Privacy policy - Ode Partners

Ode (“Ode Partners,” “we,” “us,” or “our”) recognizes the importance of your privacy and the need to protect information that users of our website, located at www.ode.partners (the “Website”), provide to us. This Privacy Policy explains our data collection practices, how we may use and disclose that information, the steps we take to keep it secure, your choices regarding our use of this information, and how you can contact us if you have any questions about our privacy practices. We will refer to the personal information we obtain about you as “Your Data.” Please read our complete Privacy Policy. By visiting www.ode.partners, you accept the practices described in this Privacy Policy. 

Ode will occasionally update this Privacy Policy. When we do, we will also revise the “Last Update” date at the top of this Privacy Policy.

Information you provide to us. We collect information from and about you directly when you provide it to us. This information may be collected when you contact us, fill out a form, access or participate on our Website, respond to surveys, or otherwise interact with us, such as through social media or networking sites. This information may include: 

• Contact information, such as your name, title, phone number, organization or employer, job title, work sector, physical address, and e-mail address;
• Comments, questions, and requests you may make; 
• Information about your preferences, such as your preferred methods of communication and the types of information in which you are interested; 
• Details of downloads from our Website; 
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us; and 
• Any other information you voluntarily provide.

Information we collect automatically. Like most online services, we automatically receive standard technical information when you use the Website. We collect this information through browser cookies, pixel tags, web server logs, web beacons, embedded scripts, and similar technologies. These features enable us to personalize your experience on the Website, understand how you use it, maintain a persistent session, and improve and further develop the Website. We collect this information as follows:
 

• Web server cookies: A cookie is a small piece of information that is sent by our web server, stored on your PC’s hard drive, and used by your web browser to “remember” information about your visit. We use cookies to help us collect information and to enhance your experience using the Website. Specifically, we use cookies to authenticate users, personalize your experience when using the Website, analyze which features of the Website you use most frequently, and measure and optimize advertising and promotional effectiveness. To do this, we may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your internet browser’s documentation for information on how to do this. However, if you decide not to accept cookies from us, certain features of the Website may not be fully available.
• Pixel Tags: Certain websites contain electronic images known as pixel tags (also called web beacons or gifs) that we use to help deliver and recognize cookies on our Website, count users who have visited those sites, and gather usage and performance data. We also include pixels in our emails to tell if you open and act on them.
• Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Website, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Website, and is deactivated or deleted thereafter.
• Log files: Like most standard website servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses etc. are tied to personally identifiable information to enable our web-based service.
• Device information: We collect information about the device you use to access or use the Website, including the hardware model, operating system and version, unique device identifiers, network information, and information about your use of our applications.
• Geolocation information: We may automatically collect geolocation information from your device, your wireless carrier, or certain third-party service providers (“ Geolocation Information ”). You may control the collection of Geolocation Information through the user settings on your device. You may decline to allow us to collect such Geolocation Information, in which case we may not be able to provide certain services to you. 

Information we collect from other sources, including our social media pages
We may collect personal information from users and visitors of other sites on which you have interacted with us. We will do so in accordance with the terms of use and privacy policies of those sites and applicable law. This includes our social media pages on places like Facebook, Instagram, TikTok, YouTube and Twitter. For example, we may collect the information you shared on our social media pages through an application or form, which will have a link to this Privacy Policy. We may also receive personal information when you comment on our social media advertisements, post comments about us, or tag Ode in a public-facing social media post. Personal information may also be collected by the third-party social media sites that host our social media pages. These sites may provide aggregate information and analysis to us about visitors' use of our social media pages. This allows us to better understand and analyze our user growth, general demographic information about the users of these pages, and interaction with the content that we post. Overall, this information may be used to help us understand the types of visitors and users of our social media pages and use of the content. This Privacy Policy does not cover personal information collected by such third-party social media sites. For more information on their privacy and security practices please review the privacy policies and terms of use on their respective websites.

