Effective Date: May 1, 2023
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
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:
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
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
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.
We may disclose Personal Information to our Affiliates for the purposes described in this
Privacy Policy. ODAG, Inc. is the party responsible for the management of the jointly-used
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
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
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 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 .
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
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 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 . 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:
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
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
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
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 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
o For transfers to third parties in the United States, ensuring they participate in
the EU-US Privacy Shield Framework.
Please contact Info@pr; if you want further information on the
specific mechanism used by us when transferring your personal information out of the EEA.