Odele Privacy Policy
Effective Date: December 19, 2025
This Privacy Policy, including the Supplemental Privacy Policy for Residents of Certain U.S. States (together, the “Policy”), provides information about how Odele, LLC, and its affiliates and subsidiaries (collectively, “Odele,” “we,” “us,” or “our”) including the foregoing entities, their subsidiaries, and affiliates) collect, use, store, disclose, analyze, delete, and modify (collectively, “Processes” and its conjugates) information that is linked or reasonably linkable to an identified or identifiable natural person (“Personal Data”) who interacts with our Services (collectively, our “Users”). This Policy applies to Personal Data Processed on any website where this Privacy Policy is posted, and any other online or offline services we may offer (collectively, our “Services”). This Policy is subject to and forms part of our Terms of Use, including your agreement to arbitrate Disputes with us on an individual basis. Capitalized terms not defined in this Policy have the definition given to them in our Terms of Use.
By using our Services, you agree to the Processing of your Personal Data as described in this Policy.
A. Types of Personal Data We Collect
We collect the following categories of Personal Data in conjunction with our Services:
1. Identifiers, such as name, alias, postal address, unique personal identifier, online identifiers, Internet Protocol address, email address, account name, signatures, physical characteristics or description, telephone number, or other similar identifiers.
2. Financial Information, including bank account number, credit card number, debit card number, or any other financial information that does not allow access or withdrawal of funds.
3. Insurance Information, including insurance policy number or health insurance information.
4. Characteristics of Protected Classifications under state or federal law, such as age, gender, and marital status.
5. Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
6. Biometric Information, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, voice recordings, gait patterns, or rhythms, and sleep, health, or exercise data from which we can extract identifying information.
7. Internet or Other Network Information, such as browsing history, search history, information regarding your interactions with our websites or advertisements.
8. Geolocation Data, such as device location that is more granular than a city or town.
9. Audio, Electronic, Visual, and Similar Information, such as call and video recordings.
10. Professional or Employment-Related Information, such as work history and prior employer.
11. Education Information, as defined in the federal Family Educational Rights and Privacy Act, such as student records and directory information.
12. Inferences drawn from any of the Personal Data listed above to create a profile or summary about, for example, an individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
13. Sensitive Personal Data, including:
a. Personal Data that reveals your:
i. Social security, driver’s license, state identification card, or passport number;
ii. Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account;
iii. Precise geolocation that is used or intended to be used to locate you within a small geographic area (less than a radius of 1,850 feet);
iv. Racial or ethnic origin, religious or philosophical beliefs, or union membership;
v. Contents of your email and text messages, unless we are the intended recipient; or
b. Biometric information Processed for the purpose of uniquely identifying you;
c. Personal Data collected and analyzed concerning your health; and
d. Personal Data collected and analyzed concerning your sex life or sexual orientation.
B. Sources of Personal Data
We collect Personal Data from the following sources:
1. Directly From You. Odele collects the Personal Data you manually provide when you use our Services. Types of Personal Data we may collect directly from you include, for example, your first and last name, age and birthday, mailing and email addresses, including zip code, and telephone number(s).
2. From Vendors & Third Parties. Odele collects Personal Data from our vendors and from third parties who disclose Personal Data to us.
3. Via Cookies & Other Tracking Technologies. Odele collects Personal Data passively via cookies and other tracking technologies more fully described below. This information typically includes your IP address, the identity of your Internet service provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, your geolocation, and the pages you visit. For example, we use Google Analytics, a web analytics tool that helps us understand how visitors engage with our Services. To learn more about Google Analytics, visit http://www.google.com/intl/en/analytics/privacyoverview.html.
C. How We Use Personal Data
We Process the Personal Data we collect:
We may also deidentify any Personal Data we collect about you. When we do so, we take reasonable measures to ensure that the information cannot be associated with a consumer or household, and we maintain and use the information in deidentified form. We will not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether our deidentification processes satisfy applicable legal requirements. After it has been deidentified, the information is no longer Personal Data and is not subject to this Policy.
