Odro Product Privacy Notice
Effective Date: 10th September 2020
The purpose of this notice is to detail how we process data on behalf of our customers for all Odro products and services.
Scope
This Product Privacy Policy does not apply to any information or data collected by Odro as a controller for other purposes, such as information collected on our websites or through other channels for marketing purposes. Please find the Odro Privacy Policy that covers this information or data by clicking here.
Definitions
Candidate – An individual who is the subject in any recording, meeting or job application discussing their profession and career opportunities.
End Users – An individual who is the subject in any recording, meeting or other usage of Odro Properties.
Inactive – No active subscription for, or ongoing legal obligation / interest.
Odro Properties – Odro Vision (including integrations), Odro Capture, Odro Producer.
Odro User – An authorised individual with access (user account) to the management and data held within Odro Properties on behalf of an organisation.
How to Contact Us
Data Protection Officer: Mark Beeby
Email Address: compliance@odro.co.uk
Address: Odro Ltd | G1 Templeton House, 62 Templeton Street, Glasgow, G40 1DA |
Telephone: 0141 465 9470
Website: www.odro.co.uk
What Information Do We Collect?
Odro collects only the information required to provide products and services to you. The amount of information provided by you and collected by Odro depends on the circumstances. Odro collects two (2) types of information about you: Personal and Non-Personal.
- “Personal Information.” Personal Information means any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual. Odro will collect Personal Information when you use the Odro Properties, please refer to the table below for details.
- “Non-Personal Information.” Non-Personal Information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or website visitations). Odro will collect Non-Personal Information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.
Personal Data Type
All gathered through Odro Properties with a retention period of 2 years once a client becomes inactive:
All Users: IP Address, Location (estimated), Device information and Browser/ Operating System information.
Candidate / End User Data: Name, E-mail, IP Address, Location (estimated), Video Recordings (containing special category data), CV and other Identity Documentation.
Odro User Data: Name, Title, Username, Email Address, Likeness (profile photo, Video Recordings (containing special category data) and telephone contact.
How Will We Use Your Data?
- Personal Information: Odro identifies the purpose for which your Personal Information is collected and will be used or disclosed. If that purpose is not listed below, we will identify any additional purposes for which we will collect your Personal Information, before or at the time of collection, and we will obtain your consent to collect, use and / or disclose your Personal Information for such additional purpose(s).
- By using the Odro Properties, you will be deemed to consent to our use of your Personal Information for the purposes of:
- communicating with you generally;
- processing your purchases;
- processing and keeping track of transactions and reporting back to you;
- protecting against fraud or error;
- providing information or services requested by you;
- administering and managing the Odro Properties and our business operations;
- personalizing your experience with the Odro Site and Odro Properties, and evaluating aggregate statistics across Odro Properties;
- performing statistical analyses of your behavior and characteristics, in order to measure interest in and use of the various sections of Odro Site and Odro Properties;
- communicating with you on other websites;
- email gating;
- delivery of content and information to Third Party Services Providers;
- complying with governmental and legal requirements of the United Kingdom
- managing and delivering content collected by Odro Properties to authorised viewers
- Otherwise, we will obtain your express consent (by verbal, written or electronic agreement) to collect, use or disclose your Personal Information. You can change your consent preferences at any time by contacting us (see the “How to Contact Us” section).
- Odro extends the rights granted to “data subjects” under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) to all of its Users. Consequently, you have the right to withdraw your consent to our processing of your Personal Information at any time (if our processing is based on consent) and the right to object to our processing of your Personal Information (if processing is based on legitimate interests).
- Non-Personal Information. Odro may use Non-Personal Information for the following purposes:
- System Administration: Odro may use Non-Personal Information for the purposes of system administration, assisting in diagnosing problems with Odro servers, monitoring Odro’s system performance and traffic on the Odro Properties and to gather broad demographic information about Odro Users.
- Personalization: Odro uses cookies and IP addresses to track features such as delivering Content specific to your location and interests and informing you of new, relevant services or certain third party offerings.
- Advertising: Odro may use Non-Personal Information to assist in optimizing the delivery of advertisements to viewers of your Content.
How Do We Store Your Data?
