Effective Date: May 1, 2023

www.orlandodigitalartgallery.com/u/privacypolicy

Including for Users Outside the United States

Orlando Digital Art Gallery (“ODAG” or “We“) know that you care about how the information

we receive from you is used and shared, and we take your privacy seriously. This Privacy

Policy describes ODAG’s privacy practices in relation to information that we collect through

websites operated by us from which you are accessing this Privacy Policy, located at [site

specific link to PP] and all related websites, our applications and/or APIs, and online

services (collectively, the “Domains”), through our social media pages (collectively, the

“Social Media Pages”), as well as through HTML-formatted email messages that we send

to you that link to this Privacy Policy (collectively, including the Domains, and the Social

Media Pages, the “Sites”). “You” or a “user” refers to any individual who visits or otherwise

uses the Sites. By using the Sites, you are accepting and agreeing to the practices outlined

in this Privacy Policy. If you do not agree with the data practices described in this Privacy

Policy you should not use our Services. This Privacy Policy does not apply to any third party

applications or software that integrate with the Services through our Site (“Third Party

Services”) or any other third party products, services, or businesses.

1. What Types of Information Does ODAG Receive From its Users?

o Personal Information. “Personal Information” is information that identifies

you as an individual or relates to an identifiable individual, including: name,

title, company name, job function, expertise, postal address, telephone

number, physical address, email address, content you post on our Site(s)

(text, images, photographs, messages, comments or any other kind of

content that is not your e-mail address). It can also include transaction

information, such details about purchases you make through the Site(s),

registrations you make through our Site(s), and billing details as well as

usage information, such as information about how you use our Site(s) and

interact with us. If you submit any Personal Information relating to other

people to us or to our service providers in connection with the Site(s), you

represent that you have the authority to do so and to permit us to use the

information in accordance with this Privacy Policy.

o Other Information. “Other Information” is any information that does not

reveal your specific identity or does not directly relate to an identifiable

individual. This might include, for instance, browser and device information;

information collected through cookies, pixel tags, and other technologies;

demographic information and other information provided by you; or

aggregated information. We use this information to facilitate our operation of

the Sites and for other purposes described below.

o IP Address. Your “IP Address” is a number that is automatically assigned to

the computer that you are using by your Internet Service Provider (ISP). An

IP Address may be identified and logged automatically in our server log files

whenever you access the Sites, along with the time of the visit and the

page(s) that you visited. Collecting IP Addresses is standard practice and is

done automatically by many websites, applications and other services. ODAG

uses IP Addresses to calculate usage levels of the Sites, help diagnose

problems with its servers, administer the Sites, and monitor the regions from

which you navigate to ODAG’s Sites.

2. How Does ODAG Collect Information?

Personal Information. We may collect Personal Information in a variety of ways, including:



o Through the Sites: We may collect Personal Information through the Sites,

e.g., when you request a catalog, contact us, subscribe to our email

newsletter, download content (e.g. free eBooks), or register to use our Sites.

o Offline: We may collect Personal Information from you offline, such as during

phone calls with sales representatives, or when you contact customer

service.

o Through You: ODAG may collect information such as your location or your

preferred means of communication when you voluntarily provide it. It also

includes feedback and correspondence, such as information you provide in

your responses to surveys, when you participate in market research activities,

report a problem with our Site, receive customer support or otherwise

correspond with us. Unless combined with Personal Information, this

information does not personally identify you or any other user of the Sites.

Note that there is no legal obligation for you to provide us with personal

information and any information collected by us will be provided by you at

your own will and with your consent.

o Information From Other Sources: In order to enhance our ability to provide

relevant marketing, offers, and services to you, we may obtain information

about you from other sources such as joint marketing partners, social media

platforms, as well as from other third parties. Some of our Site(s) include

interfaces that allow you to connect with social networking sites (each a

“SNS”). If you connect to a SNS through our Site you authorize us to access,

use, and store the information that you agreed the SNS could provide to us

based on your settings on that SNS. We will access, use, and store that

information in accordance with this Notice. You can revoke our access to the

information you provide in this way at any time by amending the appropriate

settings from within your account settings on the applicable SNS.

Other Information. We may collect Other Information in a variety of ways, including:



o Through Your Browser or Device: Certain information is collected by most

browsers or automatically through your device, such as your computer type

(Windows or Macintosh), screen resolution, operating system name and

version, device manufacturer and model, language, Internet browser type and

version, and the names(s) of the ODAG Sites you are using.

o Through Cookies and Other Similar Technologies: Cookies and other

similar technologies may be used to collect Other Information. We use

essential cookies to provide you with services available through our

Site(s). We use analytics and performance cookies to collect information

about traffic to our Site(s) and how users use our Site(s). We use social

media cookies when you share information using a social media site sharing

button or action. We may use third parties to serve advertisements on other

websites that may be of interest to you, based on information collected about

your use of our Sites and other websites. To do so, these companies may

place or recognize a unique cookie on your browser (including through the

use of pixel tags and web beacons). ODAG does not recognize automated

browser signals regarding tracking mechanisms, which may include ‘do not

track’ instructions.

