ODEEO PRIVACY POLICY

Last Updated: March 8, 2022 

In order to ensure transparency and give you more control over your personal data, this privacy policy (“Privacy Policy”) governs how we, Sonic Odeeo Ltd. (“Odeeo” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

1. When you browse or visit our website, https://odeeo.io/ (“Website”)
2. When you contact us;
3. When you create an account, log in and make use of our Services (as defined below);
4. When we serve an end user an Ad on the Developer’s game or application;
5. When we use the Personal Data of Advertisers and Developers; 
6. When you attend marketing events and provide us with Personal Data and/or exchange business cards with us; and
7. When we use the Personal Data of our service providers and suppliers; 
8. When we use the Personal Data of Advertiser or Developers; and 
9. When we collect all categories of personal data to comply with a legal obligation to store records of data processing activities.

Odeeo offers specialized and innovative solutions and concepts for audio advertising and audio-based ad platform for games (the “Services”), allowing ad placements by entities or individuals that develop computer games (“Developer”) provided by or on behalf of entities that provide advertisements, including demand side platforms, advertising networks, or other advertising demand sources (collectively, the “Advertiser”).

We greatly respect your privacy, which is why we make every effort to provide you with meaningful information concerning our processing of your Personal Data and about our data protection practices in general. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

Table of contents: 

1. What Information we Collect, Why we Collect it, and How it is Used
2. Grounds of processing
3. Period of Storage of Collected Personal Data
4. How we Protect your Personal Data
5. How we Share your Personal Data
6. Additional Information Regarding Transfers of Personal Data
7. Your Privacy Rights; How to Delete your Account
8. Data Protection Authority
9. Data Protection Officer
10. Use by Children
11. Analytic Tools
12. Specific Provisions Applicable Under California Privacy Law
13. Changes to the Privacy Policy
14. Contact us

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED 

Finally, please note that some of the abovementioned Personal Data can be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Our legal basis in these cases is for compliance with a legal obligation (e.g., fraud detection, security and/or debug). Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data.

2. GROUNDS FOR PROCESSING
   
   2.1 Our grounds for processing your personal data are: 

• your consent; 
• our legitimate interests; 
• performance of a contract; 
• our legal obligations. 
  
  2.2 We do NOT intentionally collect and process sensitive personal data. Please, refrain from sharing your sensitive personal data when you provide information to us through Website, our social media accounts, and email.
  
  2.3 We collect and process your personal data in accordance with the provisions of the GDPR
  
  GDPR provides an exclusive list of lawful bases allowing us to process the personal data. During the personal data processing we rely only on four of them, namely:

Article 6.1(a): consent

We collect the information you choose to give us, and we process it under your consent. We require the minimum amount of your personal data that is necessary to send you customized advertisements or conduct our marketing campaigns; to serve our Ads on the Developer’s game or application (in this case, the obligation to obtain consent is delegated to Developer) and to establish a business connection. You may withdraw your consent to the processing of your personal data at any time. Please remember that the withdrawal of consent does NOT automatically mean that the processing before the withdrawal is considered unlawful. You may NOT withdraw your consent to the processing of your personal data on a basis of the performance of a contract between you and Company or on a basis of Company’s legitimate interests.

You may withdraw the consent to the processing of your personal data by sending us an email at privacy@odeeo.io, via Contact Us form, or by contacting us in any other way convenient for you.

Article 6.1(b): performance of a contract
When you provide us with the personal data during the registration of the account on the Website, this can be deemed as your request to form a contract or to perform a contract between you and us. However, we may ask you to give us clear consent in case of doubt.

Article 6.1(c): legal obligation

We process your personal data to fulfil the applicable legal obligations arising mainly under the GDPR. If you send us the request to fulfil the rights granted by the GDPR, we may ask you for some personal data we already have to identify you and achieve compliance with the applicable law.

Article 6.1(f): legitimate interests

We process your personal data to prevent any fraudulent actions and to provide you and other users with the desired services. Also, we need some data to enable our Website to run smoothly and give you and other users a pleasant user experience. We use only strictly necessary data under this legal ground.

