Odyssey Privacy Policy

Bloq, Inc., together with its affiliates, agents, and licensees (collectively “Bloq,” “we,” “us,” or “our”), offers you a non-custodial cryptocurrency wallet and superapp platform called Odyssey (the “Platform”). Additionally, we operate a related interactive Odyssey Website at [www.odyssey.finance] (the “Website”). Our Software, Website, any applications, or other services or content we may offer in association with the Platform are collectively the “Services”. We are committed to respecting the privacy of information and data of the users of our Services.

This Privacy Policy explains what information may be collected when you access our Services, how we and others use this information, under what circumstances we may disclose the information to third parties, and the instances in which we may allow third parties to collect information directly. Depending on your activities when using or accessing our Services, you may from time-to-time be required to agree to additional terms and conditions. This Privacy Policy applies regardless of whether you use our Services via a computer, mobile device, tablet, or other medium (collectively, your “Equipment”). If you do not agree to the terms set forth herein, please do not use our Services.

1. Information We May Collect About You

We collect, use, store or transfer various different kinds of information from you, about you or about your Equipment when you use our Services, including: 

• Contact information such as your email address or similar identifiers. 

• Communication Information such as the communications you send us, feedback that you communicate to us, and similar communication between you and us via email, social media,or any other medium.

• Commercial information such as details of our Services (including Applications) that you have obtained or considered. 

• Internet or other similar network activity such as your browsing history, search history, and information about your interactions with our Services or advertisements. 

• Technical information such as your internet protocol (IP) address, your login data, browser type and version, time zone setting, location, browser type, browser language, operating system type, the website you visited before browsing to our Sites, browser plug-in types and versions, operating system and platform, and other technology on the Equipment you use to access the Services. 

• Web3 and Blockchain Information such as your blockchain wallet public key and the account it is associated with, wallet address, blockchain transaction ID’s, blockchain operations, and portfolio performance.

• Profile information such as your username and password, purchases or orders made by you, your interests, preferences, feedback, product reviews, survey responses, and other similar information. 

• Third Party Site Log-In Information such as your Apple, Google, and Dynamic log-in information if used to access our Services. 

• Usage information including information about how you use our websites, apps, and any other aspect of our Services, cryptocurrency collecting and trading habits within the Services, cryptocurrency portfolio preferences within the Services, the makeup of your cryptocurrency portfolio, wallet activity, risk tolerance, and similar information related to your behavior, preferences, and propensities within the context of the Services.

• Marketing and communications information such as your preferences in receiving marketing from us and your communication preferences.

Some of the information we collect about you may be personal information that can be used to identify you including – for example, your name and email address. In some jurisdictions, certain unique identifiers like IP addresses and other usage or technical information may be considered personal information. However, in no instance does personal information include data where your identity has been removed so that we can no longer identify you (anonymous data), which we may use for any purpose. 

2. How We Collect Your Information

We collect information from you in different ways and from different places, including:

• You provide it to us directly. You may give us information about you by filling in forms or by communicating with us by text, e-mail, or otherwise. This includes information you provide when you create an account, purchase a Service, use our Services, complete a survey, provide feedback, report a problem, or otherwise contact us about our Services, or provide information to be published or displayed on public areas of our Services or transmitted to others.

• We automatically collect it using technology from our websites, applications, and emails.As you interact with our Services, we may automatically collect technical information and usage information as specified above. We collect this information by using cookies, server logs, web beacons, and other similar technologies (see Cookies and Automatic Data Collection Technologies).

• From other places. We may receive information about you from other companies and individuals including, for example, business partners, subcontractors, advertising networks, social network platforms, analytics providers, and service providers. We may also receive information about you from other users.

3. Cookies and Automatic Data Collection Technologies

We may use automatic data collection technologies when you view our advertisements or use our Services. For example, we may use cookies to distinguish you from other users of the Services to help us deliver a better and more personalized service when you use our Services. It also allows us to improve our Services by enabling us to:

• Estimate our audience size and usage patterns.

• Store your preferences so we may customize our Services according to your individual interests and preferences.

• Speed up your searches.

• Recognize you when you return to our Services.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services. For more information, see Interest Based Advertising.

The technologies we use for this automatic data collection may include, among others:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your Equipment. For information about managing browser settings to refuse cookies, see Your Rights and Choices.

• Flash Cookies. Certain features of our Services may use Flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on the Services. For information about managing Flash cookies see Your Rights and Choices.

• Web Beacons. Our Services pages and e-mails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording Services content popularity or verifying system and server integrity.

  
  

4. How We Use Your Information

We use your information to provide you with our Services, offer you additional Services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using information to improve and personalize your experiences. Examples of how we may use the information we collect include:

• Manage our relationship with you which may include notifying you about changes to our Services, terms or Privacy Policy, providing you notices about your account, asking you to provide feedback or take a survey, or addressing any concerns you may have about our Services.