ODAG also uses a web analytics service, currently Google Analytics.

Google Analytics is a web analytics service provided by Google Inc. (“Google“). Google

Analytics uses cookies and similar technologies to analyze how users use the Domains.

The information generated about Domain usage (including your shortened IP address) is

transmitted to Google in the U.S. This information is used to evaluate visitors’ use of the

Domain, compile statistical reports on Domain activity, and provide other services related to

the Site and Internet use. Google may also collect information about Domain visitors’ use of

other websites. For more information about Google Analytics, or to opt out of Google

Analytics, please go to:https://tools.google.com/dlpage/gaoptout.



o By Aggregating Information: Aggregated Personal Information does not

personally identify you or any other user of the Sites (for example, we may

aggregate Personal Information to calculate the percentage of our users who

have a particular telephone area code).

Disabling cookies. You can typically remove or reject cookies via your browser

settings. In order to do this, follow the instructions provided by your browser (usually

located within the “settings,” “help,” “tools,” or “edit” facility). Many browsers are set to

accept cookies until you change your settings. Further information about cookies, including

how to see what cookies have been set on your computer or mobile device and how to

manage and delete them, visit www.allaboutcookies.org.

If you do not accept our cookies, you may experience some inconvenience in your use of

our Site(s). For example, we may not be able to recognize your computer or mobile device

and you may need to log in every time you visit our Site(s).

Pixel tags. We may also use pixel tags (which are also known as web beacons and clear

GIFs) on our Site(s) to track the actions of users on our Site(s). Unlike cookies, which are

stored on the hard drive of your computer or mobile device by a website, pixel tags are

embedded invisibly on webpages. Pixel tags measure the success of our marketing

campaigns and compile statistics about usage of the Site, so that we can manage our

content more effectively. The information we collect using pixel tags is not linked to our

users’ personal information.

3. How Does ODAG Use Personal Information?

We may use Personal Information:



o To operate, maintain, administer, and improve our Site(s).

o To respond to your inquiries and fulfill your requests, including to track and

administer services you have required and to send you newsletters.

o To send administrative information to you, for example, to confirm orders or

notice of a license or subscription expiration.

o To communicate with you, better understand your needs and interests,

personalize our experience with the Site(s), and provide you with related

customer service.

o To send you marketing communications, including via email in compliance

with applicable laws, that we believe may be of interest to you.

o To personalize your experience on the Sites by presenting products and

offers tailored to you.

o To provide support and maintenance for the Site(s) and our services.

o For our business purposes, such as data analysis, audits, fraud monitoring

and prevention, developing new products, enhancing, improving or modifying

our Sites and services, sending you service announcements, technical

notices, updates, security alerts, identifying usage trends, determining the

effectiveness of our promotional campaigns and operating and expanding our

business activities.

o As we believe to be necessary or appropriate: (a) under applicable law,

including laws outside your country of residence; (b) to comply with legal

process; (c) to respond to requests from public and government authorities

including public and government authorities outside your country of

residence; (d) to enforce our terms and conditions; (e) to protect our

operations or those of any of our Affiliates; (f) to protect our rights, privacy,

safety or property, and/or that of our Affiliates, you or others; and (g) to allow

us to pursue available remedies or limit the damages that we may sustain.

o We may use or share your personal information with your prior consent, such

as when you: consent to participate in surveys, let us post your testimonials

or endorsement on our Site(s), instruct us to take a specific action with

respect to your personal information, or opt into third party marketing

communications.

o We may disclose or use aggregated or de-identified information for any

purpose. For example, we may share aggregated or de-identified information

with prospects partners, or sponsors for business or research purposes, such

as when we analyze and report on demographic trends to measure our

objective of having healthy diversity ratios across our programs.

4. How Will ODAG Share Personal Information It Receives?

Information about our users is an integral part of our business. We only share your Personal

Information as described in this Privacy Policy.

Affiliates:

We may disclose Personal Information to our Affiliates for the purposes described in this

Personal Information.

ODAG Social Media Pages:

Personal Information may also be disclosed by you through the Sites, chat, and profile

pages to which you are able to post information and materials. This information may appear

in public ways, such as through search engines or other publicly available platforms, and

may be “crawled” or searched by third parties. Please do not post any information that you

do not want to reveal to the public at large.

