Privacy policy

01 Who we are

Odore Limited ("Odore", "we", "us") runs this website, www.odore.com (the "Website"). We are registered in England and Wales, company number 10726054, registered office International House, 61 Mosley Street, Manchester M2 3HZ. Our affiliates are Odore Inc, 1350 Avenue of the Americas, New York, NY 10019, USA, and Odore L.L.C-FZ, Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates.

This policy explains how we use personal data about:

• visitors to the Website and business contacts, such as people who request a demo (sections 2 to 11);
• creators and community members who join a brand's programme run on Odore, for example a community on a brand's own odore.com address (such as brandname.odore.com), a brand's own app, or a campaign they are invited to (a "Programme") (section 12); and
• creators whose public social media profiles appear in Odore Discovery, the search tool brands use to find creators (section 13).

For the Website, business contacts and Discovery, Odore Limited is the controller. For Programmes, see section 12. Contact us about anything in this policy, or to use any of your rights, at info@odore.com.

Brand teams and agencies that use the Odore platform at app.odore.com are also covered by their organisation's agreement with us.

02 What we collect

We collect only what we need. You do not have to give us your details, but we need your name, work email and company to reply to a demo request.

• Demo requests and enquiries: your name, work email and company, the topic you choose and anything you write in the optional message. With the form we also record the address of the page you came from before the form (which may be another website) and any campaign tags or ad click identifiers in the link you followed (for example utm_source, gclid or li_fat_id), so we know which pages and campaigns lead to enquiries.
• Emails and calls: what you send us when you contact us directly.
• Technical data: IP address, browser, device, pages viewed and the referring site. Our host records this in server logs. Google Analytics and LinkedIn record it only if you accept cookies.

We do not ask for sensitive personal data through the Website, and we do not make decisions about you based solely on automated processing.

03 How we use it and our lawful bases

Where we rely on legitimate interests, we have weighed them against your rights. You can ask us for details.

04 Cookies

Analytics and advertising cookies are set only if you click Accept. Nothing is set before you choose, and nothing on the Website depends on accepting them. The full list, with expiry periods, is in our cookie policy. You can change your choice at any time using Your privacy choices at the bottom of every page.

05 Who we share it with

We do not sell personal data. We share it only with:

• Netlify, which hosts the Website and receives form submissions. Netlify uses Akismet (Automattic) to filter spam from form submissions.
• Google, which provides our business email (Google Workspace), where form submissions and emails are delivered, and, if you accept, Google Analytics. Google's advertising features are switched off in our Analytics.
• LinkedIn, if you accept advertising cookies. We and LinkedIn are joint controllers for collecting this data and sending it to LinkedIn, under LinkedIn's joint controller terms; LinkedIn is a separate controller for its own use of it, under its privacy policy.
• Our affiliates, Odore Inc (New York, USA) and Odore L.L.C-FZ (Dubai, UAE), and colleagues in other countries, where they help us reply to you.
• Other analytics and advertising providers listed in our cookie policy, only if you accept cookies.
• Other service providers that help us run our business, such as email, customer relationship, analytics and support tools. They act on our instructions under contract.
• Our professional advisers, and regulators, courts or law enforcement where the law requires it.
• A buyer of all or part of our business, who may use the data only for the purposes in this policy.

Apart from LinkedIn, the service providers above act as our processors (or, for Programmes, sub-processors) and may use the data only to provide their service to us. Our main service providers today:

We may add or replace service providers within these categories. We choose them carefully, put contracts in place that protect your data, and update this list and our cookie policy when this changes.

06 International transfers

Some of our providers, including Netlify, Google, LinkedIn and Amazon Web Services, process data outside the UK and the European Economic Area, including in the United States. Brands choose which of our hosting regions stores their Programme data. Our team works from London, Lisbon, New York, Toronto, Mexico City, Rio de Janeiro, Dubai, Mumbai and Manila, so a colleague outside the UK may read your enquiry when helping us reply.

When personal data leaves the UK or the European Economic Area, we protect it with an adequacy decision (including the UK Extension to the EU-US Data Privacy Framework where the recipient is certified) or with standard contractual clauses and the UK International Data Transfer Addendum, or another safeguard the law allows. You can ask us for a copy of the relevant safeguards at info@odore.com.