Information we collect through third-party data and analytics providers.
We use third-party data and analytics services (including as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, enhance our data with other information about our users, analyze performance metrics, and collect and evaluate other information relating to the Website and internet usage. These third parties use cookies and other technologies to help analyze and provide us the data, and may also collect information regarding your use of other websites, apps, and online resources, and across your electronic devices. We may also receive information about you from our marketing partners, including data brokers, such as ad campaign information (e.g., the ads you click on) or the social media platforms you use. These third-party services may also provide us with information based on inferences to better understand our users (see below). The information used by such services is usually at the aggregate level, but may contain identifiable personal information.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website.

Tracking data. We collect tracking data using first and third-party cookies, pixels, web server logs, web beacons, and similar data collection and tracking technologies on the Website, third party websites, apps and online services, and across your devices (such as IP address, browser, type, ISP, platform type, device type). Third parties such as advertising networks and analytics providers may also collect information about your online activities over time and across different websites and devices when you access or use the Website.

We use Your Data to provide the Website to you, and to operate our business. This includes:

• Service-related usage: We use Your Data to provide and support the Website, such as communicating with you and other users, providing our services, informing you about our work, processing your requests, and maintaining our systems.
• Analyzing and improving our services: We may run calculations, aggregate, normalize, clean, enhance, and make derivative works of the information obtained about you in order to:
• Understand and analyze usage trends and preferences;
• Monitor and analyze the effectiveness of the Website;
• Improve the Website and develop new products, services, features, and functionalities; and
• Test the Website and our infrastructure to make sure the Website is working correctly.
• Marketing:If you enter your contact information on the Website and opt-in to receive electronic marketing communications from us, we may provide you with materials that could be useful, relevant, valuable, or otherwise of interest to you, such as our newsletter, and updates about services and products offered by us. We will not send you marketing emails if you have not signed up for this, and you can unsubscribe from receiving such emails at any time by clicking on the “unsubscribe” link at the bottom of all our marketing emails. You will continue to receive other correspondence that relates to requests for downloads or other orders you have placed with Ode.
• Advertising: Ode, its business partners, and advertising/marketing companies may use Your Data to tailor, analyze, manage, report and optimize advertising you see on the Website, and on other sites and apps that you access and/or use through your devices. By accessing and using the Website, you consent to the processing of Your Data for these purposes.

We may share, transfer, or disclose Your Data if you ask us to do so, as well as in the following circumstances. We will take reasonable measures to require that any party receiving any of your personal information from us undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose your personal information except with your consent, as permitted by law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of your personal information.

• To assist us in running our business and providing services to you
  We may employ other companies and individuals to perform functions on our behalf, such as website hosting, data analysis and enhancement, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, and email delivery. Ode thus may reveal user data to third parties including third-party affiliates, our sales representatives, and business partners that may require information to invoice for a product purchased through our Website. Additionally, we may use third-party credit card processing companies to bill users for goods and services. These other companies will have access to Your Data only as necessary to perform their functions and to the extent permitted by law.

• To better understand and serve our users. In an ongoing effort to better understand our users, we might analyze Your Data in aggregate form in order to operate, maintain, manage, and improve the Website. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes. 

• For advertising and marketing purposes. We may share information about your activity in connection with your use of the Website, including tracking data, with third-party advertisers and remarketers to serve advertisements on our behalf across the internet and for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Website and elsewhere on the web. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Website and other sites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Website and other sites, and better understand your online activity. By accessing and using the Website, you consent to the processing of data about you by these advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Policy. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.
  We may also work with third-party social media sites, such as Facebook, Google, and other media platforms, to serve ads to you as part of a customized campaign, unless you notify us that you prefer not to have information about you used in this way. For more information about how you can opt out of customized campaigns, please see “Your Choices” below.

• As part of a change of our organization. As we grow and develop our organization, we might share Your Data with other organizations we join, merge with, or in other forms cooperate with.

