PRIVACY POLICY

1. INTRODUCTION

This is the privacy policy of odem GmbH (Hannesgrub Nord 37, 4911 Tumeltsham, AUSTRIA), hereinafter: "odem", "we" or "us". The proper handling of your personal data is very important to us. That is why we take the utmost care in processing and protecting your personal data. We act in accordance with applicable data protection laws (including the General Data Protection Regulation).

To ensure the protection of your data, we adhere to the following principles:

• Information: We always inform you about why and how we use your personal data. This information is listed in this privacy policy.

• Limited Data Collection: We take care to limit the information that is collected and used to that which is necessary to sell our products and/or provide our Services (as defined below).

• Security: We take the appropriate measures to protect your personal data and require the same from the parties that use your data on our behalf. odem continuously and proactively tests its website and app using an automated security scan.

• Privacy Rights: We respect your rights under applicable law (including the right to access, correct or delete your personal information under such laws).

This Privacy Policy describes how we implement these principles and how we respect and protect your right to privacy. We urge you to read this Privacy Policy carefully as it forms the basis of how we use your personal data when you purchase our products online ("Products" ), access our website, interact with us or otherwise use our services and applications (collectively, the "Services" ).

2. COLLECTION AND USE OF PERSONAL DATA

We collect the following personal information about you when you purchase our products or use our services (collectively, "Personal Information" ):

• Your contact information. Name, postal address, telephone number and email address, as well as any other contact details you provide to us (including the delivery address if you order our products online).

• Your electronic identification data and other data collected automatically when you use our online services. When you use our websites or apps, use our newsletter (open, click, read, cursor movements, etc.) or are exposed to online ads from odem, we automatically collect data about your browser or device (including IP address, MAC address, browsing behavior, preferred products and services, and the contents of your shopping cart) using cookies and other tracking technologies on the website (including web analytics). For more information, please see our Cookie Policy.

• Your account information. To complete your account with odem when you sign up online, we use your name, gender, email address, date of birth (your social security number if it is associated with your birthday under state-specific law), and other information you voluntarily provide to us, such as your telephone number.

• Your purchases on weareodem.com. To complete your online purchases through the official odem online store or other official odem social media channels, we use your name, gender, email address, phone number (optional), delivery method and delivery address, and any relevant information about your purchases, such as purchase value and date, products and services purchased, type of device through which you make your purchase, payment method, payment status, bank details, discount (if applicable), coupon code used (if applicable). In order to offer you payment methods from external partner companies, we may share your personal data in the form of contact and order details with these third party providers during the payment process so that they can check whether you are eligible for their payment methods and to customize these payment methods for you. Your submitted personal data will be processed in accordance with the privacy policy of the respective third party provider.

• Your personal data when you subscribe to our newsletter. In order to send you the odem newsletter with inspiring and promotional content, we use your email address and other information that you add to your profile, such as name or date of birth. In addition, odem sends personalized newsletters based on your personal preferences.

• Your Communication Data. Any data you provide in the course of your communication by email, online, by telephone, via social media or in any other way, e.g. through questions, requests or complaints.

• Reviews, recommendations and feedback. The opinions, experiences, preferences, interests, and reviews of products or events that you post online on our website or share with us on social media.
  
  

3. PURPOSES OF THE USE OF YOUR PERSONAL DATA

The personal data we collect is used exclusively for the following purposes:

To fulfill our obligations to you: To fulfill obligations arising from a contract we have with you and to provide you with the products, services and information you have requested, including managing and processing your inquiries or complaints. This also includes enabling you to purchase our products, participating in our sweepstakes, contests or lead generation campaigns, responding to your inquiries and providing customer service, providing you with essential information about our products and services, etc.

For our legitimate business interests: We use your personal data as described above (on both an aggregate and individual basis) to promote our products and services, to contact you by email, post, social media or other means for marketing or other business purposes. We also use your personal data to analyze and improve the quality of our products and services, such as customer service and aftersales, and to better understand your needs as a customer (customer optimization). This allows us to determine what might interest you, measure and understand the effectiveness of our displayed advertising, and show you relevant advertising. In addition, based on your use of our services, as well as your purchased products, we can target you with targeted advertising tailored to your personal preferences and experiences.

We may also use your personal information for other legitimate business interests, such as to operate and expand our business, to develop, improve or modify our products and services, to protect and defend our rights and safety and those of third parties, to prevent abuse and fraud in connection with online purchases of our products, and to monitor compliance with our house rules for use of our website(s), to compile statistics about the users of our products and services, to enable our business operations, to comply with company policies and procedures, to carry out corporate transactions, such as a merger, sale, reorganization or transfer of odem assets or business in the event of an acquisition or bankruptcy, or for other legitimate business purposes under applicable law.

Use of information based on your consent: In some circumstances, we may ask for your consent to process your personal information. For example, if you have not yet purchased a product from us, but would like to receive direct marketing communications (such as newsletters, offers, product news) by email, via other electronic communications or by telephone.

You can revoke your consent at any time (see section "Your rights").

To comply with our legal obligations: Any personal data collected may be used to comply with our legal obligations to regulatory authorities, tax authorities or investigative bodies.

4. SOCIAL MEDIA

If you use social media such as Facebook, Twitter, Pinterest, Instagram, LinkedIn, etc., you should be aware of and understand the tools provided through these sites in order to make informed choices about how your personal information is handled on your social media profiles.

odem is bound by the privacy policies and practices of these third parties and therefore we encourage you to review their respective privacy policies, terms and conditions, and information regarding the use of your personal information in the environment of these social media.

