Privacy Policy
Rubicon, a product of Van Orton Recovery · Last revised: 12 June 2026
Introduction
Van Orton Recovery, LLC (“Van Orton,” “Rubicon,” “we,” or “us”) is committed to complying with 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 Privacy Notice applies when Van Orton provides case assessments, asset tracing, fraud investigation, recovery coordination, and related intelligence services (the “services”) through Rubicon to its clients, and to visitors of our Site.
This Privacy Notice is incorporated by reference into our Terms of Use.
Who is collecting data?
Data is collected by Van Orton Recovery, LLC. This policy applies to personal data 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.
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 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
Contact data: 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: data provided by clients to perform the services, which 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.
Investigative data: 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 subscriptions, invoicing, and payment. Payment card processing is handled by our payment service providers; Van Orton does not store full payment card numbers.
Website visitor information: information about your visit such as your IP address, device and browser type, pages 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.
Processing of personal data
We collect personal data to offer and administer our services. Data is processed for the purposes specified in this notice, namely:
- To comply with obligations provided by laws and regulations (e.g., tax, anti-money laundering, and sanctions regulations).
- Where processing is necessary to perform a contract or to take steps at your request prior to entering into one (e.g., a free case assessment or a signed case agreement).
- Where necessary for our legitimate business interests, including performing the services (asset tracing, investigation, documentation, and case reports and filings), submitting investigative findings to law enforcement, coordinating recovery with exchanges, custodians, financial institutions, and courts, communicating with you by email including monthly status reports, and operating, improving, and securing the Site.
- For marketing purposes, subject to your consent where required. You can opt out at any time via the “unsubscribe” link in our marketing emails or by emailing hello@vanortonrecovery.com.
- With your consent, where clearly provided at the time you give it.
Whenever we process personal data for our legitimate interests, we consider and balance any potential impact on you and your rights. 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 purposes and applicable regulations. We permit only authorized Van Orton personnel and third-party processors to access your information, and such parties are instructed to process data only according to our instructions, with safeguards proportionate to the sensitivity of the data we handle.
Storage of personal data
Van Orton retains personal data for a reasonable period, taking into account legitimate business needs and the period necessary to comply with 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.
- 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.
- We may share information with vendors and service providers (website hosting, CRM, electronic signature, payment processing, email delivery, and analytics and advertising), solely to perform services on our behalf and subject to security measures consistent with this notice.
- We may disclose personal data in response to lawful requests by public authorities, or to a successor entity in the event of a merger or joint venture.
Cross-border transfers of personal data
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 where 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 limit what is shared to what the matter requires.
Your rights
Depending on the laws governing the processing of your personal data, you may have rights including:
- Access to personal information we hold about you.
- Rectification of information that is inaccurate or incomplete.
- Erasure of your personal data, subject to basic data retained to respect your request.
- Restriction of processing.
- Objection to processing based on legitimate interests.
- Portability of data you have provided, where processing is based on consent or contract.
Please contact hello@vanortonrecovery.com to exercise any of these rights. All rights requests are handled by email, and we cannot facilitate them without proper verification of your identity. The rights of individuals whose data is processed as investigative data may be limited under applicable law where processing relates to the prevention and detection of crime or to legal claims.
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 to be made, 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 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 services
We are not responsible for the privacy practices of any non-Van Orton operated websites or digital services, including those linked through the Site, and we encourage you to review the privacy policies published thereon.
Contact us
All communications with Van Orton take place through email. Genuine communications are sent only from addresses ending in @vanortonrecovery.com.
Van Orton Recovery, LLC
169 Madison Ave STE 49282, New York, NY 10016, United States
hello@vanortonrecovery.com
For data subjects located in the EU or UK: if we cannot satisfactorily resolve your concerns, you have the right 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.