Privacy Policy

This Privacy Policy describes the privacy practices of Odeko Inc. and our subsidiaries and affiliates (collectively, "Odeko", "we", "us", or "our") in connection with the www.odeko.com website, the Odeko mobile application, and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the "services"), and the rights and choices available to individuals with respect to their information.

This Privacy Policy does not apply to information that we process on behalf of our business customers while providing the services to them. Our use of this information is restricted by our agreements with those business customers. If you have concerns regarding personal information that we process on behalf of a business, please direct your concerns to that business.

Our websites, products and services are designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as business representatives and not their individual capacities.

Personal Information We Collect

Information you provide to us:

• Contact data, such as your first and last name, email address, professional title and company name, and phone number.
• Communications that we exchange with you, including when you contact us with questions or feedback, through the services, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Cookies and other information collected by automated means. We, our service providers, and our business partners may use cookies, browser web storage (also known as locally stored objects, or "LSOs"), web beacons, and similar technologies to automatically collect information about your interaction with our services through your computer or mobile device, including:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, and general location information such as city, state or geographic area.
• Online activity data, such as the website you visited before browsing to our website, and information about your use of and actions on our websites, including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.
• Communications response data, such as whether you open emails we send you, and the links and other actions you take in response to the emails.

How We Use Your Personal Information

For research and development. We may use your personal information for research and development purposes, including to analyze and improve the services and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the services and promote our business.

Marketing and advertising. We, our service providers and our third party advertising partners may collect and use your personal information for marketing and advertising purposes, including direct marketing and interest-based advertising. You may opt-out of our marketing communications as described in the "Your Choices" section below.

To comply with law. As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. To protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); enforce the terms and conditions that govern our website and services; and protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

• Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
• Service providers. Third parties that provide services on our behalf or help us operate the services or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).
• Business and marketing partners. Third parties with whom we collaborate on joint activities, with whom we have entered into joint marketing relationships or other joint ventures, or who we think may offer you products or services that you may enjoy.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
• Business transferees. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, us or our affiliates (including in connection with a bankruptcy or similar proceeding).

Your Choices

Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Privacy settings and location data. We may make available certain privacy settings on the services. Users of our mobile application also have the choice whether to allow us to access your precise location data.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@odeko.com. You may continue to receive service-related and other non-marketing emails.

Cookies & browser web storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the services may not work properly.

Targeted online advertising. Some of the business partners that collect information about users' activities on or through our services may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit www.allaboutdnt.com.

Our website may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security Practices

We use organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. In the event that we are required to notify you about a situation involving your data, we may do so by email or telephone to the extent permitted by law.

International Data Transfers

We are headquartered in the United States and have service providers in other countries. Your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

The services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through the services from a child under 16 without the consent of the child's parent or guardian as required by law, we will delete it. We encourage parents or guardians with concerns to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through our services.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to privacy@odeko.com.

You may also write to us via postal mail at: Odeko Inc., 241 Centre St., 3rd Fl., New York, NY 10013.