Privacy Notice

Odyssey (“Odyssey”, “we”, or “us”) is committed to protecting the privacy of our
customers, service providers, and website users, and we take our data protection
responsibilities with the utmost seriousness.

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This Privacy Notice describes how Odyssey processes your personal data through
the Odyssey websites and applications that are referenced in this Privacy Notice. It
also informs you of how you can exercise your privacy rights, as applicable.

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1. Collection of personal data

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In the course of providing our Services, particularly for compliance with Know Your
Customer (KYC), Anti-Money Laundering (AML), and account management
obligations, Odyssey processes the following categories of personal data ("Personal
Data"):

• Identity Data: Full legal name, date of birth, nationality
• Contact Data: Email address, telephone number, and postal address
• Financial Data: Source of funds information, investment amount, and
  accredited investor status verification
• Technical Data: Wallet addresses, blockchain transaction history, IP
  addresses, and device information associated with your use of the Services

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2. Purpose of processing

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Odyssey processes your Personal Data for the following purposes:

• To provide, manage, and improve the Services and your access to the vault
  interface
• To comply with legal and regulatory obligations, including Anti-Money
  Laundering (AML), Counter-Terrorism Financing (CTF), and sanctions
  screening requirements
• To verify your identity and investor accreditation status
• To process deposits and redemptions
• To communicate with you regarding account activity, security updates, service
  changes, or settlement processing
• To prevent fraud, money laundering, and other illegal activities
• To ensure the security and integrity of the Odyssey infrastructure

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3. Legal basis for processing

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We process your Personal Data based on:

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• Contractual necessity: To fulfill our obligations under these Terms
• Legal compliance: To satisfy regulatory requirements including AML/CTF
  laws
• Legitimate interests: To operate our business, prevent fraud, and ensure
  platform security

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4. Data retention

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Your Personal Data is retained for as long as:

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• You maintain an active relationship with Odyssey
• Required to comply with applicable legal and regulatory obligations
• Necessary to resolve disputes or enforce our agreements

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5. Data sharing and disclosure

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Odyssey acts as the Data Controller. We do not sell, rent, or trade your Personal
Data. However, we may share your Personal Data with:

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• Service Providers: Including Lagoon Finance (platform infrastructure), third-
  party KYC/AML verification providers, and professional advisors (legal,
  accounting) who assist in service delivery
• Regulatory Authorities: When required by law, court order, subpoena,
  governmental request, or to comply with regulatory investigations
• Blockchain Networks: Wallet addresses and transaction data are publicly
  visible on blockchain networks by their nature

All third-party service providers are contractually obligated to maintain confidentiality
and use your Personal Data only for specified purposes.

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6. Internal data transfers

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Your Personal Data may be transferred to and processed in jurisdictions outside your
country of residence, including jurisdictions that may have different data protection
standards. We implement appropriate safeguards to protect your data in accordance
with applicable law.

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7. Cookies

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Odyssey uses cookies and similar tracking technologies to ensure the proper
functioning of our websites, enhance user experience, analyze website usage, and
support our security and compliance efforts.

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Legal basis for cookies:
Strictly necessary cookies are processed based on our legitimate interests in
operating a secure and functional website. All other cookies are used only where you
have provided your consent, in accordance with applicable data protection and
Privacy laws.

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8. Your rights

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Subject to applicable data protection laws, you have the right to:

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• Request access to your Personal Data
• Request correction of inaccurate or incomplete data
• Request deletion of your Personal Data ("Right to be Forgotten"), subject to our legal obligations to retain certain records
• Object to or restrict the processing of your data
• Lodge a complaint with a supervisory data protection authority

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To exercise your rights or for any privacy-related inquiries, please contact us at:
Email: dpo@odysseydigitalam.com

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