Privacy Policy

I. INTRODUCTION

General/briefing

1.1. The protection of your Personal Data and your privacy is of great importance to us. In order to ensure that your Personal Data are handled in accordance with the law and to provide you with appropriate information on how and for what purposes it is processed, we, the company under the name ZERONE Inc. (“Zerone Inc”, “Company”, “we” or “our”) a Delaware corporation located in the Green STE A 1771, Suite #7791 Dover, DE 19901, EIN:38-4065148 Delaware, USA, e-mail: info@odoshells.com, tel: +1 (302) 261.3852, have adopted this Privacy Policy (“Policy”) as a Controller, which is addressed to the users (“Users”, “you”, “you”) of our website (“Website”). You can contact us using the contact details above and submit any comment, question, request or complaint regarding this Policy and the collection and processing of your Personal Data in general. The definitions provided in this Policy derive from General Data Protection Regulation EU/2016/679.

1.2. Below you will find information in relation to the conditions under which we collect and process your Personal Data through our Website, which include:

The categories of Personal Data we collect and process;
The purposes and legal basis for processing: to communicate with you, for keeping our Website secure and for subscribing you to our newsletter;
Your rights and ways to exercise them. In general, as a data subject you have the right to access, rectification, erasure, restriction of processing, right to portability, right to object, right to withdrawal of consent, right to complaint to the competent data protection authority. Though automated decision making is not held by our Company through the use of the Website, we inform you that you have the right to ask for human intervention when automated decision-making including profiling is made.

1.3. This Policy includes the Cookies Policy; therefore, the two policies should be read as a single document. When you visit our Website, including by providing any Personal Data to us, you accept this Policy; by this Policy we provide you information about the collection, use, storage and in general any processing of Personal Data through your interaction with our Website. If you do not agree to the practices described in this Policy, please do not interact with the Website.

COLLECTION AND PROCESSING OF PERSONAL DATA
What data do we collect through the use of our Website and how we collect them?

2.1. We process your Personal Data in accordance with the law and transparently. We only collect data that are adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed. Data are collected for specified, explicit and legitimate purposes; they are not further processed for purposes incompatible with the purposes they were collected initially.

2.2. Through the use of our Website we indicatively collect the below categories of Personal Data:

i) From you when you choose to communicate with us through our contact information:

Identification Data: (name, surname)

Communication Data: (e-mail, telephone number)

ii) Automatically when you interact with our Website:

Data through Cookies: (see Cookie Policy)

What we do with your Personal Data? What is the purpose and legal basis of processing?

3.1. We process your Personal Data for the legitimate purposes based on the respective appropriate legal basis as introduced in the table below:

	Purpose of Processing	Personal Data	Legal Basis
1	Communication with you	Identification Data (name, surname) Communication Data (e-mail, telephone number)	Consent: We process your Personal Data based on your consent to communicate with us at your own initiative by using the contact information of our Company as appear on our Website. You can withdraw your consent at any time by sending an e-mail to the contact details above.
2	Security of our Website	Technical Data	Legitimate interest: Our legitimate interest in taking measures to ensure your safe navigation and lawful use of the Website has been fairly balanced against your rights and freedoms and does not affect them.
3	Subscription to our Newsletter	Communication data (e-mail)	Consent: We collect and process your e-mail when you introduce it in the respective newsletter form that appears on our Website based on your consent and it to inform you regarding our latest news about ODO BODI. You can withdraw your consent at any time unsubscribing from our newsletter by using the respective link introduced in every newsletter you receive.

3.2. Where consent is the legal basis for processing your Personal Data, you can withdraw it at any time so that we stop processing them for that purpose. If you wish to withdraw your consent in relation to the installation and use of specific category of cookies, you can set your preferences in relation to cookies by using the respective button at the cookie banner of the Website. The withdrawal of consent is valid for the future.

3.3. Where our legitimate interest is the basis for the processing, you can object to this processing (opt-out) by contacting us at the contact details above. However, please note that the Company has the right to demonstrate legitimate grounds for the processing, so this will be fairly balanced against your rights and freedoms.

