Privacy Policy
Last Updated: February 1, 2024
Welcome to Odyssey. This Privacy Policy explains how Odyssey Technologies (“Odyssey,” “Company,” “we,” “us” or “our”) collects, uses, discloses, and otherwise processes personal data in connection with Odyssey’s brands, including the Odyssey mobile application, as well as any specific product, service, or application that references or links to this Privacy Policy. We may also choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions, or states. Please refer to the Region-Specific Disclosures section below for additional disclosures that may be applicable to you.
This Privacy Policy does not address our privacy practices relating to Odyssey job applicants, employees and other personnel, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Policy is also not a contract and does not create any legal rights or obligations not otherwise provided by law.
Our Role in Processing Personal Data
Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller’s instructions.
This Privacy Policy describes our privacy practices where we are acting as the controller of personal data. Generally, we operate as a controller of personal data and do not operate as a processor on behalf of other entities.
If you access our services or otherwise interact with us from the European Economic Area, United Kingdom, or Switzerland, please see the Controller Details and Privacy Contacts section of our Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures for more information about our legal entities operating as the controllers of your personal data.
Our Collection and Use of Personal Data
The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you register for an account, make an online purchase, post on our platform, participate in an event, contest, promotion or survey, or otherwise contact us or interact with us.
We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties.
Personal Data Provided by Individuals
We collect the following categories of personal data individuals provide us:
Contact Information, including first and last name, phone number, email address, and communication preferences. We use this information primarily to fulfill your request or transaction and to communicate with you directly.
Account Information, including first and last name, email address, phone number, account credentials or one-time passcodes. We use this information primarily to administer your account, provide you with our products and services, communicate with you regarding your account and your use of our products and services, and for support purposes.
User Content, including any files, documents, audio, images, data, or communications you choose to input, upload, or transmit to our products and services, and any metadata associated with such documents, images or other files. We use this content primarily to provide you with our products and services, to facilitate your requests, and to improve our products and services.
Community Information, including number of days visited, topics and posts created, topics viewed, posts read, time spent reading, likes given and received, badges, certifications, and community preferences.
Payment Information, including payment card information, billing address, and other financial information if you choose to purchase additional storage space on Odyssey. Please note that we use third-party payment providers to process payments made to us. We do not retain any personally identifiable financial information, such as payment card number, you provide these third-party payment providers in connection with payments. Rather, all such information is provided directly by you to our third-party payment providers. The payment provider’s use of your personal data is governed by their privacy policy.
Event, Contest, Promotion, and Survey Information, including information provided when you sign up for an event, enter a contest or promotion, complete a survey or submit a testimonial. We use this information primarily to administer and facilitate our products and services, respond to your submission, communicate with you, conduct market research, inform our marketing and advertising activities, improve and grow our business, and facilitate the related event, content, promotion, or survey.
Feedback and Support Information, including the contents of custom messages sent through the forms, chat platforms, email addresses, or other contact information we make available to users, as well as recordings of calls with us, where permitted by law (including through the use of automated tools provided by us or our third-party providers). We use this information primarily to investigate and respond to your inquiries, to communicate with you, and to improve our products and services.
Information About Your Location, including geographic location that may be included in the metadata in the photos you upload, or that you may provide about the photos you upload. We use this information to administer and facilitate our products and services.
If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Policy. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
Personal Data Automatically Collected
We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our products and services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.
We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:
Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.
Information About the Way Individuals Use Our Services and Interact With Us, including how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, the communications you have through our services, and the content or links you interact with).
All of the information collected automatically through these tools allows us to improve your user experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our products and services, and to improve the effectiveness of our products, services, offers, advertising, communications and user support. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the app; (b) provide custom, personalized content and information; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our products and services.
For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below.
Personal Data from Other Sources and Third Parties
We may receive the same categories of personal data as described above from the following sources and other parties:
Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across all Odyssey entities. To provide our products and facilitate our services, Odyssey entities receive personal data from other Odyssey entities for purposes and uses that are consistent with this Privacy Policy.
