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PRIVACY POLICY

Odatone respects your privacy. This Privacy Statement describes your privacy rights and
our obligation to secure your personal data.

Odatone is a European company with legal entities, business processes, management
structures and technical systems across borders. Odatone provides software and services
to private companies (Customers) in Europe. Odatone's head office is located 83 Roberts
Road, Colchester, Essex, CO2 7FQ in United Kingdom, and Odatone is subject to European
Personal Data Law, including the General Data Protection Regulation (GDPR).

SCOPE AND ACCEPTANCE

This Privacy Statement applies to all business processes and to all Odatone websites,
domains, mobile solutions, cloud services and communities, and Odatone branded
websites. Service-specific supplements can be found in Odatone Terms, Data Processing
Agreements or equivalent information for that specific service.

The Privacy Statement provides information about the data processing carried out by
Odatone when Odatonedetermines for what purpose and assistive means the processing is
carried out (Odatone acts as controller). It also provides information about the data
processing that Odatone performs on behalf of our Customers based on their instructions
(Customer as Data Controller and Odatone as Data Processor).

Personal data is information that can identify you as a person, such as email address, postal
address or telephone number, etc. It is necessary for us to process your personal data in
order to serve our Customers. Please do not use Odatone Pages or our Mobile App if you
are unable to accept the way we process personal data under this Privacy Statement.

ODATONE AS A DATA CONTROLLER

Odatone acts as a data controller in scenarios where Odatone collects personal data, in the
context of you being a representative of a Customer or a Level, or when you are a software
user.

WHY WE PROCESS PERSONAL DATA ABOUT CUSTOMER CONTACTS AND
SOFTWARE USERS

In order to generally manage our Customer Relations and to meet our Customer obligations,
Odatone needs information about you in your role as a Customer Contact or User of a
Service. The purposes of processing this personal data are:
● (a) to carry out the sales and contract process to Customers
● (b) provide the requested offers of products and services to Customers
● (c) to complete deliveries in accordance with agreements concluded with you or
Customers
● (d) to offer support to users of our products and services
● (e) improve and develop the quality, functionality and user experience of our
products, services and Odatone Pages
● (f) detect, limit and prevent security threats and carry out maintenance,
troubleshooting and debugging
● (g) prevent misuse of our products and services;
● (h) process orders, invoicing, payments and other financial follow-up
● (i) to create interest profiles to promote relevant products and services;

The legal basis for processing personal data according to the purposes stated above in letter
(a) to (i) is primarily based on the fact that from a business perspective Odatone has a
legitimate interest in processing your personal data in a manner which, in our opinion, is not
in conflict with your rights regarding privacy and self-determination.

ABOUT LEADS

Odatone processes personal data on Leads for marketing purposes. In order to deliver
targeted and relevant content to potential Customers, Odatone builds an interest profile
based on your activity and choices and actions on Odatone Pages as well as your response
to marketing content by email. The legal basis for such processing is primarily your consent.

ABOUT SOFTWARE USER

You are a Software user when you, as a registered user, use Odatone or Odatone Mobile
App. The legal basis for such processing is your consent.

HOW WE COLLECT YOUR PERSONAL DATA

Generally, Odatone collects personal data directly from you or other persons associated
with our Customer. These individuals can be a manager or colleague.

We also use cookies and other tracking technologies when you use Odatone Pages or
Odatone Mobile App and when you interact with us by email to optimize your experience of
Odatone and our sites. Please refer to the 'Automatic Data Collection Tools' section for more
information on how these technologies work and your rights in this context.

In some cases, we may also collect information about you from other sources. These
sources may be Odatone's marketing partners, public sources or third-party social networks.
Odatone will be able to combine personal data about you collected from one source with
information obtained from another source. This gives us a more complete picture of you,
which also allows us to serve you in a more relevant way with a higher level of
personalization.

WHAT PERSONAL DATA WE PROCESS

The type of personal data Odatone processes about you may be:

● Basic contact information, such as name, address, phone number and email
● Feedback, comments or questions regarding Odatone or our products and services
● Usage Patterns in Listening Behavior.
● Unique user information, such as login ID, username, password and security
questions
● Financial information, such as credit card information
● ClickStream behavior and activity on Odatone Pages and in our products and
services
● Email behavior, such as which emails from Odatone you open when and how
● Other personal data contained in your profile that you have freely provided on
third-party social networks, such as LinkedIn etc.

As a data controller, Odatone does not process sensitive personal data about you.

HOW WE SHARE YOUR PERSONAL DATA

Odatone may share your personal data with external third parties in the following contexts:

BUSINESS PARTNERS

Odatone may share your personal information with our partners if this is legitimate from a
business perspective and is in accordance with applicable data protection laws. For
example, if you purchase, on behalf of your employer, a product or service that Odatone
provides through one of our certified partners.

PUBLIC AUTHORITIES

Police and other authorities may require personal information from Odatone to be handed
over. In these cases, Odatone will only disclose the information if there is a court order, etc.,
bidding to do so.

YOUR RIGHTS

You can unsubscribe from Odatone news emails and marketing at any time with a click on
our link in our newsletter or by writing to support@odatone.com

Basic Rights

You have the right to access your personal data by requesting an overview of personal data
about you, and you may have a right to data portability. You also have the right to request
Odatone to correct inaccuracies in your personal data. If you have an account with
Odatone, this can usually be done through the appropriate “your settings” or “your profile”
sections on the appropriate Odatone Page or in the application.

You also have the right to request the deletion of personal data and to limit or object to our
processing of your personal data under this Privacy Statement or other service-specific
terms. Please use support@odatone.com to submit all requests.

DATA SECURITY AND STORAGE

Odatone takes the trust you and our Customers show us very seriously. Odatone
undertakes to avoid unauthorized access, disclosure or other deviant processing of personal
data.

ORGANIZATIONAL PRECAUTIONS

● E-learning courses in data protection, which are mandatory for all employees.
● Data processing agreements with subcontractors that process data on behalf of
Odatone.

TECHNICAL PRECAUTIONS

● Classification of personal data and implementation of security measures.
● Assess the use of encryption and pseudonymization.
● Restrict access to personal data to those persons who need it.
● Use systems that detect, prevent and warn of any breach of personal data security.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Odatone will retain your personal data only for as long as necessary for the purposes
stated. When the personal data we have collected is no longer needed, we delete it.

ODATONE AS A DATA PROCESSOR

Odatone provides many different services to our Customers. Most of our services involve
processing Customers' data. In such cases Odatone acts as a data processor and
processes the data on behalf of and in accordance with instructions given by the Customer.
The relationship between the Customer as Data Controller and Odatone as Data Processor
shall be governed by a Data Processor Agreement.

Customer's and Odatone's liabilities

When 1000TRAX processes personal data on behalf of its Customers, we must do so in
accordance with applicable data protection laws for data processors. In short, the Customer
and Odatone are obliged to cooperate to ensure the privacy of data subjects.

SUBCONTRACTORS AND EXPORT OF PERSONAL DATA

Odatone uses subcontractors to process personal data and, in this regard, may export your
or our Customers' data to a non-EU location. When using subcontractors, Odatone will enter
into a data processing agreement (DPA) to secure your personal data rights.

CHANGES TO THIS STATEMENT

If we change our Privacy Statement, we will publish the revised statement here with an
updated audit date. We encourage you to review the Statement regularly.

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