OVERVIEW

This Odeum Data Transfer Statement (“Statement”) sets forth Odeum’s policies and practices concerning the transfer of personal data across borders.

APPLICABILITY

This Statement applies to Odeum LLC (collectively and for this statement only, “Odeum,” “we” or “us”). This Statement forms a part of Odeum’s Privacy Policy.

LOCATION

Odeum is based in the United States. We provide services globally using computer systems, servers, and databases located in the U.S. When you use our services from outside of the U.S., your information will therefore be transferred to, stored in, and processed in the U.S.

EUROPEAN USERS

The European Commission has determined that the transfer of personal information of its residents outside of Europe must be subject to a legal framework that adequately protects it. We transfer personal information of European Economic Area (“EEA”) and Swiss residents to the U.S. (or elsewhere) based upon the following legal frameworks:

• Our use of Standard Contractual Clauses (also known as “Model Clauses”) where appropriate.
• Our transfer of data to vendors that comply with the EU-US and Swiss-US Privacy Shield frameworks (“Privacy Shield”).

GDPR

We comply with the European Union’s General Data Protection Law (“GDPR”), which governs the protection of personal data of EU residents. To find out more about GDPR, please visit the European Union’s website, at https://ec.europa.eu/info/law/law-topic/data-protection_en.

EU users have the rights to: opt out of cookies (see our Cookie Policy); access, correct, delete, restrict or object to our use of their personal information; be forgotten; and data portability. For the most part, we enable exercise of these rights directly through our products. For example, we allow users to change their information, download their videos, and close their accounts.

If you require assistance or have a specific request that is not presently covered by our product features, please contact our Data Protection Officer. We may require additional information from you to fulfil your requests. We may charge a reasonable fee if your request imposes an unreasonable cost on us.

We will afford UK-based users with all rights available to EU users, regardless of the UK’s EU member status.

CONTROLLERS AND PROCESSORS

Some laws, including the GDPR, differentiate between controllers and processors of data. A “controller” has a direct relationship with you and exercises control over the use of your data. The third-party vendors that help a controller provide a service are considered “processors” because they process the controller’s customer data at the controller’s request (examples are payment processors and cloud-based hosting providers).

All Odeum entities are controllers of personal data relating to users who upload and stream videos.

With respect to the Odeum platform, Odeum LLC is the controller of personal data of end users who view uploaders’ videos or live streams as these Odeum entities have direct relationships with the end user viewers.

With respect to the Odeum platform, Odeum LLC and the Odeum Publisher act as independent controllers of the personal data submitted to the platform by persons who subscribe to Odeum channels.

DISPUTE RESOLUTION

We are committed to working with you to obtain a fair resolution of any complaint. We encourage you to begin by contacting our Data Protection Officer. We endeavor to respond to requests promptly.

EU residents have the right to lodge complaints with the data protection authority of their country of residence.

DATA PROTECTION OFFICER

For any questions, inquiries, or complaints, please contact us at:

Odeum LLC

425 E. 4th Street, Unit C

Long Beach, CA 90802

Attn: Legal Dept.

[email protected]