Single Sign-On: We may provide you the ability to log in to our services through certain third-party accounts you maintain. When you use these single sign-on protocols to access our services, we do not receive your login credentials for the relevant third-party service. Instead, we receive tokens from the single sign-on protocol to help identify you in our system (such as by your username) and confirm you successfully authenticated through the single sign-on protocol. This information allows us to more easily provide you access to our products and services.
Employers: If you interact with our services in connection with your employment, we may obtain personal data about you from your employer or another company for which you work. For example, we may obtain your contact information from your employer to allow us to communicate with you about your employer’s relationship with us.
Other Users: We may receive your personal data from our other users. For example, a user may provide us with your contact information as a part of a referral.
Social Media: When you interact with our services through other social media networks, such as when you follow us or share our content on other social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include profile information, profile picture, username, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information primarily to operate, maintain, and provide to you the features and functionality of our products and services, as well as to communicate directly with you, such as to send you messages about features that may be of interest to you.
Advertisers, Influencers, and Publishers: We engage in advertising through third-party services. Advertisers, influencers, and publishers may share personal data with us in connection with our advertising efforts.
Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services as a part of or in connection with our services. For example, certain of our products and services allow our users to integrate third-party services. If you choose to leverage these third-party service integrations, we may receive confirmation from our business partner regarding whether you are an existing user of their services.
Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.
Other Sources: We may also collect personal data about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.
Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.
Additional Uses of Personal Data
In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:
Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our products and services, or to deliver the services requested;
Manage our organization and its day-to-day operations;
Communicate with you, including via email, text message, chat, and/or social media;
Facilitate the relationship we have with you and, where applicable, the company you represent;
Request you provide us feedback about our product and service offerings;
Address inquiries or complaints made by or about an individual in connection with our products or services;
Create and maintain accounts for our users;
Verify your identity and entitlement to our products and services;
Register you for and provide you access to events, contests, sweepstakes, and surveys;
Market our products and services to you, including through email, text message, push notification, and social media;
Administer, improve, and personalize our products and services, including by recognizing you and remembering your information when you return to our products and services;
Develop, operate, improve, maintain, protect, and provide the features and functionality of our products and services;
Identify and analyze how you use our products and services;
Infer additional information about you from your use of our products and services, such as your interests;
Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Policy;
Conduct research and analytics on our user base and our products and services, including to better understand the demographics of our users;
Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;
Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems;
Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Service), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Odyssey and others;
Facilitate business transactions and reorganizations impacting the structure of our business;
Comply with contractual and legal obligations and requirements; or
Fulfil any other purpose for which you provide your personal data, or for which you have otherwise consented.
Our Disclosure of Personal Data
We disclose or otherwise make available personal data in the following ways:
To Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across Odyssey entities. To provide our products and facilitate our services, Odyssey entities disclose personal data to other Odyssey entities for purposes and uses that are consistent with this Privacy Policy.
To Your Employer: If you interact with our services in connection with your employment, we may disclose personal data to your employer or another company for which you work. For example, we may provide information to your employer about your usage of our services in connection with your work for them.
To Other Users and the General Public: We make available personal data designed for sharing through our services with certain or all other Odyssey users, or the general public, based on the applicable privacy settings and intended recipients. Keep in mind that the users who view user-generated content can always reshare or redistribute the content both on and off our services or save or copy the content outside of our services. In addition, by publicly posting content on our services, you are directing us to disclose that information as broadly as possible and directing those accessing the content to do the same.
To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf. We endeavor to contractually require any third party with whom the Odyssey application shares user data to provide the same or equal protection of user data.
To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction including, for example, payment processing services.
In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third-party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.
To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
in connection with the establishment, exercise, or defense of legal claims;
to comply with laws or to respond to lawful requests and legal process;
to protect our rights and property and the rights and property of our agents, users, and others, including to enforce our agreements, policies, and terms of service;
to detect, suppress, or prevent fraud;
to reduce credit risk and collect debts owed to us;
to protect the health and safety of us, our users, or any person; or
as otherwise required by applicable law.