• Facilitate the connection of third-party services or applications.

• Facilitate blockchain smart contract transactions on our Services.

• Offer you crypto portfolio suggestions tailored to you.

• Deliver relevant content, advertisements, and messaging to you and to measure or understand the effectiveness of such content, advertisements, and messaging.

• Respond to your requests from us or to fulfill any other purpose for which you provide it.

• Use data analytics to improve our Services, marketing, customer relationships, and experiences. 

• Address legal issues, including (i) complying with our obligations to retain certain business records; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal processes; (iv) detecting and preventing fraud or intellectual property infringement claims, violations of our contracts or agreements, violations of law, or other misuses of our Services; and (v) protecting our rights or property, or yours or others’ health, safety, welfare, rights, or property.

• Allow you to exercise your data privacy rights.

• Carry out our obligations and enforce our rights.

• In any other way we may describe when you provide the information.

We may use information that is not Personal Information for any purpose. For example, we may use aggregated data such as statistical data or aggregate demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Information, but Aggregated Data is not considered Personal Information, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing our Services. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Privacy Policy.

5. Disclosure of Your Information

We may share information that does not identify you without restriction. We may disclose personal information as follows:

• To our contractors, service providers and other third parties we use to support our business, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing providers; and who are obligated to keep personal information confidential and use it only for the purpose for which we disclose it to them.

• With your consent.

• For any other purposes that we disclose when you provide the information.

• To fulfill the purpose for which you provide it. 

• To an actual or prospective buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets,whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal information we hold.

We may also disclose personal information to others:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.

• To enforce or apply our Terms of Use or other agreements.

• To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection and credit risk reduction.

• To investigate suspected violations of any law, rule or regulation, or the terms or policies for our Services.

6. Third-Party Payment Processing

We use a third-party Web 3 payment processing vendor (the “Vendor”) to allow you to transfer USDC onto our Services by spending fiat. The Vendor may collect the following information: 

• Financial information such as your billing address, credit card information, account number, financial history, and other financial and/or payment-related information.

• Personal Information such as your full name, date of birth, and address.

• Other Sensitive Personal Information such as your social security number, your driver’s license or other form of government-issued ID, utility bills or other proof of address, and similar information necessary in the Know Your Customer verification process.

We do not store, control, nor process any of the information collected by the Vendor, and it is not subject to this Privacy Policy unless otherwise specified above. The Vendor has its own privacy policy by which its data collection and use are governed, and we encourage you to review its policy before using our Services.

7. International Data Transfers

The Services are hosted in the United States. If you choose to use the Services from regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal data outside of those regions to the United States for storage and processing, which may not have the same data protection laws as your jurisdiction.

If you are based in the EU or UK, please note that, while the United States has personal data privacy laws that are different from your country, and the United States has not received an adequacy decision from the European Union Commission, we will ensure that your personal data is protected in a manner that is consistent with how your personal data is protected if it was processed in your country. For additional information on rights that you have under the European Union’s General Data Protection Regulation (GDPR), visit the GDPR Notice page on our Website. 

For additional information on the transfers, please contact us at the contact information provided in the Contact Us section below. 

8. Children’s Online Privacy

We do not direct our websites or services to any person under the age of 18, and we do not knowingly collect personal information from any person under 18. If you are under 18, do not use or provide any information through the Services. 

If we learn we have collected or received personal information from a child under 13 without appropriate consent, we will delete it. If you believe we might have any information from or about a child under 13 please contact us at the contact information provided in the Contact Us section below.

9. Interest-Based Advertising

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can block the collection and use of information related to you by advertising companies for the purpose of serving interest-based advertising by visiting the following platforms of self-regulatory programs of which those companies are members:

• The NAI’s opt-out platform is available here.

• The DAA’s opt-out platform is available here.

10. Social Networks, Third-Party Links, Forums

Our Services may integrate social network plugins, include links to third-party websites or services, or provide you the opportunity to post content. Please keep the following in mind:

• Social Networks. Our websites may make available the option for you to use social network “plugins” that are operated by social media companies. If you choose to use one of these plugins, then it may collect information about you and send it back to the social media company that owns it. This may happen even if you do not click on the plugin, if you are logged into the social media website that owns the plugin when you access our Services. Information collected by a plugin is subject to the privacy policy and terms of the social media company that owns it. If you do not want the applicable social media company to collect information about you when you use our Services, sign out of the social media network before visiting. By interacting with a plugin when you use our Services (for example, clicking the Facebook “Like” button), you are knowingly transferring information to that social media company. Further, if you are logged into a social media website when you visit our websites, then you are directing us to share your data with the social media company that owns the plugin.