07 How long we keep it

• Demo requests, enquiries and related emails: up to 24 months after our last contact with you. If your organisation becomes a customer, its agreement with us sets how long we keep business contact details.
• Google Analytics data: 14 months.
• Your cookie choice: stored in your own browser for 12 months, after which we ask again.
• Server logs: kept by our host for a short period for security and troubleshooting.
• Records we must keep by law (for example for tax): for the period the law requires.
• Programme data: see section 12. Discovery: see section 13.

08 Keeping it secure

We protect personal data with technical and organisational measures under an information security management system certified to ISO 27001. The Website is served only over encrypted connections. If you think data we hold has been misused, lost or accessed without permission, tell us straight away at info@odore.com.

09 Your rights (UK and EU)

You can ask us for a copy of your data, and ask us to correct it, delete it, restrict how we use it, or move it to another provider. You can object to processing based on legitimate interests, and you can object to direct marketing at any time. Where we rely on consent, you can withdraw it at any time, without affecting what we did before. Email info@odore.com. We will reply within one month and will not charge you unless a request is manifestly unfounded or excessive.

We would like the chance to put things right first, but you can complain to the Information Commissioner's Office (ico.org.uk) or, in the EU, to the data protection authority where you live or work (for example the CNPD in Portugal).

10 Your rights if you live in the United States

This section is our notice at collection for residents of California and other US states with consumer privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA). We offer the rights below to all US residents, whether or not a state law requires it.

What we collect and why. Identifiers and professional information you give us (name, company, work email), internet activity (pages viewed, referring site, device and browser, campaign tags) and approximate location derived from IP address. We collect them from you and from your device, for the purposes in How we use it, and keep them for the periods in How long we keep it.

Selling and sharing. We do not sell personal information for money. If you accept advertising cookies, the LinkedIn Insight Tag shares identifiers and internet activity with LinkedIn for cross-context behavioural advertising, which counts as "sharing" under the CCPA. In the past 12 months, our previous website also shared this kind of data with advertising and analytics providers, including LinkedIn, Meta, Microsoft and Google. You can opt out of sharing at any time using Your privacy choices. We treat a Global Privacy Control signal from your browser as an opt-out and do not load advertising cookies when it is present. We do not knowingly sell or share the personal information of anyone under 16.

Your rights. You can ask to know what personal information we hold and how we use it, and to have it corrected or deleted. You can opt out of sale or sharing. We do not collect sensitive personal information through the Website. We will not treat you differently for using these rights. Email info@odore.com. We verify requests using information we already hold and respond within 45 days. An authorised agent can act for you with your signed permission. If we turn down your request, you can appeal by replying to our decision, and if you are still unhappy you can contact your state attorney general.

11 Your rights in other countries

Visitors come to the Website from many countries. Where a local privacy law applies to our handling of your data, you have the rights it gives you, and you can use them by emailing info@odore.com. In summary:

• Brazil (LGPD): you can ask us to confirm whether we process your data, to access, correct, anonymise, block or delete it, to move it, and to tell you who we share it with, and you can withdraw consent. You can complain to the ANPD.
• India (Digital Personal Data Protection Act 2023): you can ask for a summary of your data and how it is used, ask us to correct, complete, update or erase it, withdraw consent, raise a grievance with us, and nominate someone to act for you. If we do not resolve a grievance, you can go to the Data Protection Board of India.
• Canada (PIPEDA and provincial laws): you can ask for access to your data, ask us to correct it and withdraw consent. You can complain to the Office of the Privacy Commissioner of Canada or your provincial commissioner.
• Philippines (Data Privacy Act of 2012): you have the rights to be informed, to access, to object, to correct, to erasure or blocking, and to data portability. You can complain to the National Privacy Commission.
• United Arab Emirates (Personal Data Protection Law): you can ask for access to your data, and ask us to correct, delete or move it, or to restrict or stop processing it. You can complain to the UAE Data Office.

Wherever you live, you can ask us about your data at info@odore.com.