3.4. In case your Personal Data are involved in a dispute, we may retain them and use them as proof for the time period necessary to resolve it, based on our overriding legitimate interest.

3.5. In the event of a security incident and the necessity to conduct investigation to identify if it is a data breach and the competent authority is necessary or there is a need to informing subjects affected by the incident, we process your Personal Databased on our obligation to comply to legal obligation for the said purpose; additionally, we process them in order to record the incident in the relevant internal register/record of the company.

Who do we share your Personal Data with (Recipients)?

4.1. We may disclose your Personal Data by the use of our Website to third parties that we engage as sub-contractors (such as our hosting provider, the developers of our Website etc) after concluding the appropriate processing agreements, according to the role of every third party regarding the processing of Personal Data.

4.2. Additionally, your Personal Data may be disclosed to the competent police and other administrative authorities at their request and in accordance with applicable legislation. In addition, in the event of a legal provision, an order of an agency or an official preliminary investigation, our Company has the right to make available to the competent authority all relevant information.

4.3. We reserve the right to disclose your Personal Data to third parties to whom we choose to transfer all or part of our business. In addition, in the event of a merger, acquisition or other change in our business, the new owners etc. have the right to use your Personal Data in the same way that we use it under this Policy.

4.4. Transfers to third countries: In case our Company needs to be compliant to the obligations introduced by GDPR regarding transfers to third countries without adequacy decision, we conclude the appropriate processing agreements, and take all the necessary contractual, technical and organizational measures that answer to the respective obligations.

III SECURITY AND RETENTION

Security of your Personal Data

5.1. We implement all appropriate technical and organizational measures to protect your Personal Data from unauthorized access, use, alteration or destruction. Where appropriate, we use encryption, pseudonymization and other technologies that can contribute to the security of the data you provide to us.

5.2. Additionally, we internally carry out the processing and management of your Personal Data by specially authorized personnel of the Company. For conducting the necessary processing operations, the Company selects persons or third parties with equivalent professional qualifications under sufficient guarantees of technical knowledge and personal integrity to maintain confidentiality. The Company takes all necessary security measures to protect and ensure the confidentiality and integrity of Personal Data.

5.3. Additionally, we require our sub-contractors/service providers to comply with the necessary privacy obligations under the respective processing agreements.

Time retention

6.1. We will retain your Personal Data for the period of time necessary to fulfil the purposes for which they were collected. Data retention periods may vary depending on the respective purposes of collection and processing, taking into account the nature of the Personal Data, the quantity, purpose, security rules etc.

6.2. You have the right request the deletion of your data; when you request to object to their processing or you withdraw your consent, we are obliged to delete them and not to retain them. We keep the right not to fulfill your respective rights for tax and accounting purposes, or in support of a legal right of our Company, according to the analysis of your rights as introduced in the table below in para. 7.

IV RIGHTS

What are your rights regarding the processing of your Personal Data?