With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites.
Your Privacy Choices
The following privacy choices are made available to all individuals with whom we interact. You may also have additional choices regarding your personal data depending on your location or residency. Please refer to our Region-Specific Disclosures below for information about additional privacy choices that may be available to you.
Communication Preferences
Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as account verification, transaction confirmation, or service update emails).
Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu or in the applicable service-specific application. Please note we do not have any control over your device’s notifications settings and are not responsible if they do not function as intended.
Withdrawing Your Consent
Where we have your consent for the processing of your personal data (e.g., when you opt in to receive certain types of marketing communications from us), you may withdraw your consent by following the instructions provided when your consent was requested or by contacting us as set forth in the Contact Us section below.
Automatic Data Collection Preferences
Where an Odyssey-specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.
Modifying or Deleting Your Personal Data
If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us directly at [email protected]. We may not be able to modify or delete your personal data in all circumstances.
Device-Specific / Platform-Specific Preferences
The device and/or platform you use to interact with us (such as your mobile device), may provide you additional choices regarding the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.
Children’s Personal Data
Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.
Retention of Personal Data
We will usually retain the personal data we collect about you for no longer than reasonably necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights.
To determine the appropriate duration of the retention of personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.
Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.
Third-Party Websites and Services
Our services may include links to third-party websites, plug-ins, applications and other services. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy policies.
Region-Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:
European Economic Area, United Kingdom or Switzerland: If you are located in the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), the United Kingdom, or Switzerland, please scroll down for additional European-specific privacy disclosures, including a description of the personal data rights made available to individuals located in those jurisdictions under applicable law.
United States: If you are a resident of the United States, please scroll down for additional U.S.-specific privacy disclosures, including a description of the personal data rights made available to residents of certain states under applicable law.
Updates to This Privacy Policy
We may update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
Contact Us
If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to [email protected].
Additional United States Privacy Disclosures
These disclosures supplement the information contained in our Privacy Policy by providing additional information about our personal data processing practices relating to individual residents of certain states in the United States. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Policy.
If you are a resident of U.S. states that have implemented state privacy laws, the following supplementary disclosures apply to you.
Personal Data Disclosures, Sales and Targeted Advertising
We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Policy. However, we do not sell personal data, and we do not process or otherwise share personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across non-affiliated businesses or websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”).
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below).
Please note we do not sell the personal data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes.
Sensitive Personal Data
The following personal data elements we collect may be classified as “sensitive” under certain privacy laws:
Account log-in information in combination with any required security or access code, password or credentials allowing access to an account.
We use sensitive personal data for the purposes set forth in the Our Collection and Use of Personal Data section of our Privacy Policy.
We do not sell sensitive personal data, and we do not process or otherwise share sensitive personal data for the purpose of targeted advertising. However, depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of sensitive personal data (as described in the Your Additional U.S. Privacy Choices section below).
Deidentified Information
We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
Automated Decision-Making and Profiling
We do not conduct automated processing of personal data for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling.
Your Additional U.S. Privacy Choices
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
Right to Know: The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you, including:
The categories of personal data collected;
The categories of sources of the personal data;
The purposes for which the personal data were collected;
The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed;
The categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes; and
The categories of personal data sold (if any) and the categories of third parties to whom the personal data were sold.
Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
Right to Control Over Sensitive Personal Data: The right to exercise control over our collection and processing of certain sensitive personal data.
Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes.
Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain targeted advertising purposes.
Right to Opt-Out of Sales: The right to direct us not to sell personal data to third parties.
Right to Deletion: The right to have us delete personal data we maintain about you. If you are a resident of the State of California under the age of 18, you may also request and obtain removal of user-generated content you have posted on our platform (though please note that such a request does not ensure complete or comprehensive removal of all user-generated content, particularly where user-generated content has been republished or reposted by another user or third party).
Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
Submitting Privacy Rights Requests
Please submit a request specifying the right you wish to exercise by sending us an email at [email protected].
Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted through our online form and toll-free number to include first and last name, email address, phone number, state of residency and/or the date of your last transaction with us.
In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
Submitting Parental Requests
If you wish to submit a privacy request on behalf of your minor child in accordance with applicable law, you must provide sufficient information to allow us to reasonably verify your child is the person about whom we collected personal data and you are authorized to submit the request on your child’s behalf.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request.
Nevada Residents
If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by emailing [email protected].
California Residents
The following disclosures only apply to residents of the State of California.
California Categories of Personal Data
California law requires we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data categories for the personal data described in the Our Collection and Use of Personal Data section of our Privacy Policy below:
Identifiers, including name, email address, and social media handles.
User records, including Account Information and Community Information.
Internet / network information, including information about your device and network and information about how individuals use our service and interact with us.
Geolocation data, including general geographic information based on photo metadata or manual inputs that you provide to us.
Sensory information, including profile picture.
Professional / employment information, including the business or organization an individual represents, their title with that business or organization and information relating to their role with the business or organization, which we use to communicate with the individual about the business or organization they represent.
Sensitive personal data, including account log-in information in combination with any required security or access code, password or credentials allowing access to an account.
Other Personal Data, including communication preferences, inquiry information, personal information an individual permits us to see when interacting with us through social media, and personal information an individual provides us in relation to a question, request, inquiry, survey, contest or promotion.
Inferences, including our predictions about interests and preferences and related service information.
Additional European Economic Area, United Kingdom and Switzerland Privacy Disclosures
These disclosures supplement the information contained in our Privacy Policy by providing additional information about our personal data processing practices relating to individuals who access our services or otherwise interact with us from the European Economic Area (“EEA”), United Kingdom ("UK"), and Switzerland. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Policy.
Controller Details and Privacy Contacts
EEA, UK, and Swiss Controller
Odyssey Technologies, Inc., a company duly incorporated and organised under the laws of the United States, having its registered address at 91 Red River Street, Austin, TX 78701, USA, is the “controller” responsible for the processing of personal data in connection with our EEA, UK, and Swiss services and operations. This means Odyssey Technologies determines and is responsible for how your personal data is used. You may contact Odyssey Technologies by emailing [email protected].
Additional Questions or Complaints
If you have a concern about our processing of personal data, you have the right to lodge a complaint with the Data Protection Authority where you reside, where you work, or where an alleged violation of the law has occurred. Contact details for applicable Data Protection Authorities can be found using the links below:
European Economic Area: https://edpb.europa.eu/about-edpb/board/members_en
United Kingdom: https://ico.org.uk/global/contact-us/
Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
We would, however, appreciate the chance to handle your concerns directly prior to a complaint being filed, so please email us directly at [email protected] if you have any concerns.
Purposes and Legal Bases of Processing
When we process your personal data, we will do so in reliance on the following lawful bases:
Contract: Where the processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract with you. This applies to any processing where you sign a contract with us, for example when you become a user or deliver services to us as a vendor or contractor. This may also include processing necessary for the performance of our Terms of Service.
Legitimate Interest: Where the processing is necessary for the purposes of a legitimate interest that are not overridden by your interests or fundamental rights and freedoms (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you regarding our services).
Vital Interest: Where the processing is necessary to protect the vital interests of you or another person (e.g., to protect your physical safety).
Public Interest: Where the processing is necessary to perform tasks carried out in the public interest or in the exercise of official authority vested in us (e.g., to cooperate in an ongoing law enforcement investigation).
Legal Obligation: Where the processing is necessary to comply with our legal obligations (e.g., to maintain a record of your personal data to comply with laws and regulations related to bookkeeping, accounting, taxation, and employment).
Consent: Where we have your consent for the processing (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing of your personal data, you may withdraw your consent at any time.