12 Creators and community members in brand programmes

Who is responsible. Each Programme is run by a brand (the "Brand"). The Brand decides what personal data its Programme collects and why, so the Brand is the controller and its own privacy notice also applies. Odore runs the platform and, where the Brand asks us to, helps run the Programme. When we do this we act as the Brand's processor, on its instructions and under a contract with it. We are a controller in our own right only for keeping the platform secure, preventing fraud and abuse, keeping records the law requires, and the creator Discovery tool described in section 13. Information you give a Programme stays with that Brand and is not added to Discovery or shared with other brands.

Where it comes from. From you; from social media accounts you connect; from the Brand, for example if it invites you; and from public posts you make for a campaign.

What is collected. Depending on the Programme:

• your name, email address, phone number, date of birth or age confirmation, country and preferred language;
• your social media handles and, if you connect an account, the public profile details and statistics that account shares, such as follower numbers, posts and engagement;
• your delivery address, to send you products, and records of what was sent and delivered;
• the content you submit or post for the Programme, such as photos, videos, captions, reviews and comments, and how it performs;
• your answers to the Programme's questions, surveys and sign-up forms, and your points, rewards and campaign history;
• professional details where a Programme is for professionals, such as your job, workplace or licence number, so the Brand can check your credentials;
• messages between you and the Programme by email, WhatsApp, push notification or in the app; and
• technical data such as your device, browser, IP address and how you use the Programme's app or site.

How it is used. To review your application and run the Programme; to invite you to campaigns and send you briefs and reminders; to send you products; to review content against the brief, the Brand's rules and advertising law, including checking that posts are labelled correctly; to award points and rewards; to report to the Brand on how the Programme performs; and to keep the platform secure. Odore's AI tools may score profiles and content, for example for brand safety and fit with a brief, to help the Brand's team decide. People at the Brand or at Odore decide who joins a Programme, who is invited to campaigns and whether content is accepted, helped by these tools. No decision with legal or similarly significant effects is made by automated means alone.

Lawful bases. The Brand sets the lawful basis for its Programme, usually your agreement to the Programme's terms (contract), its legitimate interests, or your consent where the law requires it, for example for marketing. Where we act as a controller, we rely on legitimate interests in keeping the platform secure and preventing fraud, and on legal obligation where the law requires us to keep records.

Who sees it. The Brand and the people it authorises, such as its agencies; Odore colleagues who help run the Programme, in the cities listed in section 6; delivery partners and couriers, who receive your name, address and phone number to deliver products; and the service providers that host and run the platform for us, such as cloud hosting (Amazon Web Services), email and messaging providers (including WhatsApp, where you choose to use it) and AI service providers, all acting under contract. Transfers outside the UK are covered in section 6. Content you post publicly on social media stays subject to that platform's own terms.

How long it is kept. For as long as you are a member of the Programme, and afterwards for the period the Brand sets in its instructions to us, unless the law requires us to keep it longer. If you ask for your data to be deleted, we pass your request to the Brand and delete it on its instructions. If you leave a Programme, we close your account in it.

Your rights. You have the rights described in sections 9 to 11. You can contact the Brand, or email us at info@odore.com. Where we act for the Brand, we will pass your request to the Brand and help it to respond.

13 Creators in Odore Discovery

Odore Discovery is a social listening and search tool that helps brands find creators who fit a brief. It uses information creators have made public on social media, such as their handle, profile, public posts and follower numbers. We use it, on the basis of our legitimate interests and those of the brands we work with, so brands can find creators and invite them to Programmes. We keep it only as long as it is useful for this, and we remove a profile when we learn it belongs to someone under 18.

You can ask us what we hold about you or ask us to remove your profile from Discovery by emailing info@odore.com with your social media handles. You also have the other rights in sections 9 to 11.

14 Children

The Website is for businesses and is not directed at children. We do not knowingly collect personal data from anyone under 16 through the Website. Programmes are for people aged 18 or over unless a Programme clearly says it accepts younger members with permission from a parent or guardian. If you think a child has given us their details, tell us at info@odore.com and we will delete them, or for a Programme ask the Brand to. We remove Discovery profiles that belong to anyone under 18.

15 Links to other websites

The Website links to other sites, such as LinkedIn and the sources quoted in our Journal. Their privacy policies apply when you visit them.

16 Changes to this policy

We will update this policy when our practices change and show the new date at the top. Significant changes will be highlighted on the Website, and if you are in a Programme, we will also tell you there.