• For legal purposes. To the extent permitted by law, we may also disclose Your Data when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of Ode or others.

Ode takes children’s privacy seriously. We do not seek to collect personal information about children under the age of 13 through our Website. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children to never provide us personal information without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will promptly take steps to delete such information and terminate the child’s account.

The Website may contain links to third-party websites. Ode has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites. 

Please be advised that your use of third-party payment processors is subject to the terms and conditions, including the privacy policies, of those companies. By using these services, you accept the their terms of service, which can be found here:

Google Pay:https://payments.developers.google.com/terms/sellertos
PayPal:https://www.paypal.com/us/webapps/mpp/ua/legalhub-full 
Shop Pay:https://shop.app/terms-of-service 
Meta Pay:https://www.metapay.com/terms-of-use/ 

We take commercially reasonable steps to protect Your Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

• Deletion of Information. If you would like us to delete any or all information, please email us at info@ode.partners. To the extent compatible with our legal or regulatory record keeping requirements, we will use commercially reasonable efforts to process such requests in a timely manner.
• Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Website.
• Promotional Communications. You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at info@ode.partners. Please note that you cannot opt out of receiving transactional e-mails related to your orders. 

As discussed above, third parties such as advertising networks and analytics providers may collect information about your online activities over time and across different websites when you access or use the Website. Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. At this time, we do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Pursuant to California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. 
To make such a request, please send an email to info@ode.partners. Please note, however, that we have never shared any personal information for a third party’s direct marketing purposes.

If you are a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. You can exercise this right by contacting us at info@ode.partners with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note, however, that we do not sell personal information to third parties.

If you are an individual located in the European Economic Area, the United Kingdom or Switzerland, please review our GDPR Privacy Notice (below) for further information regarding the processing of your personal data and your rights under the General Data Protection Regulation (2016/679).

The Website is hosted in and provided from the United States and is intended for visitors located within the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Website, you consent to any transfer and processing of your personal information in accordance with this Privacy Policy, and you do so at your own risk.

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our privacy practices. We will indicate at the top of this Privacy Policy when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. By accessing the Website after we notify you of changes to this Privacy Policy, you are deemed to have accepted such changes. 

If you are located in the European Union (EU), United Kingdom, Lichtenstein, Norway, or Iceland (“European Individuals”), you may have additional rights with respect to your Personal Data under the General Data Protection Regulation (“EU GDPR”), and/or the EU GDPR as saved into United Kingdom law by the United Kingdom's European Union (Withdrawal) Act 2018 (“UK GDPR”) (collectively with the EU GDPR, the “GDPR”), as set forth in this GDPR Notice (the “GDPR Notice”).

In this GDPR Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to identify a person, and “processing” generally refers to actions that can be performed on data such as its collection, use, storage or disclosure. Ode will usually be the controller of your Personal Data processed in connection with the Services. 

Where applicable, this GDPR Notice is intended to supplement, and not replace, our Privacy Policy (above). If there are any conflicts between the GDPR Notice and the other parts of the Privacy Policy, and you are located in the EU, United Kingdom, Lichtenstein, Norway, or Iceland, the provision that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this GDPR Notice or whether any of the following rights apply to you, please contact us at info@ode.partners with the subject line “GDPR Request.”

We currently collect and otherwise process the categories of Personal Data listed in Section 2 of the Privacy Policy.

We collect and/or receive the Personal Data in the ways listed in Section 2 of the Privacy Policy.