• Third-party links. Our Services may link to or contain links to third-party websites that we do not control or maintain, such as in connection with purchasing products we may recommend or reference via our Services and/or advertisements you may see while using our Services. We are not responsible for the privacy practices employed by any third-party website. We encourage you to read the privacy statements of all third-party websites before submitting any personally identifiable information through these websites.

• Forums. We may offer chat rooms, blogs, message boards, discords, or similar public forums where you and other users of our Services can share information and communicate – e.g., places where you can post your profile. The protections described in this Privacy Policy do not apply when you post information (including personal information) to these forums. And we may use personal information to identify you with a post on any such forum. Any information you share with or on these forums is public information and may be seen or collected by anyone, including third parties that do not adhere to our Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Services.

11. Your Rights and Choices

Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information: 

• Marketing/Notifications. If you have an account with us, we may collect and use your email address to provide you with newsletters or other similar marketing or promotional notifications. If you do not want us to use your email address or other contact information to promote or recommend our own Services, or third parties’ products or services, you may opt-out by checking the relevant box located on the form where we initially collect your contact information or, if presented with the option to opt-in, do not opt-in. If you have an account with our Services, you may be able to log in and check or uncheck relevant boxes. If you do not have an account, you can adjust your preferences by contacting us as set forth below in the Contact Us section. You may also opt-out of further marketing communications by replying to any promotional email we have sent you or following the opt-out links on that message. Marketing opt-out generally will not apply to information provided to us as a result of a purchase, licensing, or other transactions regarding our Services.  

• Accessing, updating, and deleting your information. If you have an account with us, you may have the ability to access your information and make updates to or delete your data. If not, you can contact us as set forth in the Contact Us section below to request access to, correction of, or deletion of personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.

• If we receive your personal data in the context of providing problem solving services to you, we will securely accept that data, segregate it from other customer data, and limit access to the data. We will delete the data once the issue is resolved.

• In general, we will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law, or we have obtained your consent.

• Location Information. When you use our Services, particularly our Application(s), we may automatically collect certain Equipment (mobile device) specific information. This includes the general or specific location of your Equipment through GPS, Bluetooth, or WiFi signals. Before we collect or send location-specific information, it is our practice to ask for your consent. In some instances, your operating system may not allow you to install an Application without giving us consent. In all instances, you may withdraw your consent by disabling location features for your Equipment.

•  Cookies and automatic data collection technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Flash cookies are not managed by the same browser settings used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. However, if you disable or refuse cookies, please note that some parts of the Services may become inaccessible or not function properly.

• Interest Based Advertising. Please see Interest-Based Advertising above for information on how to opt-out of interest-based advertising.

12. Your California Privacy Rights

If you are a California resident, you may have additional personal rights and choices with regard to your personal information. Please send any requests you may have in this regard in writing to the address provided in Section 15 below. In your request, please attest to the fact that you are a California resident and provide a current California address for our response.

13. Data Security

The security of your information is very important to us. We use physical, electronic, and administrative safeguards designed to protect your information from loss, misuse and unauthorized access, use, alteration, or disclosure, taking into account the level of risk associated with the processing of your personal data. The personal data we hold is stored and processed securely in line with the information security measures and guidance standard in our industry. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. 

While we take reasonable precautions and have implemented managerial and technical procedures to try to protect the security of data and information, including personal information, we cannot guarantee against any loss, misuse, unauthorized disclosure, or alteration or destruction of data or personal information. You provide your personal information to us at your own risk. You acknowledge that: (1) there are security and privacy limitations in computer systems and on the Internet which are beyond our control; (2) the security, integrity, and privacy of any and all information and data exchanged between you and us through our Services, including personal information, cannot be guaranteed; and (3) any such information and data, including personal information, may be viewed or tampered with by a third party while such information or data is being used, transmitted, processed, or stored.

14. Changes to our Privacy Policy

We reserve the right to modify this Privacy Policy at any time for any reason. We will post notice of any material changes we may make to our Privacy Policy on the Odyssey Website prior to making the change. Your continued use of our Services after the posting of the amended Privacy Notice on the Website constitutes your assent to the Privacy Policy as amended. The date the privacy policy was last revised is identified at the top of the page. Please check back frequently to review any updates or changes to our Privacy Policy.

15. Contact Us

If you have any comments or questions about our privacy policy, or to exercise the specified rights above, you may contact us at:

Address: 575 E. 4th Street Winston Salem, NC 27101

Email: admin@odyssey.finance

We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Services. 

16. Sole Statement

This Privacy Policy is the sole statement of our privacy practices with respect to our Services. No summary, modification, restatement or other version of this Privacy Policy, or other privacy statement or policy, in any form, is valid unless we post a new or revised policy to our Website or Applications.