Business Transfers:

In some cases, we may buy or sell assets or businesses. In these types of transactions,

user information is typically one of the business assets that is transferred. ODAG may

disclose Personal Information to a third party in the event of any reorganization, merger,

sale, joint venture, assignment, transfer, or other disposition of all or any portion of our

business, assets, or stock (including in connection with any bankruptcy or similar

proceedings).

Protection of ODAG and Others:

We may release Personal Information when we believe that release is necessary or

appropriate (a) under applicable law, including laws outside your country of residence; (b) to

comply with legal process; (c) to respond to requests from public and government

authorities including public and government authorities outside your country of residence;

(d) to enforce or apply our conditions of use and other agreements; (e) to protect our rights,

privacy, safety or property, and/or that of you or others and operations or those of any of our

Affiliates; (f) to protect, investigate, and deter against fraudulent, harmful, unauthorized,

unethical or illegal activity; (g) to allow us to pursue available remedies or limit the damages

that we may sustain; and (h) to protect the rights, privacy, property, or safety of ODAG, our

employees, our Affiliates, our users, or any other person or entity. This includes exchanging

information with other companies and organizations for fraud protection and credit risk

reduction.

5. How Does ODAG Use and Disclose Other Information?

We may use and disclose Other Information for any purpose, except where we are required

to do otherwise under applicable law. If we are required to treat Other Information as

Personal Information under applicable law, then we may use it for all the purposes for which

we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as

combining your name with your geographical location). If we do, we will treat the combined

information as Personal Information for as long as it is combined.

6. How Does ODAG Secure Personal Information About Me?

We have implemented organizational, technical, and administrative measures to protect

Personal Information within our organization, including security controls to prevent

unauthorized access to our systems. While we take reasonable steps to secure your

Personal Information from loss, misuse, interference and unauthorized access, modification

and disclosure, you should be aware no security procedures or protocols are ever

guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore

always some risk assumed by sharing Personal Information online. If you have reason to

believe that your interaction with us is no longer secure (for example, if you feel that the

security of your account has been compromised), please immediately notify us in

accordance with the “Questions, Concerns and Complaints” section below.

7. How Can I Correct or Remove Information About Me?

If you feel that any Personal Information about you that has been collected and stored by

ODAG is incorrect, or if you would Personal Information about you removed from our

systems, please notify us at Info@orlandodigitalartgallery.com so that we may consider

and respond to your request in accordance with applicable law. You may also request

access to your Personal Information held by ODAG, by sending a written request to

info@orlandodigitalartgallery.com .

For your protection, we may only implement requests with respect to the Personal

Information associated with the particular email address that you use to send us your

request, and we may need to verify your identity before implementing your request. We will

try to comply with your request as soon as reasonably practicable, subject to applicable law.

Please note that we may need to retain certain information for record keeping purposes

and/or to complete any transactions that you began prior to requesting such change or

deletion.

8. For How Long Will ODAG Retain My Personal Information?

We will retain your Personal Information for the period necessary to fulfill the purposes for

which collected and as outlined in this Privacy Policy unless a longer retention period is

required or permitted by law.

9. What Choices Do I Have?

You can always opt not to disclose information. However, if you elect to do so, we may be

limited in responding to your inquiry or providing services to you.

You may opt-out of receiving marketing messages from ODAG or our Affiliates by sending

an email to info@orlandodigitalartgallery.com by unsubscribing through the unsubscribe or

opt-out link in an email. We will try to comply with your request(s) as soon as reasonably

practicable. Please note that if you opt-out of receiving marketing-related emails from us,

we may still send you important administrative messages.

10. Third Party Sites

The Sites may permit you to link to other websites on the Internet through direct links or

through applications such as “share” or “Like” buttons, and other websites likewise may

contain links to the Sites. The information practices or content of such other websites is

governed by the privacy statements of those websites and not by this Privacy Policy. We

encourage you to review the privacy policies found on such other websites, services, and

applications to understand how your information may be collected and used.

11. Sensitive Information

We ask that you not send us or disclose any sensitive Personal Information (e.g., social

security numbers) on or through the Sites or via other means.

12. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to

periodically review this page for the latest information on our privacy practices. If we make

material changes to this Privacy Policy we will communicate that a change has been made

to the policy in a reasonable manner which may include posting a notice on our web page,

blog, specific announcement on this page, and/or posting the new Privacy Policy here.

Any modifications to this privacy Policy will be effective upon our posting of the new terms

and/or upon implementation of the new changes on the Site(s) (or as otherwise indicated at

the time of posting). In all cases, your continued use of the Site(s) and/or our services after

the posting of any modified Privacy Policy indicates your acceptance of the terms of the

modified Privacy Policy.

13. Children’s Privacy. Our Products, Services, and Site(s) are not directed to children

under the age of 13, and we do not intentionally gather personal information from visitors

who are under the age of 13 and such individuals are prohibited hereby from providing

personal information, without their parental or guardian’s consent. If a parent or guardian

becomes aware that his or her child has provided us with information without their consent,

he or she should contact us at the contact information provided above. We will delete such

information from our files as soon as reasonably practicable.

14. Questions, Concerns or Complaints: Contact Us. Your privacy is important to us. If

you have any questions, concerns, or complaints regarding the way we collect and handle

your information, please contact us by email at info@orlandodigitalartgallery.com . Because

email communications are not secure, please do not include credit card information or other

sensitive information in your emails to us.

ODAG will take any privacy complaint seriously and any complaint will be assessed by an

appropriate person with the aim of resolving any issue in a timely and efficient manner. We

request that you cooperate with us during this process and provide us with any relevant

information that we may need.

For Users Outside of the United States

ODAG is headquartered in the United States. Your information, including personal

information that we collect from you, may be transferred to, stored at and processed by us

and our affiliates and other third parties outside the country in which you reside, including,

but not limited to the united States, where data protection and privacy regulations may not

offer the same level of protection as in your jurisdiction. We will take all reasonable steps to

ensure that your data is treated securely and in accordance with this Policy.

References to “personal information” in this Privacy Policy are equivalent to “personal data”

governed by European Union data protection legislation. We use the following safeguards if

ODAG transfers personal information origination from the European Union to other

countries not deemed adequate under applicable data protection law:

Controller

ODAG is the controller of your personal information for purposes of European data

protection legislation. See the Contact Us section above for contact details.

Legal Bases for Processing Personal Information

We only use your personal information as permitted by law. We are required to inform you

of the legal bases of our processing of your personal information. Such legal basis

includes:



o To provide our Services. Processing is necessary to perform the contract

governing our provision of the Services or to take steps that you request prior

to signing up for the Services.

o To communicate with you, create aggregated or de-identified information, and

for compliance, fraud prevention, and safety. These processing activities

constitute our legitimate interests. We make sure we consider and balance

any potential impact on you (both positive and negative) and your rights

before we process your personal information for our legitimate interests. We

do not use your personal information for activities where our interests are

overridden by the impact on you (unless we have your consent or are

otherwise required or permitted to by law).

o To comply with law. Processing is necessary to comply with our legal

obligations.

o With your consent. Processing is based on your consent. Where we rely on

your consent you have the right to withdraw it anytime in the manner

indicated in this policy or by contacting us

at info@orlandodigitalartgallery.com

o Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy

where permitted by law and the reason is compatible with the purpose for which we

collected it. If we need to use your personal information for an unrelated purpose, we will

notify you and explain the applicable legal basis.

Your Rights

European data protection laws give you certain rights regarding your personal

information. You may ask us to take the following actions in relation to your personal

information that we hold:



o Opt-out. Stop sending you direct marketing communications. You may

continue to receive service-related and other non-marketing emails.

o Access. Provide you with information about our processing of your personal

information and give you access to your personal information.

o Correct. Update or correct inaccuracies in your personal information.

o Delete. Delete your personal information.

o Transfer. Transfer a machine-readable copy of your personal information to

you or a third party of your choice.

o Restrict. Restrict the processing of your personal information.

o Object. Object to our reliance on our legitimate interests as the basis of our

processing of your personal information that impacts your rights.

You can submit these requests by email to info@orlandodigitalartgallery.com or our postal

address provided above. We may request specific information from you to help us confirm

your identity and process your request. Applicable law may require or permit us to decline

your request. If we decline your request, we will tell you why, subject to legal restrictions. If

you would like to submit a complaint about our use of your personal information or response

to your requests regarding your personal information, you may contact us at or submit a

complaint to the data protection regulator in your jurisdiction.

Cross-Border Data Transfer

Whenever we transfer your personal information out of the European Economic Area

(“EEA”) to countries not deemed by the European Commission to provide an adequate level

of personal information protection, the transfer will be based on one of the following

safeguards recognized by the European Commission as providing adequate protection for

personal information, where required by EU data protection legislation:



o Contracts approved by the European Commission that impose data

protection obligations on the parties to the transfer. For further details, see

European Commission Model contracts for the transfer of personal

information to third countries.

o For transfers to third parties in the United States, ensuring they comply with

EU legal data transfer protections and the transfer complies with such legal

requirements.

o For transfers to third parties in the United States, ensuring they participate in

the EU-US Privacy Shield Framework.

Please contact Info@pr;andodigitalartgallery.com if you want further information on the

specific mechanism used by us when transferring your personal information out of the EEA.