You are not required to provide personal data to us, but we do rely on your personal data to provide certain of our products and services. For example, we need your personal data to facilitate and deliver an order that you request. If you choose not to provide us with your personal data, we may not be able to provide you with a service or product you request. We will inform you at the point that we collect personal data from you if the provision of certain personal data is mandatory or optional for receipt of our products and services.
Automated Decision-Making and Profiling
We do not conduct automated processing of personal data, including profiling, for the purposes of making decisions about you.
International Transfers of Personal Data
We operate and engage third-party partners and providers in various jurisdictions. Therefore, we and our third-party providers may transfer personal data to, or store, access, or process personal data in a country other than the one in which it was collected, including, but not limited to, the United States. The country to which personal data is transferred may not provide the same level of protection for personal data as the country from which it was transferred.
We may transfer personal data about you outside of the EEA, UK, and Switzerland, and when we do so we rely on appropriate or suitable safeguards recognized under applicable law, including adequacy decisions, standard contractual clauses, and the EU-US Data Privacy Framework. If you would like more information on the specific safeguards we use (and obtain a copy of such safeguards, where applicable), please contact us at [email protected].
Adequacy Decisions
We may transfer personal data about you to countries that the relevant regulatory authority has deemed to adequately safeguard personal data, either automatically or in connection with a specific safe harbor framework.
Standard Contractual Clauses
Certain regulatory authorities have adopted standard contractual clauses, which provide safeguards for personal data transferred outside of the originating jurisdiction. We may use these standard contractual clauses when transferring personal data to a third country that has not been deemed to adequately safeguard personal data.
EU-U.S. Data Privacy Framework
The EU-U.S. Data Privacy Framework was designed by the U.S. Department of Commerce and the European Commission to ensure adequate protection for personal data transferred to a company participating in the EU-U.S. Data Privacy Framework. If we transfer any personal data about you from the EEA to a third party outside the EEA who is participating in the EU-U.S. Data Privacy Framework, we may rely on their participation in the Framework to ensure adequate protection for personal data so transferred.
Your Additional EEA, UK, and Swiss Privacy Choices
Subject to certain limitations at law, you may be able to exercise the following rights:
Right to Access: The right to obtain confirmation of whether we are processing personal data about you, access to and a copy of the personal data we are processing about you, and information relating to its processing, including:
The categories of personal data being processed;
The purposes of the processing;
The categories of the sources of the personal data;
The categories of recipients to whom the personal data have been or will be disclosed;
The envisaged period for which the personal data will be stored, or the criteria used to determine that period;
Any automated decision-making or profiling performed in connection with your personal data; and
The safeguards relied upon for the transfer of personal data to any third country.
Right of Portability: The right to obtain a copy of the personal data we have collected about you in a structured, commonly used, and machine-readable format, and the right to transmit that personal data to another controller without hindrance.
Right to Rectification: The right to correct or update any personal data about you that is inaccurate or incomplete.
Right to Restriction of Processing: The right to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
Right to Object to Processing: The right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
Right to Withdraw Consent: The right to withdraw your previously provided consent to our processing of your personal data. Please note withdrawing your consent will not affect the lawfulness of our use of your personal data before your consent was withdrawn, nor our processing of personal data pursuant to a different lawful basis for processing.
Right to Erasure: The right to have us erase your personal data if the continued processing of that personal data is not otherwise justified.
Please note that if the exercise of these rights limits our ability to process personal data, we may not be able to provide our services to you, or otherwise engage with you in the same manner.
Submitting Privacy Rights Requests
Please submit a request specifying the right you wish to exercise by sending us an email at [email protected].
Before processing your request to exercise certain rights (taking into account the confidential nature of any personal data we maintain), we will need to verify your identity and confirm you are accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted through our online form to include first and last name, email address, phone number, state of residency and/or the date of your last transaction with us.
In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity as needed to protect your personal data or locate your information in our systems, or where you are not accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland.