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Privacy Policy

Updated: October 6, 2023

Transaction Assembly, Inc. and any of our subsidiaries and affiliates (collectively, “Transaction Assembly”, “us” or “we”) are committed to protecting and respecting your personal information. Please read the following carefully to understand our practices regarding the collection, use and disclosure of, any personal information or personal data, as such terms are understood under applicable law (collectively, “Personal Information”) we collect from you (“you” or “user”) or you provide to us when you visit our website https://app.odos.xyz/ (the “Site”), when you use the Transaction Assembly’s proprietary online application (the “ODOS Service”, “ODOS”, or “Service”), or when you communicate with us in connection with our business.

If you are located in the European Economic Area (“EEA”), United Kingdom or Switzerland, certain additional rights, including under the European Union’s General Data Protection Regulation or “GDPR”, may be available to you. Please see Section VI(B) (EU, UK, and Swiss Residents) below.

This Privacy Policy is a part of Transaction Assembly’s Terms of Use available at https://docs.odos.xyz/policy/terms-of-use/ Capitalized terms not defined in this Privacy Policy have the meaning set out in the Terms of Use.

1. What Information We Collect and How We Collect It​

A. Information You Choose to Share: We collect information you directly share with us. When you fill out a survey, request support, use any interactive features of the ODOS Service, or communicate with us in other ways, you choose to provide the information to us.

B. IP Address and Device Information: When you use the ODOS Service, we collect log information including your IP address, browser type, time of visit, pages viewed, and any other log information typically shared through interacting with websites. We also obtain information about the device you use to access our Service, including operating system, model of the computer or mobile device, mobile network, and any other information about your device.

C. Information Collected by Cookies: Cookies are small data files stored on your computer’s hard drive by websites that you visit. Our Service and Site uses cookies, which help us understand trends and quality of visits. We use information collected by cookies to enhance the effectiveness and improve your experience using the Service and our Site.

D. Email Communication: If you subscribe to our newsletter with your email address, we may from time to time communicate news, updates, promotional information, marketing materials and other information related to Transaction Assembly and the ODOS Service. If you want to opt out of receiving such emails from us, you can opt out by clicking “unsubscribe” in any of the emails we send you. We may also collect and store information that you share with us through email, including inquiries, requests, Feedback, and any other information you choose to provide.

E. Social Media: When you visit Transaction Assembly’s organization page on social media sites (like Twitter or Facebook), you acknowledge that the associated third party social network may collect and use your data, including the data of your visits to those pages, in accordance with their respective privacy policies. We are not responsible for data collected by, and the privacy practices of, these third party social networks.

F. Information Collected from Other Sources: We may receive information from other sources, including third party service providers. This helps us evaluate and improve the ODOS Service and Site.

2. Purpose of Processing Your Personal Information​

A. General: We collect your Personal Information to provide, maintain, and improve the Service and Site. To be more specific, we primarily use your Personal Information to:

  • Communicate with you about our Service and Site, including technical updates and new features, and any information that you request or that we think you might be interested;
  • Track and analyze activities, usage, trends, numbers, and market insights related to our Service and Site;
  • Detect, prevent, and address security or technical issues;
  • Prevent illegal activities and protect the rights and property of Transaction Assembly and users; and
  • Facilitate our work with partners, vendors, agents, contractors, and service providers.

A. Cookies: Transaction Assembly uses cookies on the Service and Site. Transaction Assembly uses “persistent” cookies that remain on your device when you go offline for purposes including remembering your login details and to authenticate users using the Service. Transaction Assembly uses “session” cookies that are deleted as soon as you close your web browser for purposes including to analyze how the Service or Site is used. Please see our Cookie Policy https://docs.odos.xyz/policy/cookie/ for additional information and to change or withdraw your cookie permissions.

B. Sensitive Personal Information: We do not collect sensitive Personal Information from your use of our Service or Site. If we collect sensitive personal information, we will only process such Personal Information where we have obtained your consent, in accordance with applicable law, for the purposes for which it is collected by us.

C. How Long We Keep Your Personal Information: Transaction Assembly will retain your Personal Information only for as long as required to engage in the purpose for which such information was collected or provided as described in this Privacy Policy, unless there is a legitimate business purpose or legal requirement for retaining your Personal Information for a longer period. If it is not possible to delete your Personal Information after such period or at your request (for example, because your Personal Information has been stored in backup systems or because there is a legal requirement to retain your Personal Information), Transaction Assembly will securely store your Personal Information and isolate it from any further processing until deletion is possible. In some instances, Transaction Assembly may choose to anonymize your Personal Information instead of deleting it, for statistical use, for instance. When Transaction Assembly chooses to anonymize your Personal Information, Transaction Assembly will make sure that the anonymized information cannot be linked back to you.

3. What We Provide to Third Parties​

Transaction Assembly does not sell, rent, or trade your Personal Information. We disclose your Personal Information only in limited circumstances, such as:

A. Subsidiaries and Affiliates: We may share your information, including Personal Information, with our subsidiaries or affiliates, in which case we will require those subsidiaries and affiliates to honor this Privacy Policy. Subsidiaries and affiliates include companies that we control or that are under common control with us.

B. Third Party DEXs: We may share your information, including Personal Information, with Third Party DEXs to place orders for, and complete, your Swaps with the applicable Third Party DEXs. By clicking “Swap”, you acknowledge that we may provide to the applicable Third Party DEX, and such Third Party DEX may collect and use, your information, including Personal Information, in accordance with the applicable Third Party DEX’s privacy policy. We are not responsible for the privacy practices of Third Party DEXs. You can see the full list of Third Party DEXs the Service currently connects with https://app.odos.xyz/. For more information regarding the privacy practices of any Third Party DEX, please visit the applicable Third Party DEX’s website to view their privacy policy.

C. Wallet Solution Providers: We may collect from, and share with, the third party provider of the Wallet you connect to the Service (“Wallet Solution Provider”), your information, including Personal Information, to display your Wallet information on the Service and to process your orders and complete your Swaps. You acknowledge that such Wallet Solution Provider may collect and use your information, including Personal Information, in accordance with such Wallet Solution Provider’s privacy policy. We are not responsible for the privacy practices of any Wallet Solution Provider. You can see the full list of Wallet Solution Providers that you may use with the Service https://app.odos.xyz/. For more information regarding the privacy practices of any Wallet Solution Provider, please visit the applicable Wallet Solution Provider’s website to view their privacy policy.

D. Google Analytics: Transaction Assembly uses ‘Google Analytics’ component (with anonymization setting turned on) integrated on our Service and Site. Google Analytics, operated by Google or its affiliates (“Google”), is a web-analytics service that we use to collect, compile and analyze data about the behavior of visitors to our Service and Site. We primarily use this tool to optimize user experience of our Service and Site. For more information on the privacy practices of Google and how Google processes Personal Information, please visit the following Google information link: https://support.google.com/analytics/answer/6004245?Hl=en.

E. Service Providers: Semiotic may contract with other companies to provide services or functionality on our behalf. If we do so, we may share your information, including Personal Information, with such providers to the extent necessary for their engagement. In all such cases, the service providers’ use of your information will be contractually limited to uses consistent with this Privacy Policy.

F. Legal Requirements: We reserve the right to disclose your information, including Personal Information, as required by law such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. With respect to Personal Information collected from your use of our Service or Site, unless we are prohibited by law, we will attempt to notify you of any request to disclose your Personal Information to the authorities or any other party and, where appropriate, refer such requests directly to you.

We may also disclose your information, including Personal Information, to third parties: (a) to enforce any part of the agreements between you and us or to investigate potential breaches; or (b) to protect the rights, property or safety of us, our users, or others; or (c) for the purpose you have permitted in this Privacy Policy or under the Terms of Use https://docs.odos.xyz/policy/terms-of-use/.

G. Successors: If Semiotic or any of its subsidiaries or affiliates is involved in a merger, acquisition, or sale of all or a portion of its assets, your information, including Personal Information, may be disclosed and transferred in connection with that transaction. Such transfer would enable due diligence and/or allow the transferee to operate the business. You will be notified via email and/or a prominent notice on the Service or Site of any change in ownership or uses of your Personal Information by Transaction Assembly or such transferee, as well as any choices Transaction Assembly or such transferee makes available to you regarding your information.

