Legal
ORTELIUS AI PRIVACY POLICY
Last Updated: [DATE]
Ortelius AI, Inc. (“Ortelius,” “we,” “us,” or “our”) operates an online marketplace and site intelligence platform that connects owners of land with business buyers and lessees of industrial-use real property, including data center, manufacturing, and energy sites. This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with our website at orteliusai.com, our landowner portal at list.orteliusai.com (the “Landowner Portal”), our buyer portal at find.orteliusai.com (the “Buyer Portal”), and our related communications and services (collectively, the “Services”).
This Privacy Policy forms part of, and should be read together with, our Marketplace Terms of Service (the “Terms”). Capitalized terms used but not defined in this Privacy Policy have the meanings given in the Terms.
This Privacy Policy does not apply to personal information that a Buyer, landowner, or other third party collects or uses independently, including personal information you share directly with another user after an introduction through the Services. Those persons are responsible for their own privacy practices.
1. WHO THIS PRIVACY POLICY COVERS
This Privacy Policy applies to the following individuals:
- Landowner Users, including individual owners, co-owners, trustees and estate representatives, representatives of entities that own property, and licensed real estate professionals acting for owners (“Land Partners”);
- Buyer Users, meaning individuals who access the Buyer Portal on their own behalf or on behalf of a business, and personnel of any Buyer’s Authorized Organizations;
- Visitors to our websites and individuals who contact us, sign up for updates, attend our events, or otherwise interact with us;
- Associated individuals whose information a user provides to us, such as co-owners, alternate contacts, trustees, and other individuals named in documents uploaded to the Services; and
- Property owners and other individuals who are not users but whose information appears in public records or third-party data sources that we use to identify, map, and evaluate land parcels (see Section 4).
2. OUR ROLE
Ortelius is the business or controller responsible for the personal information described in this Privacy Policy. Ortelius does not act as a service provider or processor on behalf of Buyers or landowners for the information described here. If Ortelius enters into a separate written agreement with an enterprise Buyer under which Ortelius processes personal information on that Buyer’s behalf, the terms of that agreement will govern that processing.
3. PERSONAL INFORMATION WE COLLECT
Information you provide to us. Depending on how you use the Services, we collect:
- Account and contact information, such as name, email address, telephone and mobile number, mailing address, company or organization name, job title, username, password, and communication preferences;
- Listing and property information submitted by Landowner Users, such as property address, parcel or tax identification numbers, acreage, ownership structure, property interests offered, utility service, zoning, leases, encumbrances, environmental conditions, photographs, pricing expectations, and other listing content;
- Uploaded documents, such as deeds, title reports, surveys, leases, tax bills, trust or estate documents, powers of attorney, and entity documents, which may contain personal information about you and about other individuals, such as co-owners, prior owners, tenants, and lenders;
- Authority and licensing information, such as evidence of your authority to act on behalf of an owner, trust, estate, or entity, and, for Land Partners, real estate license numbers and brokerage affiliation;
- Buyer information, such as your organization, role, site requirements and investment criteria, bids, option requests, requests for information, Authorized Organization disclosures, non-disclosure agreement records, records of persons with whom you have shared Site Information;
- Verification and screening information, such as information about your identity, the beneficial ownership and control of a Buyer, and information needed to screen against sanctions and restricted-party lists, including government-issued identification where we request it;
- Payment and transaction information, such as invoicing details, payment records, and, where you pay a fee by bank transfer, bank account details used to process that payment;
- Communications, such as messages exchanged with us or, through the Services, with other users, support requests, survey responses, and feedback, and recordings of calls with us where permitted by law and after any required notice; and
- Information about other individuals that you choose to provide, such as co-owner or alternate contact details. If you provide information about another person, you must have the right to do so and must provide any notice and obtain any consent required by law (see Section 7.3 of the Terms).
Information we collect automatically. When you use the Services, we and our service providers automatically collect:
- Device and log information, such as IP address, browser type and version, operating system, device identifiers, access times, referring URLs, and error and diagnostic data;
- Usage information, such as pages, listings, maps, and reports viewed; searches, filters, and map interactions; the dates and times you first and subsequently view each listing; documents opened or downloaded; and actions taken within the Landowner Portal or Buyer Portal;
- Approximate location information, such as country, state, city, or region derived from your IP address. We do not collect the precise geolocation of your device; and
- Cookie and similar technology information, as described in Section 9.