D. How We Disclose Personal Data
We disclose the categories of Personal Data we collect in the following contexts:
1. To Our Affiliates & Vendors. Odele discloses Personal Data collected through our Services to our affiliates and with vendors who act on our behalf. For example, we use vendors to operate our Services and help us with our promotional efforts. We impose contractual limitations on our vendors’ use of Personal Data they collect in conjunction with providing services to us.[AT3]
2. To Third Parties for Marketing & Analytics Purposes. We may disclose your Personal Data to third parties who process Personal Data for their own purposes, including marketing and analytics companies. This primarily includes disclosures of IP addresses and related web browsing information via Cookies.
3. As Described in a Privacy Notice or With Your Consent. We may disclose Personal Data as described in any privacy notice we provide to you via our Services, or with your consent if we obtain it from you in a particular context.
4. In Aggregate or De-Identified Form. We may aggregate or de-identify the Personal Data we collect, and we may disclose aggregated and/or de-identified information to our vendors and to third parties for our business operational purposes and for any other purposes permitted by applicable law.
We may also disclose Personal Data in the following contexts:
1. As Part of a Business Transfer. Your Personal Data may be transferred to a successor organization if, for example, we transfer the ownership or operation of the Services to another organization, if we merge with or are acquired by another organization, or if we liquidate our assets. In negotiating with a third party about entering into such an arrangement, we may need to disclose your Personal Data. In such cases, we will take reasonable measures to protect the Personal Data we disclose, and we will seek assurances that the successor organization’s use of your Personal Data will still be subject to this Policy and the privacy preferences you have expressed to us.
2. For Compliance with Laws and Protection of Our Rights and the Rights of Others. We may disclose your Personal Data when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your Personal Data to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of the Services; to enforce or apply our Terms of Use or other agreements; or to protect our own rights or property or the rights, property, or safety of our Users or others.
E. Cookies, Pixels, and Other Tracking Technologies
We use t third-party tracking technologies, including pixels, web beacons, session replay scripts, software development kits, cookies, and tags (collectively, “Cookies”) to collect information about your interactions with our Services. This information may include your IP address, device and browser details, pages visited, and actions taken.
Cookies enable us and our advertising partners (such as Meta, Google, and The Trade Desk) to deliver targeted advertising (also known as cross-context behavioral advertising) by not opting out of the use of these technologies you agree to our disclosure of your data via these technologies to third parties.
Targeted advertising involves the use of your Personal Data to serve ads based on your activities over time and across nonaffiliated websites or apps. This may involve sharing Personal Data, such as device identifiers and browsing behavior, with third parties.
You have the right to opt out of the processing of your Personal Data for targeted advertising. You can exercise this right by clicking Your Privacy Choices at the bottom of this website and selecting "Customize". We also honor the Global Privacy Control (GPC) signal.
F. Steps We Take to Safeguard Your Personal Data
We maintain reasonable administrative, physical, and technological measures to protect the confidentiality and security of Personal Data you submit on or through the Services. Unfortunately, no website, app, or database is completely secure or “hacker proof.” We therefore cannot guarantee that your Personal Data will not be disclosed, misused, or lost by accident or by the unauthorized acts of others.
G. Children Under the Age of Thirteen
Our Services are not intended for children under the age of 13, and we do not collect Personal Data from children under the age of 13. If you believe that a child has submitted Personal Data on or through our Services, please contact us promptly at hello@odelebeauty.com so that we can take appropriate action.
H. Links to Other Sites
Our Services may provide links to websites and services operated by third parties. We do not control the content or links that appear on these websites and services, and we are not responsible for their privacy practices. When you visit a third party’s website or use a third party’s services, such use is subject to the third party’s privacy policy and terms of use. We encourage you to review the privacy policy and any applicable terms of use posted on any website you visit or other services you access before providing any Personal Data to that third party.
I. Changes to this Policy
This Policy describes Odele’s current policies and practices with regard to the Personal Data we Process through the Services.
We are continually improving and adding to the features and functionality of our Services. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time. When we do so, we will post the revised version of this Policy behind the link marked “Privacy Policy” in the footer of our website. Your continued use of our Services after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy.
J. Contact us
If you have any questions about this Policy or our privacy practices, please contact us using the information provided below:
Odele, LLC
2434 Commerce Blvd.
Mound, MN 55364
612-254-7275
Email: hello@odelebeauty.com