Privacy Policy

This Privacy Policy outlines how OddinPay collects, processes, and protects your personal information. We are committed to safeguarding your privacy and complying with applicable laws and regulations regarding the data we handle. Please review this Policy regularly, as it may be updated from time to time.

At OddinPay, your privacy is our priority. We respect your personal information and ensure compliance with legal standards across all platforms, including our website, www.oddinpay.com, and other digital properties we operate.

Information We Collect

Personal information refers to any data that can be used to identify you. This includes, but is not limited to:

• Personal Details: Name, address, date of birth, and other identifying information.
• Device Information: Data related to the devices you use to access our services.
• Payment Information: Transaction and payment details.
• Usage Data: Information about how you interact with our website and services.

Automatic Data Collection

When you visit our website, our servers may automatically log certain standard information provided by your web browser. This may include: Your device’s Internet Protocol (IP) address, Geolocation for localization and Browser type and version Pages visited and the duration of each visit Date and time of your visit Other details about your browsing activity.

Additionally, if you encounter an error while using the site, we may automatically collect information related to the issue. This may include: Technical details about your device The actions you were performing when the error occurred Other relevant technical information You may or may not receive immediate notice of such errors or their details.

While this information alone typically cannot identify you personally, it could potentially be combined with other data to do so. We take steps to protect your data and minimize any risk of unintended identification.

User-Generated Content

User-generated content refers to any materials, including text, images, and videos, that are voluntarily submitted by users for publication on our website or re-sharing on our social media platforms. All user-generated content will be linked to the account or email address associated with the submission.

Please note that any content you submit for publication will become publicly accessible once posted, after undergoing any necessary review or vetting process. After publication, the content may be viewed or shared by third parties who are not covered by this privacy policy.

Legitimate Reasons for Processing Your Personal Information

We collect and use your personal information only when we have a legitimate reason to do so. In such cases, we ensure that we only gather personal data that is necessary and proportionate to providing our services to you.

Security

We are committed to protecting the personal information you provide to us. When we collect, process, and store your data, we take commercially reasonable measures to safeguard it against loss, theft, unauthorized access, disclosure, copying, use, or modification.

Assets you publish through our platform are already DRM-protected to prevent unauthorized downloads.

While we make every effort to ensure the security of your personal information, it’s important to note that no method of electronic transmission or storage can be considered 100% secure. As such, we cannot guarantee absolute data security.

You are responsible for maintaining the confidentiality and security of your account credentials, including passwords. It is important to choose strong, unique passwords and keep them secure to protect your personal information within the scope of our services.

Collection and Use of Information

We may collect personal information from you when you interact with our website in the following ways:

• Registering for an account
• Signing up to receive updates via email or social media
• Accessing our content via a mobile device or web browser
• Contacting us through email, social media, or similar communication channels
• Mentioning or tagging us on social media platforms

The information we collect may be used for the following purposes, and we will ensure that any further processing aligns with these objectives:

• To provide you with the core features and services of our platform
• To personalize and enhance your experience on our website
• To deliver products and services to you
• To communicate with you, including responding to inquiries or requests
• To facilitate your access to and use of our website, applications, and associated social media platforms
• To comply with our legal obligations and resolve any potential disputes
• For security purposes, fraud prevention, and to maintain the safety and integrity of our sites and services in accordance with our terms of use

If you request information from us (such as signing up for our newsletter), we may send you OddinPay-related marketing communications as permitted by law. You will have the ability to opt out of such communications.

In some cases, we may combine the personal information you voluntarily provide with data automatically collected from your interactions with our website, along with insights from trusted external sources. For example, data from our marketing and market research activities may be integrated with user behavior data to improve both the functionality of our site and your overall experience.

Sensitive Personal Information

By submitting sensitive personal information through our Services, you consent to its processing and use in accordance with this Privacy Policy. If you do not agree to the processing and use of your sensitive personal information as outlined, please refrain from submitting such information through our Platform.

How Long We Keep Your Personal Information

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or reporting obligations.

The retention period for your personal information is determined based on factors such as the nature and sensitivity of the data, the potential risks of unauthorized use or disclosure, the purpose of processing, and applicable legal requirements.

For example, if your onboarding application is rejected, we will delete all personal data associated with you from our servers. If you are accepted, we will retain your information for as long as needed to provide our services and comply with our legal obligations.

Once your personal information is no longer needed, we will dissociate it from any content associated with you. In some cases, we may anonymize your data so that it can no longer be linked to you. Anonymized data may be retained and used indefinitely without further notice.

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13. For younger children, parents can help create and manage a OddinPay account. When a child reaches their country’s minimum age, they can manage their own account.