Information we obtain from other sources. We obtain information from:
- Public records and government sources, such as county assessor, recorder, and tax records, parcel and GIS datasets, court records, utility and public utility commission filings, interconnection queue data, permitting records, and records of public meetings, which may include the names and mailing addresses of property owners and the names of individuals who participate in public proceedings;
- Third-party data providers and licensors, such as providers of mapping, geocoding, zoning, and telecommunications infrastructure data, and providers of property ownership, business contact, or data enrichment information;
- Publicly available online sources, such as news reports, public comment records, and public social media content that we analyze in aggregate to assess community sentiment regarding development;
- Other users, such as a Landowner User who identifies a co-owner or alternate contact, a Land Partner who lists a client’s property, or a Buyer who identifies its Authorized Organizations;
- Verification and screening providers, such as identity verification and sanctions or restricted-party screening services; and
- Business contacts and referral sources, such as individuals who refer landowners or Buyers to us, event organizers, and professional networking services.
Sensitive personal information. Some information we collect may be considered sensitive under applicable law, such as account log-in credentials, government identification numbers, and financial account information used to process payments. We use sensitive personal information only for purposes permitted by applicable law, such as providing the Services you request, verifying identity, preventing fraud, and complying with legal obligations, and we do not use it to infer characteristics about you.
4. PROPERTY OWNERS WHO ARE NOT USERS
To identify and evaluate land that may be suitable for industrial development, we use parcel data from public records and licensed third-party sources. This data may include the names and mailing addresses of property owners who have never used the Services. We use this information to identify parcels, assess their characteristics, determine ownership type (for example, individual, trust, or entity), and maintain the accuracy of our parcel data. We do not display the names or contact information of owners of unlisted parcels to Buyers, and we do not sell this information. We may contact owners of parcels that appear suitable for development to let them know about the Services, in compliance with applicable law.
If you are a property owner and would like us to suppress your information from any outreach, or to exercise any of the rights described in Section 12 or Section 13, please contact us as described in Section 18. Where information is lawfully made available from government records, some privacy laws do not treat it as personal information, and we may be unable to delete it from our parcel datasets, but we will honor suppression requests for outreach and will not associate your name with the Services beyond what is necessary to maintain accurate parcel data.
5. HOW WE USE PERSONAL INFORMATION
We use personal information to:
- create and administer accounts, authenticate users, and provide the Landowner Portal and Buyer Portal;
- publish listings, present anonymized listings to Buyers, and, with the landowner’s consent, facilitate direct contact between landowners and Buyers;
- generate, maintain, and improve site scores, maps, analyses, and other Platform content;
- verify identity, ownership, authority, and licensing, and screen users against sanctions and restricted-party lists;
- administer and enforce the Terms, including Buyer confidentiality obligations, records of Authorized Organizations and Site Information recipients, and the invoicing and collection of fees under any applicable Order Form;
- communicate with you about your account, listings, Buyer interest, bids, transactions, security, and changes to the Services or our policies;
- send marketing communications about the Services, subject to your choices and applicable law;
- provide support, respond to inquiries, and conduct surveys;
- monitor, analyze, debug, and improve the performance and security of the Services;
- detect, investigate, prevent, and respond to fraud, misuse, scraping, security incidents, and violations of the Terms;
- comply with applicable law, legal process, and regulatory obligations, and establish, exercise, or defend legal claims; and
- carry out any other purpose disclosed to you at the time of collection or with your consent.
6. ARTIFICIAL INTELLIGENCE AND MODEL DEVELOPMENT
Ortelius uses machine-learning and artificial intelligence models, including models provided by third parties, to generate site scores, summaries, and analyses. Our scores and analyses evaluate land and sites, not individuals, and we do not use them to make decisions about any individual that produce legal or similarly significant effects.
We may use listing content, information about listing activity and transaction outcomes, and usage information to develop, train, validate, and improve our models and Services, in de-identified or aggregated form wherever reasonably practicable.
We do not use the contents of documents you upload, your contact information, or your communications to train generalized artificial intelligence models, and we do not permit our third-party artificial intelligence providers to use your personal information to train their models. Where we use public online content to assess community sentiment, we analyze it in aggregate and do not create profiles of identifiable individuals.
