Privacy Policy

Last updated: November 28, 2023

Owner and Data Controller

Odo Labs, Inc.
2752 Clay Street, Apartment 402,
Denver, CO 80211

Owner contact email: privacy@odo.do

Definitions and Legal References

DEFINITIONS

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Odo. The Data Controller, unless otherwise specified, is the Owner of Odo.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Subject

The natural person to whom the Personal Data refers.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Odo (or this Application)

The means by which the Personal Data of the User is collected and processed.

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Service

The service provided by Odo as described in the relative terms (if available) and on this site/application.

Tracker

Tracker indicates any technology - e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Usage Data

Information collected automatically through Odo (or third-party services employed in Odo), which can include: the IP addresses or domain names of the computers utilized by the Users who use Odo, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using Odo who, unless otherwise specified, coincides with the Data Subject.

LEGAL INFORMATION

This privacy policy relates solely to Odo, if not stated otherwise within this document.

Types of Data collected

Among the types of Personal Data that Odo collects, by itself or through third parties, there are: Usage Data; email address; company name; first name; last name.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Odo.

Unless specified otherwise, all Data requested by Odo is mandatory and failure to provide this Data may make it impossible for Odo to provide its services. In cases where Odo specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by Odo or by the owners of third-party services used by Odo serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Odo and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

METHODS OF PROCESSING

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Odo (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

LEGAL BASIS OF PROCESSING

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

PLACE

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

RETENTION TIME

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Displaying content from external platforms, Platform services and hosting, Managing data collection and online surveys, Analytics, Tag Management, Handling payments, Hosting and backend infrastructure, Contacting the User, Infrastructure monitoring, Managing contacts and sending messages and Beta Testing.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

CONTACTING THE USER

Mailing list or newsletter (Odo)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Odo. Your email address might also be added to this list as a result of signing up to Odo or after making a purchase.

Personal Data processed: email address; first name; last name.

Squarespace

Squarespace is a website building and hosting company.

Personal Data processed: email address; first name; last name.

HOSTING AND BACKEND INFRASTRUCTURE

This type of service has the purpose of hosting Data and files that enable Odo to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Odo.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Akamai

Akamai is a hosting backend service.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

MANAGING CONTACTS AND SENDING MESSAGES

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Amazon Simple Email Service (SES)

Amazon Simple Email Service (SES) is an email sender service provided by Amazon Web Services, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

HOW TO EXERCISE THESE RIGHTS

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

LEGAL ACTION

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Odo or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

SYSTEM LOGS AND MAINTENANCE

For operation and maintenance purposes, Odo and any third-party services may collect files that record interaction with Odo (System logs) use other Personal Data (such as the IP Address) for this purpose.

INFORMATION NOT CONTAINED IN THIS POLICY

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

CHANGES TO THIS PRIVACY POLICY

The Owner reserves the right to modify this Privacy Policy at any time. If the Owner makes material changes to this Privacy Policy, the Owner will notify Users by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, Users' use of the Service after the effective date of any modified Privacy Policy indicates Users' acknowledgment that the modified Privacy Policy applies to Users' interactions with the Service and our business.

Users under 18

The Service is not intended for use by anyone under 18 years of age, particularly children under 13 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child under 18 years of age without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.