Odro takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of Personal Information. These include, but are not limited to, internal reviews of: (a) Odro’s data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Odro stores Personal Information.
All Odro employees, contractors and agents who access Personal Information are bound by contractual confidentiality obligations and may be subject to discipline, including termination and criminal prosecution for unauthorized use or disclosure of Personal Information.
Personal information held by Odro is stored on and processed on computers situated in Ireland, the United Kingdom and the EEA. Where usage of Odro Properties occurs outside of the EEA, providers of Odro Properties will process data outside of the EEA, see “Disclosure Of Information To Third Parties. Any data processed outside of the EEA is immediately transferred into the EEA.
Odro utilises Amazon Web Services (AWS) and processes all data through the Ireland data centres. Amazon’s content delivery network will be used to optimise the delivery of content around the world when usage occurs outside of the EEA. All data accessed in this manner is still stored securely, with authentication and encryption maintained end to end. Amazon Web Services is a fully GDPR, SOC2 and ISO 27001 compliant infrastructure.
Data Retention
Odro retains the Personal Information that we collect about you for as long as reasonably necessary for the purposes set out in this Privacy Policy. We also may retain your Personal Information for a longer period of time on the basis of our legitimate interests in providing or marketing our services to you; or as necessary to comply with our legal obligations; to resolve disputes; and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use information that has been aggregated and anonymized in such a way it can no longer be used for personal identification.
Odro Users can configure a custom retention period to trigger the automatic deletion of data according to their own policies. This is available to administrators via the Odro Vision dashboard. Where the custom retention period feature is not activated then the following retention information applies:
Personal Data Type
All gathered through Odro Properties with a retention period of 2 years once a client becomes inactive:
All Users: IP Address, Location (estimated), Device information and Browser/ Operating System information.
Candidate / End User Data: Name, E-mail, IP Address, Location (estimated), Video Recordings (containing special category data), CV and other Identity Documentation.
Odro User Data: Name, Title, Username, Email Address, Likeness (profile photo, Video Recordings (containing special category data) and telephone contact.
Sub-processors
The following is an up-to-date list of the names of Odro’s key sub-processors and the purposes for which they process personal data.
| Name | Purpose |
|---|---|
| Amazon Web Services (AWS) aws.amazon.com |
Provides key hosting infrastructure for Odro's application(s) and website(s). |
| Hubspot Hubspot.com |
Customer relationship management used to provide services and support to Odro’s product(s).. |
| Transloadit transloadit.com |
Media transcoding services used by Odro product(s) to reformat and process files into acceptable web-standard assets. |
| Vonage www.vonage.co.uk |
Media broadcast services used by Odro product(s) to connect and record video feeds within Odro product(s). |
| ChargeBee chargebee.com |
Provides billing functionality to Odro’s product(s). |
| Stripe stripe.com |
Payment processing service. |
| Go Cardless gocardless.com |
Payment processing service. |
| OpenAI openai.com |
AI Provider (optional)
Odro has opted out of storing data and revoked permission for training on data provided as part of our service(s). Data provided to large language model powered services will be used in accordance with our data privacy addendum with OpenAI, in compliance with EEA and UK data processing laws.. |
| Sentry sentry.io |
Application logging, processing and reporting services.. |
Disclosure of Information to Third Parties
International transfers to third parties
Some of the activities described in this privacy policy, which are provided services to Odro under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. Odro ensures that all processors of data comply with laws applicable to the United Kingdom and EEA using European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, EU adequacy decisions, or other appropriate legal mechanisms to safeguard the transfer.
What Are Your Data Protection Rights?
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Changes to Our Privacy Policy
The terms in this Privacy Policy may be changed from time to time, so you should review it periodically for changes. We reserve the right, at any time, to modify or replace this Privacy Policy. The date of the most recent version of the Privacy Policy is noted below under “Effective Date of this Privacy Policy.” We may also notify you via email or other direct electronic communication method of any changes that, in our sole discretion, materially impact your use of the Odro Properties or the treatment of your Personal Information. Your use of the Odro Properties following the posting of any changes to the Privacy Policy constitutes acceptance of those changes.
How to Contact the Appropriate Authorities
You can complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