We collect and/or receive the Personal Data for the purposes listed in Section 3 of the Privacy Policy. We will only process your Personal Data if we have a lawful basis for doing so. Under the GDPR, the lawful bases we rely on for processing this information are:

1. Your Consent. In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. You can remove your consent at any time. You can do this by contacting us via email at info@ode.partners with the subject line “GDPR Request.”
2. We Have a Contractual Obligation. We process certain categories of Personal Data as a matter of “contractual necessity,” meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Website and other services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Website or services that require such data. These categories of Personal Data are: Contact information; and Any other information you voluntarily provide to us to request our services or communicate with us.
3.  We Have a Legitimate Interest. We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
   • Contact information;
   • Any other information you voluntarily provide; and
   • Automatically collected information about your use of our Website and other interactions with us (including log files, device information, geolocation, tracking data, performance metrics, etc.).
   • Our legitimate interests are:
   • Information Security: We process contact information and automatically collected information in order to maintain an audit log of activities performed. We use this information pursuant to our legitimate interests in tracking usage, combating DDOS or other attacks, and removing or defending against malicious individuals or programs. 
   • Operation and Improvement of our Website and Services: We process automatically collected information pursuant to our legitimate interest in operating and improving our Website and services. 
   • Audience Measurement and Marketing: Pursuant to a user’s consent, we use analytics and targeting cookies, and collect identifiers through such cookies, for purposes of audience measurement, analytics, audience reaction to our Website, creating relevant user experiences, and targeted marketing by us and other third parties.
   • General Business Development and Management: We process contact information and other information you voluntarily provide pursuant to our legitimate interest in creating and managing our relationships with European Individuals, including without limitation:
   • To respond to inquiries from European Individuals; 
   • To provide European Individuals with information about our products and services; and
   • To assist European Individuals with any issues while using the Website or our services.
   • Direct Marketing: Generally, we send email marketing to European Individuals pursuant to their consent. When you use the Website, email marketing may be sent to you pursuant to our legitimate interest in sending marketing communications to you in the context of such engagement.
   • Protection of Rights: We may disclose any categories of Personal Data to respond to claims of violation of third party rights or to enforce and protect our rights
4. We Have a Legal Obligation

• We may be required to disclose Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose Personal Data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Section 4 of the Privacy Policy explains how we share your Personal Data with third parties.

We use commercially reasonable administrative, technical, and physical safeguards to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, for which we take into account the nature of the Personal Data, its processing, and the threats posed to it. Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us via email at info@ode.partners with the subject line “GDPR Request.”

We retain your Personal Data for as long as needed to fulfill the purposes for which we obtained it, as further described in this Privacy Policy. We will only keep your Personal Data for as long as allowed or required by law.

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at info@ode.partners with the subject line “GDPR Request.” You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Right of access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. 
Right to rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. 

Right to erasure: You can request that we erase some or all of your Personal Data from our systems. 

Right to restriction of processing: You have the right to ask us to restrict the processing of your Personal Data. 

Right to object to processing: You have the the right to object to the processing of your Personal Data in certain circumstances.

Right to data portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

Right to withdraw consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Objecting to Legitimate Interest/Direct Marketing: You may object to Personal Data processed pursuant to our legitimate interest. In such case, we will no longer process your Personal Data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your Personal Data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to info@ode.partners with the subject line “GDPR Request.” In such case, your Personal Data will no longer be used for that purpose.
We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Please note that all of these rights are subject to applicable exemptions and restrictions, and are not absolute rights. If we need to rely on these exemptions or restrictions, we will provide this information to you in our response. 

If you have any concerns about our use of your Personal Data, you can make a complaint to us at info@ode.partners with the subject line “GDPR Request.”
You also have the right to lodge a complaint about the processing of your personal data with a supervisory authority of the European state where you work or live or where any alleged infringement of data protection laws occurred. A list of most of the supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

As we grow and develop our organization, as well as in the event of a merger, reorganization, dissolution, or similar corporate event, or the sale of all or substantially all of our assets, the information that we have collected, including Personal Data, may be transferred to the organization we join, merge with, or in other forms cooperate with, or the surviving or acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such Personal Data as set forth in this GDPR Notice. 

If, in the future, we intend to process your Personal Data for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately within this GDPR Notice, and the “Last Update” at the top of this page will be updated accordingly.