Sonic ODEEO Ltd. PRIVACY POLICY

Last Updated: February 2021

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:

  • When you browse or visit our website, https://odeeo.io/ (“Website”)
  • When you contact us via our Website:
  • When you create an account, log in and make use of our Services (as defined below);
  • When we serve an end user an Ad on the Developer’s game or application;
  • When we use the Personal Data of Advertisers and Developers;
  • When you attend a marketing events and provide us with Personal Data and/or exchange business cards with us; and
  • When we use the Personal Data of our service providers and suppliers;

Odeeo Ltd. offers specialized and innovative solutions and concepts for audio advertising and audio based ad platform for games (the “Services”), allowing ad placements by entity 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:

  • What Information we Collect, Why we Collect it, and How it is Used.
  • Period of Storage of Collected Personal Data.
  • How we Protect your Personal Data
  • How we Share your Personal Data
  • Additional Information Regarding Transfers of Personal Data
  • Your Privacy Rights; How to Delete your Account
  • Use by Children
  • Analytic Tools
  • Specific Provisions Applicable Under California Privacy Law
  • 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.

  • WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

When you browse or visit our Website

Data we collect Why is the Personal Data collected and for what purposes?Legal basis (GDPR only, if applicable)
Internet and other electronic network
information, such as cookies, analytic tools
and log files
For more information, please read our cookies policy
  • For the Website to function properly
  • To analyze and improve the Website
  • For debugging and to resolve technical problems
  • To improve user experience
  • To engage in internet-based advertising
Consent Legitimate interest (e.g., to improve your user experience)

When you contact us

  • Full Name
  • Email Address
  • Phone Number
  • Company name and address
  • any additional information you choose
  • To process and answer questions; and
  • To provide support.
Legitimate interest (e.g., to respond to your questions).
  • Full Name
  • Email Address
  • Phone Number
  • Company name and address
  • To send you marketing communication
Consent

When you create an account, log in and make use of the Services for its intended use

Personal identifiers and internet and other electronic network information, such as:
  • Full Name
  • Email Address
  • Phone Number
  • Company name and address
  • To allow you to create an account and log in;
  • To perform/execute the agreement; and
  • To grant you access to the Services
Processing is necessary for the performance of a contract to which our customer is a party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to allow you to create an account

When you create an account, log in and make use of the Services for its intended use

Internet and other electronic network activity information, including:
  • IP address (country)
  • User ID
  • User agent
  • Geo location
  • Select and serve personalized ads when the end user makes use of the Developer’s game or application;
  • Measure ad performance;
  • Apply market research to generate audience insights;
  • Ensure security, prevent fraud, and debug;
  • Match and combine offline data sources; and
  • To develop, update, fix and improve our products and Services.
When we are a separate data controller, we obtain consent through the Developer of the applicable game or application

When you create an account, log in and make use of the Services for its intended use

  • Full Name
  • Email Address
  • Phone Number
  • Company name
  • Job Position
  • Phone Number
  • Any other data you decide to provide/suppy us with
  • To establish a business connection
  • To send marketing communications
Consent
Legitimate interest (e.g. send you more information about Odeeo)

When we use the Personal Data of our service providers and suppliers

  • Full Name
  • Email Address
  • Phone Number
  • Company name
  • Job Position
  • Phone Number
  • Any other data you decide to provide/suppy us with
  • To contact our service providers
  • To perform the applicable agreement
  • To communicate with you (e.g., service-related communications)
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legitimate interest (e.g. perform the contract, send contract-related communications)

When we use the Personal Data of Advertiser or Developers

Personal identifiers and customer records information, including:
  • Full Name
  • Email Address
  • Phone Number
  • Company name
  • Job Position
  • Phone Number
  • Payment information (i.e. bank account number and/or credit card details
  • Any other data you decide to provide/suppy us with
  • To provide our products and services
  • To contact our Advertiser
  • To perform the applicable agreement
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legitimate interest (e.g. perform the contract, send contract-related communications)
  • Full Name
  • Email Address
  • Phone Number
  • Company name
To send you marketing communication Consent

Finally, please note that some of the abovementioned Personal Data will 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.

  • PERIOD OF STORAGE OF COLLECTED PERSONAL DATA

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.
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.
Website cookies. Regarding retention of cookies, you can read more in our cookie policy 

  • HOW WE PROTECT YOUR PERSONAL DATA

Security. 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.

  • HOW WE SHARE YOUR PERSONAL DATA

Security. 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.

  • With service providers that assist us in providing the Website and the Services, such as AWS;
  • 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). A list of those Advertisers can be found here 
  • 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;
  • To the extent necessary, to our 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;
  • 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 make your request by contacting us to info@odeeo.io.
  • ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
  • Internal Transfers: We ensure transfers with the affiliated companies of Odeeo will be covered by an agreement to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
  • External transfers: Where we transfer Personal Data outside of the EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Data.
  • YOUR PRIVACY RIGHTS; HOW TO DELETE YOUR ACCOUNT
  • 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.

You can exercise your rights by contacting us at info@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 initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

  • Deleting your account: Should you ever decide to delete your account, you may do so by emailing: info@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.
  • USE BY CHILDREN

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 question and or to obtain more information you should contact the Developer.

  • ANALYTIC TOOLS

Odeeo uses in its Website the following tools.


Google Analytics. The Website uses a tool called “Google Analytics” to collect information about 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.

  • SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
  • Access Requests. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an email to info@marketman.com. Please note that we are only required to respond to one request per customer each year.
  • Our California Do Not Track Notice. 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 web sites when a consumer uses the Services.
  • 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: info@odeeo.io.