3. PERIOD OF STORAGE OF COLLECTED PERSONAL DATA 
   
   3.1 Personal Data. Your Personal Data will be stored until we: (i) no longer need the information and proactively delete it; or (ii) you send a valid deletion request.  Please note that we may retain it for a longer or shorter period in accordance with data retention laws. 
   
   3.2 Retention of your Personal Data. In addition to the retention periods mentioned in this section, in some circumstances, we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. 

3.3 Website cookies. We store identifiers and usage data for the period specified in our Cookie Policy.

4. HOW WE PROTECT YOUR PERSONAL DATA 

We have implemented appropriate technical, organizational, and security measures designed to protect your Personal Data. As the security of information depends in part on the security of the computer, device, or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information. We regularly review our security procedures and policies to consider appropriate new technology and methods.

5. HOW WE SHARE YOUR PERSONAL DATA 
   
   5.1 With service providers that assist us in providing the Website and the Services, such as AWS;
   
   5.2 Where you have provided your consent to us sharing the Personal Data with Advertisers (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality);
   
   5.3 With regulators, to comply with all applicable laws, regulations, and rules, and requests of law enforcement, regulatory, and other governmental agencies or if required to do so by court order;
   
   5.4 To the extent necessary, to our employees, contractors, legal advisors, law enforcement, or governmental agencies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, or to comply with a legal obligation; and/or
   
   5.5 If in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events;

If you want to receive the list of the current recipients of your Personal Data, please contact us at privacy@odeeo.io.

We only transfer your personal data to third parties according to the requirements of GDPR. Where possible, we always enter into data processing agreements (DPAs) and Non-Disclosure Agreements (NDAs) with our third parties. We may disclose the personal data to third parties, including those located outside the EU and EEA, provided that proper safeguards are put in place and the applicable local laws do not put your rights at risk.

6. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

6.1 For transfers to countries that do not fall under requirements of Article 45 of the GDPR on the adequacy of the level of protection, we may transfer your personal data to the third countries outside the EU and the EEA, including the onward transfers of the personal data from the third countries to other third countries, under Article 46 of the GDPR with the appropriate safeguards, including the SCC.

6.2 We disclose your personal data to the countries outside the EU and the EEA, in compliance with the SCC approved by the European Commission in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of natural and legal persons. We put supplementary technical and organizational measures in place when transferring data outside the EU and the EEA. e.g., prior assessment of the service supplier’s reliability and personal data protection practices, encryption of the transferred personal data, prompt reacting to any threats to confidentiality, integrity, and availability of the personal data, etc. 

7. YOUR PRIVACY RIGHTS; HOW TO DELETE YOUR ACCOUNT
   
   7.1 EU Residents: If our processing of your Personal Data is subject to GDPR, you are entitled to the following rights (which may be subject to certain exemptions or derogations):

• You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge; however, we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
• You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
• You have the right to request the erasure/deletion of your Personal Data (e.g., from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise, or defense of legal claims;
• You have the right to object, to or to request restriction, of the processing;
• You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;
• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular, if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
• You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

7.2 You can exercise your rights by contacting us at privacy@odeeo.io. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

7.3 Deleting your account: Should you ever decide to delete your account, you may do so by emailing: privacy@odeeo.io. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account.

8. DATA PROTECTION AUTHORITY

8.1 We kindly invite you to share your concerns with us in the first place regarding any issue related to your personal data processing. You may use the following channels to address your inquiries: privacy@odeeo.io

In some cases, you have the right to lodge a complaint about our use of your personal data with a data protection authority. For more information, please contact your national data protection authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us.

8.2 In case of any questions regarding data protection, you can apply to the Supervisory Authority. You can find the full list of EU supervisory authorities through the link.

