Privacy Policy

Introduction

These terms apply to the website, applications, products and services developed and/or published by Odders Lab, S.L. (“Odders” / “we” / “us”), including VOLATTA.

Odders Lab, S.L. is a company validly incorporated and existing under the laws of Spain, with registered offices at Avenida Santa Clara de Cuba, 4, Nave 18 (Seville), registered with the Commercial Registry of Seville as of 05/03/2019, under volume 6,686, Book 0, page 29, section 8 and sheet SE-121020, and holder of Spanish tax identification number (N.I.F.) B-90.422.262.

Who does this Privacy Policy apply to?

This privacy and data policy (“Privacy Policy”) applies to users who visit the VOLATTA website and landing page, as well as users who voluntarily provide their email address to express their interest in VOLATTA (the “App”), including registering their interest in obtaining information about future availability, updates and potential Early Access opportunities.

The VOLATTA website, landing page and related online features are hereinafter referred to as the “Online Services.”

Who is responsible for personal data processed in accordance with this Privacy Policy?

This Privacy Policy explains what personal data we may collect from you, the purposes for which we collect it, how we use your personal information and the measures we take to protect it.

Please read this Privacy Policy carefully, as it contains important information about:

• What information we may collect about you;
• How we will use the information we collect;
• Whether we will disclose your information to third parties; and
• Your choices and rights regarding the personal data we hold about you.

Where we determine the purposes and means for processing personal data supplied through the Online Services, Odders Lab, S.L. acts as the data controller for the purposes of Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”) and Spanish Organic Law 3/2018, of 5 December, on Personal Data Protection and Guarantee of Digital Rights.

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any of your rights regarding your personal data, you can contact us at info@odderslab.com.

Services operated by third parties

The Online Services may contain hyperlinks to websites or services owned and operated by third parties. These third-party services may have their own privacy policies, which we recommend you review.

Those policies will govern the use of personal data you submit to those third parties or that may be collected through cookies and other tracking technologies while using their services.

Odders does not accept responsibility or liability for the privacy practices of third-party services.

Updates to this Privacy Policy

Odders may revise this Privacy Policy from time to time, for example, as a result of changes to VOLATTA, the Online Services, applicable regulations or our data processing practices.

Any updated Privacy Policy will apply from the moment it is published on this page.

If significant changes are made to this Privacy Policy and where required by applicable law, we will take appropriate steps to inform you. Where processing is based on your consent and a new consent is legally required, we will request it.

When you use the VOLATTA Online Services, we may collect and process the following personal data:

Information provided directly by you

When you register your interest in VOLATTA or its Early Access through our landing page, we may collect:

• Your email address; and
• Any other information that you voluntarily provide through forms made available on the website.

Providing your email address is voluntary. However, without it, we will not be able to contact you regarding VOLATTA, its availability or Early Access opportunities.

Technical and analytics information

Subject to your cookie preferences and applicable law, we may also collect certain technical information about your interaction with the VOLATTA website through cookies or similar technologies.

Depending on the technologies implemented on the website, this information may include:

• IP address;
• Device type;
• Browser type;
• Operating system;
• Country or approximate location derived from technical information;
• Language;
• Pages visited;
• Date and time of visits; and
• General interaction with the website.

Where required by applicable law, analytics or other non-essential cookies will only be used after obtaining your consent.

We collect and process personal data primarily to manage your interest in VOLATTA and its Early Access programme.

In particular, we may process your personal data for the following purposes:

Managing your interest in VOLATTA Early Access

We will process your email address to record your interest in VOLATTA and to manage the list of users interested in accessing or learning more about the App before or around its public release.

Contacting you about VOLATTA

We may use the email address you provide to contact you with information directly related to VOLATTA, including:

• Early Access availability;
• Invitations to participate in Early Access or testing programmes;
• Product launch information;
• Important updates regarding VOLATTA;
• Availability of new versions or features; and
• Other information related to your expressed interest in VOLATTA.

Improving our Online Services

Where permitted by applicable law and subject to your cookie preferences, we may use aggregated or analytics information to understand how users interact with the VOLATTA website and to improve its performance, usability and content.