7. HOW WE DISCLOSE PERSONAL INFORMATION
Between landowners and Buyers. The Services are designed to share information between landowners and Buyers in stages:
- Listings. We make listing information available to Buyers in anonymized form. Listings do not include a landowner’s name or contact information, but the location and characteristics of a property may allow a Buyer to identify the property and its owner through public records.
- Documents. Documents that a landowner elects to share with Buyers, including any personal information they contain, will be visible to Buyers who access them.
- Contact information. We share a landowner’s name and contact information with a Buyer only with the landowner’s consent, as described in Section 9.8 of the Terms.
- Buyer information. We share bids, option requests, requests for information, and related communications from a Buyer with the applicable landowner, and we disclose a Buyer’s identity to the landowner at the stage described in the Services or with the Buyer’s consent.
Once a landowner or Buyer receives personal information through the Services, that recipient is responsible for its own use of the information, subject to the confidentiality and data-use obligations in the Terms.
Authorized Organizations. Buyers may share Site Information with their Authorized Organizations, such as affiliates, investors, lenders, co-investors, and advisors, subject to the Terms.
Service providers. We disclose personal information to vendors that perform services on our behalf, such as cloud hosting and storage, authentication, email and SMS delivery, customer support, analytics, mapping and geocoding, identity verification and sanctions screening, payment processing, artificial intelligence and machine-learning providers, security, and professional services. Our current service providers include: Amazon Web Services; Vercel; Supabase; Resend; PostHog; CARTO; Esri; komoot (Photon geocoding); Zoneomics; Anthropic; OpenAI; and Google (Google Maps Platform). We require service providers to use personal information only to provide services to us.
Professional advisors and auditors. We disclose personal information to our lawyers, accountants, auditors, insurers, and other professional advisors as needed in the course of their services.
Legal, safety, and enforcement. We disclose personal information when we believe in good faith that doing so is necessary to comply with law, legal process, or a governmental request; to enforce the Terms, including confidentiality and fee obligations under any applicable Order Form; to protect the rights, property, or safety of Ortelius, our users, or others; or to detect, prevent, or respond to fraud, security incidents, or illegal activity.
Corporate transactions. We may disclose personal information in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, or bankruptcy, in which case personal information may be transferred to the successor or acquirer.
With your consent or at your direction. We disclose personal information when you instruct us to or consent to the disclosure.
De-identified and aggregated information. We may use and disclose information that has been de-identified or aggregated so that it does not reasonably identify any individual. Where we maintain de-identified information, we take reasonable measures to ensure it cannot be associated with an individual, publicly commit to maintain and use it only in de-identified form and not to attempt to re-identify it, and contractually require any recipients to do the same.
No sale of personal information. We do not sell personal information for money.
8. YOUR COMMUNICATION CHOICES
Email. You may unsubscribe from marketing emails by using the unsubscribe link in the email or contacting us. We will continue to send account, listing, transaction, and security communications, which are necessary to use the Services.
Text messages. If you consent to receive text messages, you may opt out at any time by replying STOP, and you may reply HELP for help. Consent to receive marketing text messages is not a condition of using the Services. Message frequency varies, and message and data rates may apply. We do not sell or share mobile numbers or text messaging consent with third parties for their own marketing purposes.
Calls. We may record calls with you for quality, training, and record-keeping purposes after providing any notice required by law.
9. COOKIES AND SIMILAR TECHNOLOGIES
We and our service providers use cookies, local storage, pixels, and similar technologies (collectively, “cookies”) to operate the Services, keep you signed in, remember your preferences, protect the Services, and understand how the Services are used. The table below describes the categories of cookies we use.
| Category | Purpose | Your choices |
|---|---|---|
| Strictly necessary | Authentication, session management, security, fraud and bot prevention, load balancing, and enforcing access controls on Site Information. | These cannot be disabled through our systems. Blocking them in your browser may prevent the Services from working. |
| Functional | Remembering your preferences, such as map layers, filters, and interface settings. | You can clear or block these in your browser settings. |
| Analytics | Measuring usage and performance of the Services using PostHog (buyer portal only). Autocapture is disabled; only a limited set of allowlisted events are collected; no personal information is included. | You can block these in your browser settings. Where required by applicable law, these are set only with your consent. |
| Advertising and visitor identification | We do not use these technologies. | Not applicable. |
Some browsers transmit “Do Not Track” signals. Because there is no common standard for these signals, we do not currently respond to them. We also do not currently respond to Global Privacy Control or other browser-based opt-out preference signals, except where required by applicable law.