Depending on your choices regarding your settings on various social media (and/or in combination with your settings on odem's Sites), certain personal information about your online activities and social media profiles (e.g., interests, marital status, gender, username, photo, comments and posted/shared content, etc.) may be shared with odem.

5. DISCLOSURE OF YOUR PERSONAL DATA

We share your personal information with the following parties:

• Third Party Providers. From time to time, we engage the following third party vendors to assist us in providing our products and services:

- Business partners, service providers (e.g. IT service providers) and subcontractors;

- Contact centers that support our customer service;

- Advertising agencies and media companies that perform marketing and media activities on our behalf (including affiliate marketing);

- Analytics services and search engine operators that help us improve and optimize our website and apps, such as Google Analytics.

In providing their services, these third-party service providers may access, receive, maintain or otherwise process personal data on our behalf. Our contracts with these service providers prohibit the use of your personal data for their own (marketing) purposes. To the extent permitted by applicable law, we take commercially reasonable steps to require these third-party service providers to adequately protect your personal data and to process it only with our consent.

• corporate transaction. In addition, personal data must be disclosed as part of a merger, sale or transfer of assets of odem.

• Third Party Providers with Legal Requirement. We may also disclose your personal information if we believe the law requires us to do so.

• With consent. We may also share information about you, including your personal data, with third parties if you have given us your consent or requested us to do so (for example, for an advertising campaign with another sponsor).
  
  

6. INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

In most cases, your personal data will be processed within the European Union. However, please note that odem may transfer and process the personal data you provide to countries outside your country of residence. The data protection laws of these countries may not provide the same level of protection for your personal data. That is why odem or third-party service providers acting on our behalf take all reasonable security measures to comply with all applicable laws and regulations in connection with such transfers, especially for personal data transferred to countries outside the European Economic Area. This means that we have entered into legally required contracts with the recipients of your data, including standard contractual clauses approved by the European Commission or other supervisory authorities, where required.

7. SECURITY

We take necessary steps to ensure that your personal data is protected against unauthorized or unlawful use, unauthorized alteration, unauthorized access or disclosure, accidental or intentional destruction and loss using appropriate technical, physical and organizational measures.

We take steps to limit access to your personal data to individuals who are granted access for a reason set forth in this Privacy Policy. In addition, we contractually ensure that third-party vendors who process your personal data also maintain the integrity, confidentiality and security of your data.

8. DATA STORAGE

We retain personal data for as long as necessary to fulfill the purpose for which it was collected and used (e.g., the period necessary to provide customer service, respond to inquiries, or resolve technical issues), as long as longer retention periods are not required for our legal obligations or to defend legal claims.

9. YOUR RIGHTS

In accordance with the applicable legal provisions, you have the following rights regarding our processing of your personal data:

• Right of Access - You have the right to request confirmation as to whether odem is processing your personal data and, if so, you have the right to obtain access to the personal data and other information. Upon request, we may provide you with a copy of the personal data that we process;

• Right of rectification - You have the right to request odem to correct, amend or supplement your personal data if this data is incomplete or incorrect. You may also correct, amend or supplement your personal data yourself by updating your profile. Furthermore, we would like to ask you to inform odem of any changes in your personal circumstances (such as change of address, bank details, etc.) so that we can ensure that your personal data is up to date. odem will take all necessary steps to ensure the accuracy of your personal data;

• Right of Withdrawal - You have the right to withdraw your consent to receive marketing communications at any time by following the instructions in any marketing communications or by completing the form below. If we use your personal information with your consent for purposes other than marketing communications, you may withdraw your consent by sending us an informal message to the email address below;

• Right to erasure - You are entitled to request the erasure of any irrelevant personal data held by us if (i) the data is no longer necessary for the purpose for which it was collected; (ii) you withdraw your consent and there is no further lawful reason for processing; (iii) you object to the processing of your data for direct marketing purposes or, in all other cases, there are no compelling grounds for processing; (iv) we have unlawfully retained your data. If you have this request and all requirements are met, we will ensure that odem deletes the data that we are not legally obliged to retain;

• Right to data portability - As long as we use your personal data for the performance of the contract and the personal data is processed automatically, you are entitled to receive any personal data you have provided odem in a structured, used and machine-readable format, and to request us to transfer it to another controller, where technically feasible;

• Right to object - As long as we process your personal data on the basis of legitimate interests, you are entitled to object to the use and we are obliged to stop the processing until we present either compelling legitimate grounds which override your interests, rights and freedoms, or where the processing of the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to object to profiling by odem;

• Right to Complain - You also have the right to file a complaint with a supervisory body, particularly in your country of residence, if you believe that the collection and use of your personal information violates this Privacy Policy or applicable laws.

For more information about your rights or to exercise your rights, please email us at the following address: info@weareodem.com

10. AMENDMENTS TO THE DIRECTIVE

This Privacy Policy may be amended from time to time. If there are fundamental changes to how we use your personal information, or if the changes are otherwise relevant to you, we will ensure that you are notified well in advance of the changes taking effect.

11. CONTACT US

If you have any questions about this Privacy Policy or our treatment of your personal information, please email us at info@weareodem.com and indicate the reason for your inquiry.