Privacy Policy


What does this Privacy Policy cover?

Odin( “Odin”, “we” or “us”) privacy policy describes the privacy practices of Odin and Odin’s Website and app(s), as well as our products, online services, and apps that include a link to this policy (we refer to our products, online services, and apps as “applications”). This privacy policy also applies to Odin ’s marketing and advertising practices. Any person who does not agree to be bound by this Privacy Policy should not create a user account or interact with the Website.


What Is Your Personal Data ?

Personal data is any information that relates to a living individual who can be identified from that information either by the information alone or together with any other information likely to come into (or already in) our possession. The obtaining, storing and use of personal data is governed by the General Data Protection Regulation 2016/679.


What information does Odin collect about me?

We collect the following types of Personal Information, all of which the user chooses to opt in to:
We may collect, receive, use, store and transfer the following kinds of personal data about you: 

• Identity Data including information about your identity such as name, address, date of birth, username or similar identifier, title, gender.

• Contact Data including where you live and how to contact you including: address, email address and telephone numbers.

• Technical Data Data including details about the devices and technology you use including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or services.

• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences ie: by choosing to log in via Facebook or Twitter


How does Odin collect Personal Information?

We use different methods to collect data about you including through the Information you give us:

• By phone, post, email, online or by other means;

• By use of or access to our websites or device applications;

• By emails, letters and other correspondence;

• By Surveys or when you give us feedback; and

• When you request marketing to be sent to you by us or selected third parties.

 We may automatically collect Technical Data about your equipment, browsing actions and patterns as well as employ the use of cookies and similar technologies for certain types of User Account Information.


Why does Odin Collect and Use Personal Information?

We have a table below, that gives a description of why we collect certain types of data & the ways we plan to use your personal data, and the basis for processing your personal information and the legal basis as governed by the General Data Protection Regulation 2016/679.



Data   Type

Basis   for Processing


To   communicate with you over phone or email.

(a)   Identity

(b) Contact
(c) Marketing and Communications

Consent   in relation to marketing communications


To   use and improve our website and products/services (including troubleshooting,   data analysis, testing, system maintenance, support, security, reporting,   complying with our regulatory obligations and hosting of data)

(a)   Identity
(b) Contact
(c) Technical

(a)   Necessary for our legitimate interests (for running business, administration   and IT services, network security, to prevent fraud and in the context of a   business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation


To   give you, or allow selected third parties to give you, information about   goods and services we think you may be interested in.

(a)   Identity
(b) Contact
(c) Marketing and Communications
(d) Technical

(a)   Consent in relation to marketing communications
(b) Necessary for our legitimate interests (to study how customers use our   products/services)


Who Odin May Share Personal Information With?

As part of providing you with our services and running our business, we may disclose your personal information to:

· Any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries as reasonably necessary for the purposes, and on the legal bases, detailed in this policy;

· Our agents, advisors and business partners who we use to help manage our services, improve services and resolve issues such as legal disputes;

· Government authorities and bodies, supra-national authorities and bodies, crime investigation agencies, courts and others who ask us to disclose that information as required by law

· Any party linked with you or your business’s products or services;

· Organisations we introduce you to for marketing purposes; and

· Analytics and search engine providers that assist us in the improvement and optimisation of our website.

 We may disclose your personal information to the above mentioned third parties:

· If we are under a duty to disclose or share your personal data in order to comply with a specific legal obligation; and

· To enable us to run our website and offer our services to you.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


What is Odin’s responsibility for Privacy Practices of third parties?

This Privacy Policy only applies to the Odin website it does not apply to third-party websites, plug-ins and applications that have been linked to or from or are redirected to or from this website regardless of whether nor not such a link or redirection is authorised by Odin. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Visiting or using any third-party websites, plug ins or applications is done so at your own risk and we are not responsible for the results or their privacy policy. When you leave our website, we encourage you to read the privacy notice of every website you visit.


How can I review, update, or delete my personal information?

You may correct or update certain aspects of your Personal Information via your device’s general settings. This is where you can control what information appears on the device you are using. You can also delete and download the app again in order to choose your personal settings again.
You may close an account and make request for deletion of your data where it is no longer required for us to retain such data, however we reserve the right to retain on our systems your personal data for as long as necessary to enable the completion of transactions, maintaining of records for financial reporting purposes, complying with our legal obligations, resolving disputes, and enforcing agreements. We will not hold or process your data for longer than is reasonably required by law.


Consent to Process Your Personal Information

By registering with our service through the website, plugin or application you confirm that you have read and agree with our Privacy Policy and that you consent to us holding and processing your Personal Data for the following purposes. 