9. DATA PROTECTION OFFICE
   
   We designated a Data Protection Officer (“DPO”) in order to ensure that our Company processes personal data in compliance with the applicable data protection rules and regulations. You can contact the DPO directly using the following details:External Data Protection Officer

Legal IT Group LLC
Office 1, 38 Volodymyrska Str.
01030 Kyiv, Ukraine
Email:  privacy@odeeo.io

10. USE BY CHILDREN 
    
    10.1 Odeeo complies with the requirements under applicable privacy regulations, including, COPPA and GDPR, but does not knowingly collect any Personal Data connected to Children. When Odeeo controls the Personal Data of such children, Odeeo delegates Odeeo’s obligations regarding consent to the Developer. For any privacy/related questions and or to obtain more information you should contact the Developer.
    
    10.2 If you learn that a child has provided us with personal information without verifiable parental consent, we will take steps to delete the information and terminate their account if any. If you become aware that a child has provided us with personal information without parental consent, please contact us by email at privacy@odeeo.io.
    
    10.3 Note that COPPA only covers personal information collected online from children. It does not cover personal information collected from parents, grandparents, teachers, coaches, schools, kindergartens, and other corporate clients that may pertain to children. Please consider other applicable laws and regulations regarding the protection of children if you pass children’s personal information to us.
    

11. ANALYTIC TOOLS

Odeeo uses in its Website the following tools: 

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about the use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. 

We reserve the right to remove or add new analytic tools.

12. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
    
    12.1 Under the California Consumer Privacy Act (the “CCPA”), California residents have certain rights regarding our collection, use, and sharing of their personal information.
    
    We may collect various categories of personal information when you use and/or access our Website and Services, including information you provide when you create an account, usage data (regarding your interactions with our Services), payment information, and other data you may possibly provide to us.

In particular, we may collect the following categories of personal information specified in the CCPA when you use and/or access Website and/or our Services: 

Category A – Identifiers; 

Category B – Personal information categories listed in the Cal. Civ. Code § 1798.80(e); 

Category C – Protected classification characteristics under California or federal law; 

Category F – Internet or other similar network activity; 

Category G – Geolocation data; 

Category H – Audio, electronic, visual, thermal, olfactory, or similar information;

Category I – Professional or employment-related information. 

You can find a detailed description of the personal information that we may collect from you above in Section 1 (What Information we Collect, Why we Collect it, and How it is Used). Note that in Section 5 (How we Share your Personal Data) you can review the categories of third parties with whom we may share your personal information. 

12.2 If you are a California resident, to the extent provided for by the CCPA and subject to applicable exception, you have the following rights in relation to the personal information we have about you: 

• Right to obtain information. You can request information about what personal information has been collected about you and how we have used that personal information during the preceding 12 months. 
• Right of access. You can request a copy of the personal information that we have collected about you during the preceding 12 months. 
• Right to deletion. You can request us to delete the personal information that we have collected from you unless it is necessary for us to maintain your personal information in certain cases under the CCPA, such as protection against malicious, deceptive, fraudulent, or illegal activity. 
• Right to be free from discrimination relating to the exercise of any of your privacy rights. 

We do not sell your personal information to third parties for monetary or other valuable considerations. Additionally, we do not offer any financial incentives associated with our collection, sharing, or retention of your personal information. We take the protection of your privacy seriously, so in no way will we discriminate against you for exercising any of your rights granted by the CCPA. You can exercise your rights under the CCPA by sending us an email at privacy@odeeo.io or by any other means of communications convenient for you. 

Please, note that we may need to confirm your identity to process your requests to exercise your rights under the CCPA. Thus, we may not be able to satisfy your request if you do not provide us with sufficient detail to allow us to verify your identity and respond to your request

12.3 We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personal information, subject to applicable law, about an individual consumer’s online activities over time and across different websites when a consumer uses the Services.

13. CHANGES TO THE PRIVACY POLICY
    
    This Policy may be changed from time to time due to the implementation of new technologies, laws’ requirements, or for other purposes. We will send notice to you if these changes are dramatic and where required by applicable laws, we will obtain your consent. Also, we encourage you to regularly review this Policy to check for any changes.

14. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at: privacy@odeeo.io