10. RETENTION
We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, administer and enforce the Terms, comply with legal obligations, resolve disputes, and maintain security and backup records. The criteria we use include the nature of the information, the duration of your relationship with us, the duration of confidentiality obligations and any fee obligations under the Terms, applicable statutes of limitations. For example, we retain records of Buyer listing views, introductions, bids, Authorized Organizations, and Site Information recipients for at least the applicable confidentiality period under the Terms and any applicable limitations period after they end.
When retention is no longer necessary, we delete or de-identify the information or, if that is not technically possible (for example, in backups), securely isolate it until deletion is possible.
11. SECURITY
We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including access controls, encryption in transit, encryption at rest, and logging, and restrictions on who within Ortelius may access licensed data and Site Information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your credentials confidential and for notifying us promptly of any unauthorized use of your account.
12. YOUR PRIVACY RIGHTS
Depending on where you live, and subject to exceptions, applicable law may give you the right to: (a) know or access the personal information we hold about you; (b) correct inaccurate personal information; (c) delete personal information; and (d) receive a portable copy of personal information you provided to us. To exercise these rights, contact us as described in Section 18. Where applicable law does not give you a particular right, we may consider your request in our discretion. We will verify your request by matching information you provide with information we hold, and we may ask for additional information where necessary. We will not discriminate against you for exercising your rights.
Some requests may be limited by law or by our legitimate needs. For example, we may retain information needed to administer fee obligations under any applicable Order Form, comply with law, or defend legal claims, and deleting certain information may require closing your account. If a landowner has already shared information with a Buyer in accordance with the Terms, we can delete our copy but cannot retrieve information from the Buyer; we will, however, notify the Buyer of your request where required by law.
13. U.S. STATE NOTICES
Residents of certain U.S. states may have additional rights under the privacy laws of their state of residence, to the extent those laws apply to Ortelius. Where they apply, you may exercise those rights as described in Section 12.
California “Shine the Light.” California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.
14. INTERNATIONAL USERS
The Services are intended for the evaluation of real property in the United States, and we process personal information in the United States. If you access the Services from outside the United States, including from the European Economic Area, the United Kingdom, or Switzerland, your personal information will be transferred to and processed in the United States, which may not provide the same level of protection as your home jurisdiction.
If the GDPR or UK GDPR applies to our processing of your personal information, we rely on the following legal bases: performance of a contract (to provide the Services and administer the Terms); legitimate interests (to secure, improve, and market the Services, verify users, enforce the Terms, and maintain accurate parcel data, where those interests are not overridden by your rights); compliance with legal obligations (for example, sanctions screening and tax records); and consent (for non-essential cookies and marketing where consent is required). Where we transfer personal information outside the EEA, the United Kingdom, or Switzerland, we rely on the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, or another lawful transfer mechanism. In addition to the rights in Section 12, you may object to processing based on legitimate interests, request restriction of processing, withdraw consent at any time without affecting prior processing, and lodge a complaint with your local supervisory authority.
15. CHILDREN
The Services are intended for business use and are not directed to anyone under eighteen (18) years of age. We do not knowingly collect personal information from anyone under eighteen (18). If you believe we have done so, please contact us and we will delete the information.
16. THIRD-PARTY SITES AND SERVICES
The Services may contain links to, or integrations with, third-party websites and services, including mapping and data providers. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.
17. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. If we make material changes, we will post the updated Privacy Policy with a revised “Last Updated” date and, where required by law, provide additional notice, such as by email to the address associated with your account. Where required by law, we will obtain your consent before using previously collected personal information in a materially different way.
18. CONTACT US
If you have questions about this Privacy Policy or wish to exercise your rights, please contact us at:
Ortelius AI, Inc.Attn: Privacy95 Third Street, Suite 260, San Francisco, CA 94103Email: issues@orteliusai.com