· Provide you with access to our Product/Systems & Service

· To keep you informed about news & business activities

· Provide relevant information on products and services that we offer.

You further consent to be contacted by: email ⦿ by text ⦿ by post ⦿ by phone ⦿

You can grant consent to all the purposes; one of the purposes or none of the purposes. Where you do not grant consent we will not be able to use your Personal Data for marketing purposes but may process the data in certain limited situations, such as where required to do so by law.

If you do grant consent, please note you can withdraw your consent to all or any one of the above purposes at any time by contacting the Data Controller. Please note that all processing of your Personal Data will cease once you have withdrawn consent, but this will not affect any Personal Data that has already been processed prior to this point.


Your Rights in Relation to your Personal information

Under the General Data Protection Regulation you have the following rights;

· The right to request a copy of your Personal Data which we hold about you (Data Subject Access Request);

· The right to request that we correct any Personal Data if it is found to be inaccurate or out of date;

· The right to request your Personal Data is erased where it is no longer necessary for us to retain such data;

· The right to withdraw your consent to the processing at any time;

· The right to request that the Data Controller provide the Data Subject with his/her Personal Data and where possible, to transmit that data directly to another Data Controller;

· The right, where there is a dispute in relation to the accuracy or processing of your Personal Data, to request a restriction is placed on further processing;

· The right to object to the processing of Personal Data;

· The right to lodge a complaint with the Appropriate Authority (see below under complaints).

If you wish to exercise any of these rights, you will need to contact the Data Protection Officer using the contact details below. In the case of exercising your right to access, you will also need to provide appropriate evidence of your identity.

If you wish to make a Personal Data Access Request the following applies:

No Fee Required:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Identity Confirmation:
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


Contact Details of the Data Protection Officer

Odin Treasury Consulting Ltd – Data Protection Officer –



We try to meet the highest standards in order to protect your privacy. If you are concerned about the way in which we are managing your personal data, please contact our Data Protection Officer using the contact details above.
You have the right to make a complaint at any time to the Gibraltar Regulatory Authority, which is Gibraltar’s supervisory authority for data protection issues ( However should wish to make a complaint, please contact the Odin Data Protection officer (details above) so that we can have opportunity to address your concerns before you approach the supervisory authority.


Where We Store & Transfer Your Personal Information

Usually all information you provide to us will be transferred and stored in a jurisdiction located in the European Economic Area (EEA). However, we may transfer some or all of your data to countries outside of the EEA which may not offer the same level of protection as the General Data Protection Regulations with respect to the processing of your personal data. The General Data Protection Regulations is the legal instrument that deals with the protection of your data (‘GDPR’).
Where your data is transferred to such countries it will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission (EC) can by found on the EC’s website:

Where data is to be transferred to a group company in a country outside of the EEA which may not offer the same level of protection as the GDPR with respect to the processing of your personal data, we will ensure that the group company agrees to similar levels of protection. Further information can by found on the EC’s website:

Where we transfer data to organisations based in the US, we may transfer data to them where they provide similar protection to personal data shared between the Europe and the US. For further details, see EC’s website page:


Data Security

We have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties who have a business based requirement to do so. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


Changes to Our Privacy Policy

We reserve the right to make changes to this policy from time to time, to take into consideration changes to our standard practices and procedures or where necessary to comply with new laws and regulations. The latest version of this policy will always be available on our website and we encourage to review it regularly. Any users of our Products/ Services maintain personal responsibility to review our up to date Privacy Policy & to take note of any material changes that may be notified to customers by means other than our website (such as email).


Copyright & Trademarks

The Website and app contains copyrighted material, trademarks and other proprietary information, including, but not limited to, text, software, photos, video, graphics, music and sound, software, code and the entire contents of the Website and app are protected by copyright. Odin owns a copyright in the selection, coordination, arrangement and enhancement of such content in any collected work, as well as in the content original to it. Users may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, sell, re-sell, re-post, or deep-link to any information, software, products or services obtained from or through the Website and app, in whole or in part. Users may download, print, and/or save copyrighted material for its own personal or internal business use only. Except as otherwise expressly stated under copyright law, no copying, redistribution, retransmission, publication or commercial exploitation of downloaded material without the express permission of Odin or the copyright owner is permitted.

“Odin” are trademarks and service marks of Odin. The Odin marks, together with other trademarks that are located within or on the Website and app otherwise owned or operated in conjunction with Odin shall not be deemed to be in the public domain but rather the exclusive property of Odin.