Compliance and security

We may process information where necessary to comply with our legal obligations, protect the security and integrity of our Online Services, prevent fraudulent or unlawful activity, or establish, exercise or defend legal claims.

The primary legal basis for processing the email address you voluntarily provide through the VOLATTA Early Access landing page is your consent.

By submitting your email address through the relevant form and providing the required consent, you authorize Odders to process your email address for the purposes described above.

You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before your consent was withdrawn.

You may withdraw your consent by:

• Using the unsubscribe option included in our communications, where available; or
• Contacting us at info@odderslab.com.

We may also process certain personal data where necessary to comply with a legal obligation or based on our legitimate interests, such as maintaining the security and integrity of our website, provided that those interests do not override your fundamental rights and freedoms.

Where non-essential cookies or analytics technologies require consent under applicable law, we will request your consent before using them.

We will retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy.

In particular, if you provide your email address to register your interest in VOLATTA Early Access, we may retain it for as long as necessary to manage your interest in VOLATTA and communicate with you regarding the App.

If you withdraw your consent or request deletion of your personal data, we will stop processing your email address for these purposes and delete or anonymise it, unless we are required to retain certain information to comply with applicable legal obligations.

We will never sell your personal data.

We may share your personal information only where necessary for the purposes described in this Privacy Policy and where we have a valid legal basis to do so.

This may include the following categories of recipients:

Personnel, suppliers and service providers

We may disclose personal data to Odders personnel and trusted suppliers or service providers where reasonably necessary to operate the VOLATTA website, manage Early Access registrations, send communications, host information or provide related technical services.

These parties may only process personal data according to our instructions and are required to implement appropriate safeguards to protect it.

Merger or acquisition

If Odders is involved in a merger, acquisition, restructuring, transfer or sale of all or part of its assets, personal information may be transferred as part of that transaction, subject to applicable data protection requirements.

Required by law

We may disclose your information where required by applicable law, regulation, legal proceedings or requests from competent public authorities, or where necessary to establish, exercise or defend our legal rights.

We do not use the email address submitted through the VOLATTA Early Access landing page to make decisions based solely on automated processing that produce legal effects or similarly significantly affect you.

We will obtain your consent where required before using your personal data to send you communications related to VOLATTA.

You can withdraw your consent or ask us to stop sending you these communications at any time by using the unsubscribe mechanism provided in our emails, where available, or by contacting us at: info@odderslab.com

Under applicable data protection law, you may have the right to:

• Access the personal data we hold about you;
• Rectify inaccurate or incomplete personal data;
• Request deletion of your personal data;
• Restrict the processing of your personal data in certain circumstances;
• Object to certain processing of your personal data;
• Withdraw your consent at any time where processing is based on consent; and
• Request portability of your personal data where applicable.

To exercise any of these rights, you can contact us at: info@odderslab.com

We will respond to valid requests in accordance with the time limits established under applicable data protection law.

You also have the right to lodge a complaint with a competent Data Protection Supervisory Authority if you believe that your personal data has been processed in violation of applicable data protection legislation.

In Spain, the competent supervisory authority is the Agencia Española de Protección de Datos (AEPD).

The VOLATTA Early Access registration is not intended to knowingly collect personal information from children under the age of 16.

If we become aware that we have collected personal data from a child under the age of 16 without the appropriate authorization where required, we will take reasonable steps to delete that information.

If you believe that we may hold information relating to a child under the age of 16, please contact us at info@odderslab.com.

We take appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

We implement safeguards appropriate to the nature of the information processed and the risks associated with such processing.

However, no method of transmitting or storing information electronically can guarantee absolute security.

Some of the service providers we use to operate the VOLATTA website, manage registrations, store information or send communications may process personal data outside the European Economic Area (“EEA”).

Where personal data is transferred outside the EEA, we will ensure that appropriate safeguards are implemented in accordance with applicable data protection legislation.

Where the recipient country is not subject to an adequacy decision by the European Commission, these safeguards may include the use of Standard Contractual Clauses approved by the European Commission or other legally recognised transfer mechanisms.

You may contact us at info@odderslab.com if you require additional information about the safeguards applicable to international data transfers.

All questions, comments or enquiries regarding this Privacy Policy or the processing of your personal data should be directed to: