any such message, whereupon transmission shall cease. Replying HELP returns contact particulars. The Company does not transmit promotional short message service traffic to a Person who has neither solicited an Indicative Estimate nor entered into an Engagement.

8.3 Where an Indicative Estimate is solicited and no response is received, the Company transmits a bounded follow-up sequence and thereafter desists. Any reply whatsoever terminates that sequence in its entirety, a reply being treated as indicating that the correspondence warrants a person rather than a schedule.

9. Telemetry and Do Not Track

9.1 The Company records measurements of the use of the Digital Properties comprising: the pages requested and their sequence; the stage attained within the Pricing Utility; the referring resource, if any; a coarse device classification; the municipality within which a Subject Property lies, and not the street address thereof; the figure produced by the Pricing Utility; and a randomly generated identifier permitting two requests to be attributed to a single visit.

9.2 Telemetry does not incorporate a name, electronic mail address, telephone number or street address, and is not linked by the Company to any identified natural person. Telemetry is erased upon the expiry of one hundred and eighty (180) days from collection, by automated process.

9.3 The Company does not permit third-party advertising networks, analytics providers or tracking technologies to operate upon the Digital Properties, and does not track data subjects across third-party websites or services. No cookie is set for advertising or cross-site purposes. In consequence, and for the purposes of Cal. Bus. & Prof. Code § 22575(b)(5) and (b)(6), the Company states that it does not undertake the tracking to which a Do Not Track signal pertains, and no third party conducts such tracking upon the Digital Properties; the Company therefore has no occasion to respond differentially to such a signal.

10. Retention

10.1 Personal Information is retained for the period stated below, or for such longer period as is required by Applicable Law or as is necessary for the establishment, exercise or defence of a legal claim then subsisting, whereupon it is erased or deidentified.

TelemetryOne hundred and eighty (180) days
Indicative Estimates not resulting in an EngagementTwo (2) years
Customer and Engagement recordsSeven (7) years, consistent with taxation and warranty periods
Photographic recordsTwo (2) years
Retained payment instrumentUntil revoked by the data subject or expiry
Message historyCoterminous with the record to which it pertains
Unsuccessful applicationsOne (1) year
Personnel recordsAs required by federal and Georgia law, generally four (4) years following cessation of employment and three (3) years in respect of Form I-9

11. Rights of data subjects

11.1 Any data subject, irrespective of residence, may exercise each of the following rights by notice to the Company pursuant to Article 17:

11.2 The Company shall respond within thirty (30) days of receipt and shall levy no charge. The Company may request such information as is reasonably necessary to verify the identity of the requesting Person, and shall use such information for no purpose other than verification. An authorised agent may make a request on a data subject’s behalf upon production of written authority.

11.3 The Company does not require a data subject to establish residence in any particular jurisdiction as a condition of exercising the rights set out in Section 11.1, and extends them generally.

12. Security

12.1 The Company maintains administrative, technical and physical safeguards proportionate to the nature and sensitivity of the Personal Information processed, comprising, inter alia: transmission over encrypted channels; restriction of access to the Company’s systems by authentication; the limitation of information displayed to field personnel to the municipality of a Subject Property in substitution for its street address; the issuance of document access identifiers of sufficient entropy as to preclude enumeration and the maintenance of no index thereof; and the encryption of Sensitive Information field by field under a key maintained apart from the data store, such that acquisition of the data store alone does not yield any item of Sensitive Information in intelligible form.

12.2 No safeguard is absolute and the Company does not represent otherwise. In the event of a breach of the security of the system resulting in the unauthorised acquisition of unencrypted Personal Information, the Company shall give notice to each affected data subject and to the Attorney General of the State of Georgia in the manner and within the period prescribed by O.C.G.A. § 10-1-910 et seq., and to such other authority as Applicable Law may require.

13. Personnel data

13.1 In respect of an applicant, the Company collects identifiers, professional information and such responses as the applicant elects to provide. In respect of a Person engaged, the Company further collects the particulars required by Form I-9, Form W-4 and Georgia Form G-4, particulars of a financial account for the remittance of wages, an emergency contact, and documentary evidence of identity and authorisation to work. Such documentary evidence is processed for the purpose of verification under 8 U.S.C. § 1324a and for no other purpose.

13.2 Responses concerning race, ethnicity, sex, veteran status and disability are solicited on a voluntary basis only, are maintained apart from the application, are withheld from each Person participating in the selection decision, and are processed solely for the statistical reporting contemplated by Applicable Law.

13.3 Sensitive Information pertaining to Personnel is encrypted in accordance with Section 12.1, is not rendered in intelligible form upon any screen of the Company’s administrative systems, and is decrypted only where the completion of an instrument requires it.

14. Minors

14.1 The Digital Properties are directed to Persons of the age of majority transacting in respect of real property. The Company does not knowingly collect Personal Information from a child under the age of thirteen (13) within the meaning of the Children’s Online Privacy Protection Act, 15 U.S.C. § 6501 et seq. Should the Company become aware that it has done so, it shall erase such information forthwith. A parent or guardian may give notice pursuant to Article 17.

15. Transfers and succession

15.1 Personal Information is processed and stored within the United States. The Company does not transfer Personal Information to a Processor established outside the United States save where such Processor is engaged upon terms providing an equivalent standard of protection.

15.2 In the event of a merger, acquisition, reorganisation or sale of all or substantially all of the Company’s assets, Personal Information may be transferred to the successor in interest, which shall remain bound by this Policy in respect of information so transferred until such time as it publishes a policy of its own and gives notice thereof.

16. Amendment

16.1 The Company may amend this Policy from time to time by publication of a revised version bearing a later effective date upon this page. Where an amendment materially alters the categories collected, the purposes of processing or the categories of recipient, the Company shall identify that amendment upon this page rather than effect it silently.

17. Notices and contact

17.1 All requests, enquiries and notices under this Policy shall be addressed to marketing@orancoclean.com, or by post to ORANCO LLC, Lawrenceville, Georgia, and shall be deemed given upon receipt. The Company does not require any particular form of words.

ORANCO LLC
Lawrenceville, Georgia
marketing@orancoclean.com
(770) 525-4655

Intuit QuickBooks: the connection subsisting between the Company and the Company’s own books of account carries identifiers and commercial information pertaining to invoicing and settlement, as set out in Article 6. Processing by Intuit Inc. in that capacity is governed additionally by Intuit’s own privacy statement. The connection affords no Person access to the Company’s records other than the Company and its accountant.