RIGHT of	WHAT IS IT?
Access	You can request from us to: • confirm that our Company processes your Personal Data; • acquire access to those of your Personal Data that we process and receive a copy of them, if this does not affect third parties’ rights; • receive relevant information about their processing such as: what data our Company has, why it uses them, to whom it disclosures them, whether it transfers them to third counties, how it protects them, how long it retains them, what rights you have, how we can submit a complaint, where it has collected them from in case it did not collect them from you, in case you don’t already have the respective information.
Rectification	You can request from our Company to rectify your false or inaccurate Personal Data or update them. In this context the Company has the right to verify the accuracy of the data before it rectifies them and is obliged to inform the recipient to whom Personal Data are notified, unless this proves impracticable or involves a disproportionate effort.
Erasure	You can request your data to be erased when: · you have withdrawn your consent on which the processing is based; · they are no longer needed for the purposes for which they were collected; · in the event that you discover that they are otherwise or unlawfully processed; · if you object to the processing. Our company reserves the right to refuse the exercise of the above right if the processing of the data is necessary a) for the purpose for which they were collected, b) to comply with a legal obligation, c) to establish, exercise or defend legal claims. The erasure, will take place when the above conditions are met.
Restriction	You can ask from our Company to exercise the right of restriction of the processing i.e. your Personal Data to be retained but not to be used when: · their accuracy is contested, so that you can verify their accuracy; · the processing is unlawful but you do not wish to have them deleted; · the processing of the data is no longer necessary for the purposes for which they were collected, but our company still needs them for the establishment, exercise or defense of legal claims; · you object to the processing and you are waiting verification of its effect, i.e. whether our company’s legitimate reasons prevail over your legitimate claims.
Portability	You have the right to ask our Company to provide you with your Personal Data in a structured form or you can request that they be transmitted directly to another data controller. A prerequisite is that your Personal Data must have been provided with consent and that they must be retained by automated means and not in paper form. A further condition is that the data have been provided by you; this term does not apply in case the data have been inferred by our company based on data provided by you.
Objection	You may at any time object to any processing of your Personal Data, which has as its legal basis of the legitimate interest. If you exercise the specific right, our Company should demonstrate compelling and legitimate grounds which override your rights and freedoms or are related to the establishment, exercise or defense of legal claims to continue this processing.
Withdrawal of consent	You have the right to withdraw your consent, where consent is the basis of processing. You can withdraw your consent freely at any time with a request at our Company’s contact data that have been inserted above. The withdrawal of consent is valid for the future.
Right to human intervention	Our Company does not make decisions using a technical means by which (decision) your personal aspects are assessed and is taken solely based on automated processing that produces legal effects against you or similarly significantly affects you. Nor does it make your profiling through automated processing of Personal Data without human intervention. You are hereby informed that you have the right to request human intervention in decision-making through automated processing and to express your point of view on the decision.
Supervisory authority/Alternative forms of dispute resolution	You have the right to submit your complaints or accusation to the local supervisory authority about your processing of Personal Data. Since the protection of your privacy is a priority for our company, you can contact our company at any time and for any issue or complaint regarding the processing of your Personal Data. In addition, our company suggests that you choose alternative dispute resolution – mediation as a more flexible means of resolving disputes between you and our company.

What procedure do we keep to fulfill your rights?

8.1. Identification: We aim to maintain a high level of confidentiality of your Personal Data, therefore we reserve the right to ask you for some information to prove your identity, if you request to exercise your rights in relation to such files.

8.2 Specific requests: Your request must include specific and true information and/or actual facts in order for us to respond and/or satisfy it accurately. Otherwise, our Company reserves the right to refuse requests that are unfounded, excessive, abusive or illegal.

8.3 Schedules: We will respond to your valid and accurate requests within one (1) month of their receipt, unless they are particularly complex or a series of requests have been submitted together. If we need more time to respond to your request, we will notify you as to that within the month; in that case we shall fulfill your rights in three (3) months’ time.

8.4 Costs: We will not charge you any costs for exercising your rights in relation to your Personal Data unless, as provided by law, your request for access to information is unfounded or excessive, in which case we have the right to charge a reasonable fee under the specific circumstances. In any case, we will inform you of any charges before we complete your request.

8.5. Contact: You can contact us at the details mentioned above and submit to us your comments, questions, remarks or any complaints regarding this Policy and the collection and processing of your Personal Data in general.

Amendments

9.1. We reserve the right to modify this Policy at our discretion in order to respond to the obligation of new legislation or different procedures we adopt regarding the processing of your personal data, i.e. when we may add new services on our Website or differentiate its scope, its function or its characteristics.

9.2. If you continue to browse our Website or use its services you confirm that you accepted all its amendments. Please read this Policy carefully and check back periodically to obtain the latest information on the protection of your Personal Data by the use of this Policy.

9.3. If you wish to be provided with any clarification or information or have any reservations or questions about, you can contact us at the contact details listed above. Please note that any information/clarification regarding changes to this Policy provided to you in the manner described above does not constitute a replacement or any amendment to this Policy.