Disclosure

Disclosure of Personal Information to Third Parties

We may share your personal information with the following parties for various purposes, as outlined below:

1. Affiliated Entities
   • Any parent, subsidiary, or affiliate of our company.
2. Service Providers
   • Third-party providers for essential services, including but not limited to:
     • IT services
     • Data storage, hosting, and server management
     • Error logging and maintenance
     • Debt collection
     • Marketing services
     • Professional advisory services
     • Payment processing systems
3. Internal Personnel
   • Our employees, contractors, and related entities.
4. Business Partners
   • Current or prospective agents and business partners.
5. Credit & Legal Authorities
   • Credit reporting agencies, courts, tribunals, or regulatory authorities in cases where you fail to fulfill payment obligations for goods or services provided.
6. Legal & Regulatory Compliance
   • Courts, tribunals, regulatory bodies, or law enforcement agencies, as required by law or in connection with legal proceedings, or to establish, exercise, or defend our legal rights.
7. Third-Party Assistants
   • Agents or subcontractors who assist us in delivering services, products, or marketing communications to you.
8. Data Processing
   • Third parties responsible for collecting and processing data on our behalf.
9. Business Transfers
   • Any entity acquiring our business or assets, either wholly or substantially, as part of a merger, sale, or transfer.

International Transfers of Personal Information

The personal information we collect is stored and/or processed in United States, or where we or our partners, affiliates, and third-party providers maintain facilities.

The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

Your Rights and Controlling Your Personal Information

Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Use of Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.

Please refer to our Cookie Policy for more information.

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

Additional Disclosures for Australian Privacy Act Compliance (AU)

International Transfers of Personal Information

Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act.

Data Controller / Data Processor

The GDPR distinguishes between organisations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). We, Oddin Pay LLC, located at the address provided in our Contact Us section, are a Data Controller and/or Processor with respect to the personal information you provide to us.

Legal Bases for Processing Your Personal Information

We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.

Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:

Consent From You

Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. You may consent to providing your email address for the purpose of receiving marketing emails from us. While you may unsubscribe at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

Performance of a Contract or Transaction

Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you contact us with an enquiry, we may require personal information such as your name and contact details in order to respond.

Our Legitimate Interests

Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

Compliance with Law

In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

We may also process your personal information to comply with any applicable obligations related to monitoring for fraud, and to prevent and detect fraud, and to comply with any applicable laws and regulations related to discovering and reporting illegal activities. This includes any applicable obligation to comply with the applicable federal and state reporting laws and regulations in connection with our transactions with users and third-parties. We may need to verify the identity of our customers, whether individuals or entities, and may use your personal information to do so.

We may report our compliance with these regulations and we may need to have third parties audit our compliance. Your personal information may be recorded, maintained, and used.

Substantial Public Interest

We may also process special categories of personal information (defined under the GDPR), when we need to in order to meet a substantial public interest, as long as such processing is consistent with applicable law. We may also process your personal information for sanction screening, due diligence, and know your customer regulations and best practices.

International Transfers Outside of the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Your Rights and Controlling Your Personal Information

Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.

Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.

Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information within 30 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.

Retention of KYC / KYB Information

You may delete your OddinPay account at any time directly through the platform. When you delete your account, we will instantly delete information from our active systems.

However, certain information collected as part of our Know Your Customer (KYC) and Know Your Business (KYB) obligations cannot be deleted immediately. We are legally required under anti-money laundering (AML), counter-terrorist financing (CTF), and other financial regulations to retain identity verification records, transaction histories, and related compliance documentation for a defined period (typically 5–10 years, depending on jurisdiction).

This KYC/KYB data is retained exclusively for regulatory compliance purposes and will not be used for marketing or any unrelated activities. Once the legally required retention period expires, this information will be permanently deleted.

Additional Disclosures for California Compliance (US)

Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes.

To make such a request, please contact us using the details provided in this privacy policy with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

Do Not Track

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals.

We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

Cookies and Pixels

At all times, you may decline cookies from our site if your browser permits. Most browsers allow you to activate settings on your browser to refuse the setting of all or some cookies. Accordingly, your ability to limit cookies is based only on your browser’s capabilities. Please refer to the Cookies section of this privacy policy for more information.

CCPA-permitted financial incentives

In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide.

Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:

Customer records, such as billing and shipping address, and credit or debit card data.

For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.

Right to Know and Delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.
• To exercise any of these rights, please contact us using the details provided in this privacy policy.

Shine the Light

If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes.

To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

For any questions or concerns regarding your privacy, you may contact us using the following details: support@oddinpay.com

Cookies

What are cookies?

Cookies are small data files stored on your computer or mobile device by a website. Our Sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers or business partners on our Sites, and can be used by such service providers or business partners to recognise your computer or mobile device when it visits other websites. Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

• Essential Cookies: These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
• Functionality Cookies: These cookies allow our Sites to remember choices you make when you use our Sites. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.
• Analytics and Performance Cookies: These cookies collect information about traffic to our Sites and about how individuals use our Sites. The information gathered may include the types of information described above in the section titled “Information automatically collected.” We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site. We use Google Analytics, Optimizely, and New Relic for this purpose. These parties use their own cookies.
• You can find out more information about Google Analytics cookies here - Google Analytics, and about how Google protects your data here: Google Privacy. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.
• Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” (or similar) button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this. Social networks use their own cookies.
• Targeting/advertising cookies: Targeting/advertising cookies are used to identify promotional content that is most relevant to your interests. We do not use this type of cookie on our site.