D.2 Política de Privacidade

PART D.2 — PRIVACY POLICY

This page forms part of Part D (ODIX Earn). It explains how the Strategy Partner Privacy Policy relates to ODIX Earn and summarises its main points.

Important: this is a summary prepared by ODIX for your convenience. The legally binding document is the Strategy Partner Privacy Policy published by the Strategy Partner and available on request from support@odixpay.com. If this summary and the Strategy Partner document differ, the Strategy Partner document applies.

1. HOW THIS RELATES TO ODIX

ODIX obtains the vault strategy management behind ODIX Earn from the Strategy Partner under a contract, and offers Earn to eligible ODIX customers in the App. The Strategy Partner manages the strategies; ODIX offers the service, onboards you and remains the company you deal with for your ODIX Account.

ODIX remains responsible for the personal data we hold about you under our own Privacy Policy, including the identity information collected during onboarding. To provide ODIX Earn, Where ODIX shares information with the Strategy Partner, it is limited to what the Strategy Partner needs to provide its services under our contract, as described in our Privacy Policy.

If you visit the Strategy Partner's website or contact it directly, the Strategy Partner processes your personal data as an independent controller under its own Privacy Policy, summarised below.

2. WHAT THE STRATEGY PARTNER COLLECTS

Information you give it, such as your name, email address, protocol of interest, payment details and requests; information from event organisers, data suppliers, business partners and social media; and information collected automatically, such as browser and device details, IP address and approximate location, device and cookie identifiers, browsing activity and email engagement.

3. WHY THE STRATEGY PARTNER USES IT

To respond to requests, provide support, analyse use of its site, communicate and market, advertise, protect its rights and comply with the law. Its legal bases are contract, legal obligation, legitimate interests and, where required, consent, which you can withdraw at any time.

4. WHO THE STRATEGY PARTNER SHARES IT WITH

Service providers such as payment processors, security consultants, hosting and analytics providers; business partners; advertising networks; social media platforms; parties involved in legal compliance or corporate transactions; and others with your consent.

5. INTERNATIONAL TRANSFERS

Data may be transferred outside your country, including to the United States. For EEA and UK residents, the Strategy Partner uses Standard Contractual Clauses where there is no adequacy decision.

6. RETENTION AND SECURITY

Data is kept as required by law and for legitimate business purposes such as audits, disputes and enforcing agreements, and may be anonymised or aggregated. The Strategy Partner uses appropriate technical and organisational safeguards but notes that no system is impenetrable.

7. YOUR RIGHTS

You can ask the Strategy Partner for access, information about processing, correction, deletion, restriction, portability and objection, decline significant automated decisions, withdraw consent and complain to a supervisory authority. Requests go to the partner contact address set out in its terms; the Strategy Partner may verify your identity and aims to respond within about one month.

You can manage cookies in your browser (the Strategy Partner honours Global Privacy Control), opt out of interest-based advertising in the EU and UK, and unsubscribe from marketing emails.

8. CHILDREN

The Strategy Partner does not knowingly collect personal data from anyone under 16.

9. FULL DOCUMENT AND QUESTIONS

The complete Strategy Partner Privacy Policy is available on request from support@odixpay.com. The Strategy Partner may update it at any time; the version published by the Strategy Partner is the current one.

Questions about ODIX Earn go to us at support@odixpay.com.