4. Security​

Transaction Assembly has implemented reasonable technical and organizational security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information. Unfortunately, no data transmission over the Internet can be guaranteed to be entirely secure, and we assume no liability for any damage suffered by you caused by the interception, alteration, or misuse of information during transmission.

5. Where Personal Information is Stored; International Transfers​

We process and store your Personal Information in the U.S. However, you acknowledge that in order for us to provide the Service and Site to you, we may need to transfer, process, and store your Personal Information outside of your country of residence where data protection standards may be different. Several countries, including those in the European Economic Area, have established data protection laws and regulations that place restrictions on the transfer of Personal Information across country borders. We are committed to complying with all of those laws and regulations and ensuring that third-party recipients of your Personal Information acting on our behalf process that information in accordance with such laws. Notwithstanding the foregoing, you acknowledge that any information received by Third Party DEXs and Wallet Solution Providers from your use of the Service may be used by such Third Party DEX or Wallet Solution Provider in accordance with their own respective privacy policy, including any international transfers by such third parties. We are not responsible for the privacy practices of any Third Party DEX or Wallet Solution Provider.

6. Your Rights and Access to Information​

A. General​

You have the right to obtain from us a copy of your Personal Information controlled by Transaction Assembly. You may also update, rectify, or delete such Personal Information anytime, by sending us a request as described in Section IX (Contact Us). However, we may keep such information for a period of time in our backup systems or to comply with applicable law as described in Section II(D) (How Long We Keep Your Personal Information).

You may unsubscribe from our email communications or newsletters by completing the instructed steps in those communications or by sending us a request as described in Section IX (Contact Us).

You may also stop us from sharing your Personal Information with third parties as described in this Privacy Policy, by sending us a request as described in Section IX (Contact Us).

If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We will handle any request to exercise your rights in accordance with applicable law. Some of these rights may be subject to certain restrictions or limitations under applicable law. Additionally, we reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity.

B. EU, UK and Swiss Residents​

If you are a European Union, UK or Swiss resident certain additional rights, including under the GDPR, may be available to you. To the extent established under applicable law, you may have the right, subject to preconditions or limitations under applicable law:

  • to access, review, and update (including correcting any inaccuracies in) your personal information;
  • to restrict our processing of your personal information;
  • to request that we provide you a copy of, or access to, your personal information in structured, commonly used and machine-readable format (or that we transfer your personal information to another controller, when technically feasible);
  • to withdraw your consent when our processing of your personal information is based on your consent (and not another legitimate basis);
  • to request that we delete all of your personal information; and
  • to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. Before you do this, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your personal information.

You may exercise any of the above rights with respect to Personal Information controlled by us by sending us a request as described in Section IX (Contact Us). If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. Some of these rights may be subject to certain restrictions or limitations under applicable law. Additionally, we reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity.

7. Children​

The Service and Site is not intended to be used by any person under the age of 18, and certainly not by anyone under the age of 13. Transaction Assembly does not knowingly collect Personal Information from children without appropriate parental or guardian consent. If you believe that we may have collected Personal Information from someone under the applicable age of consent in your country without proper consent, please let us know at [email protected] and we will take appropriate measures to investigate and address the issue promptly.

8. Changes to this Privacy Policy​

This Privacy Policy may change from time to time, and we will post any changes to it on this page. Your continued use of the Service or Site following such posts will signal your acceptance of such changes. The date this Privacy Policy was last updated appears at the top.

9. Contact Us​

If you have any questions or would like to exercise any of your rights under applicable law, please contact us in one of the following ways:

  1. Email us at [email protected] with the subject line “Privacy Policy”, or if it is with respect to exercising any of your rights with respect to your Personal Information, with the subject line “Data Rights Request”, as applicable; or
  2. Send us mail at the following address below marking it “Attention: Data Privacy Officer (Privacy Policy), or if it is with respect to exercising any of your rights with respect to your Personal Information, “Attention: Data Privacy Officer (Data Rights Request)”, as applicable:

Transaction Assembly, Inc. 127 Second St. Suite 2 Los Altos, CA 94022