Privacy Policy

ODYSSEIA CONCIERGE, LLC

This Privacy Policy explains how Odysseia Concierge, LLC ("Odysseia," "we," "us," or "our"), a Florida limited liability company with its principal place of business in Miami, Florida, United States, collects, uses, stores, discloses, and protects personal information in connection with Membership, Services, and your use of our Website at www.odysseiaconcierge.com (the "Website"). Please read this Policy carefully. By using our Website, applying for Membership, or engaging our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the practices described herein.

Odysseia serves an exclusive, internationally distributed clientele of affluent and ultra-high-net-worth individuals. We recognize that the privacy, discretion, and security of your personal information are of the utmost importance and are fundamental to the trust you place in us. This Policy reflects our commitment to protecting your information to the highest standards.

1. DATA CONTROLLER IDENTITY

The data controller responsible for your personal information is:

Odysseia Concierge, LLC

Miami, Florida, United States

Website: www.odysseiaconcierge.com

For privacy inquiries, data subject requests, or concerns, please contact us through the Website. We are committed to responding to all privacy-related inquiries in a timely and thorough manner.

2. SCOPE AND APPLICABILITY

This Privacy Policy applies to: (a) all individuals who visit, access, or interact with the Website; (b) all Membership applicants; (c) all active and former Members; (d) all individuals who engage Odysseia for Retainer, Bespoke, or one-time concierge services; and (e) all individuals whose personal information is provided to Odysseia in connection with a Request (including family members, guests, or travel companions named in a Member's Request).

This Policy applies to personal information collected online through the Website, through our Member communication channels (email, phone, messaging), and through the membership and service relationship.

This Policy does not apply to the privacy practices of Third-Party Providers engaged to fulfill Member Requests. We encourage you to review the privacy policies of any third party with whom you interact as a result of Odysseia's arrangement of services on your behalf.

3. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Depending on your engagement with Odysseia, we may collect the following categories of personal information:

3.1 Identity and Contact Data: Full name; date of birth; nationality; passport details and other government-issued identification; residential and postal addresses; email addresses; telephone numbers; and emergency contact information.

3.2 Financial and Billing Data: Credit card and payment details (processed through secure third-party payment processors); billing address; bank account information where applicable; and general information about financial capacity to assess Membership suitability.

3.3 Membership and Account Data: Membership Tier; enrollment date; Renewal Dates; communication preferences; account access credentials; and Membership history.

3.4 Lifestyle and Preference Data: Dietary requirements and restrictions; culinary preferences; accommodation preferences; travel styles; preferred airlines, hotels, and destinations; recreational interests; wellness preferences; family structure and composition; and any other lifestyle preferences shared to enable personalized service delivery.

3.5 Request and Service Data: Details of Requests placed; itineraries and travel plans; reservations and bookings made on your behalf; communications with our concierge team; and records of services arranged.

3.6 Special Category Data: Where voluntarily provided in connection with Service delivery, we may process health or medical information (e.g., dietary restrictions, mobility requirements, medical emergency contacts), religious or dietary observances, and other data that may constitute "special category" or "sensitive" personal information under applicable law. We process such data solely to fulfill your Requests and never for commercial profiling purposes.

3.7 Technical and Usage Data: IP address; browser type and version; operating system; device identifiers; pages visited; time spent on the Website; referring URLs; and interaction data collected through cookies and similar technologies (see our Cookie Policy).

3.8 Communications Data: Records of correspondence with Odysseia via email, phone, messaging, or other channels; feedback; and any content you submit to us.

4. HOW WE COLLECT PERSONAL INFORMATION

We collect personal information through:

Direct submission by you, including via the Website contact form, membership application, and ongoing service communications.
Service delivery interactions, including when you place Requests, provide preferences, or communicate with our concierge team.
Automated technologies when you visit the Website, including cookies, web beacons, and analytics tools (see our Cookie Policy).
Third parties, including Third-Party Providers who may share information relevant to the fulfilment of a Request, identity verification providers, and payment processors.
Publicly available sources, where relevant to verifying identity or understanding service needs.

5. LEGAL BASES FOR PROCESSING PERSONAL INFORMATION

Odysseia processes your personal information on the following legal bases under applicable law, including the EU General Data Protection Regulation ("GDPR") and other applicable privacy frameworks:

5.1 Performance of a Contract. Processing is necessary to provide Membership Services, fulfill Requests, manage your account, and perform our contractual obligations to you.

5.2 Legitimate Interests. We process personal information where necessary for our legitimate business interests, including: improving and personalizing our Services; maintaining the security and integrity of our systems and Member relationships; preventing fraud and abuse; and marketing our Services to prospective Members, provided such interests are not overridden by your rights and freedoms.

5.3 Compliance with Legal Obligations. We process personal information to comply with applicable legal, regulatory, and governmental requirements, including anti-money laundering (AML), know-your-customer (KYC), sanctions screening, and tax obligations.

5.4 Consent. Where we rely on your consent to process personal information — including for marketing communications or the processing of sensitive personal data — you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing. Withdrawal of consent may impact our ability to deliver personalized Services.

5.5 Vital Interests. In limited emergency circumstances, we may process personal information to protect your vital interests or those of another person.

6. HOW WE USE YOUR PERSONAL INFORMATION

We use the personal information we collect for the following purposes:

Providing, personalizing, and improving our concierge and lifestyle management Services.
Processing and managing your Membership application and account.
Fulfilling your Requests and managing bookings, reservations, and arrangements with Third-Party Providers.
Administering billing, payments, and financial transactions.
Communicating with you regarding your Membership, Requests, renewals, and service updates.
Sending you information about new services, luxury experiences, and membership opportunities where you have consented to such communications, or where we have a legitimate interest in doing so.
Conducting identity verification, AML/KYC checks, and sanctions screening.
Maintaining the security and integrity of our systems, Website, and Member data.
Complying with applicable legal, regulatory, and governmental obligations.
Resolving disputes and enforcing our contractual rights.
Conducting analytics to understand how our Website and Services are used and to improve them.

7. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

Odysseia treats your personal information with the utmost discretion. We do not sell your personal information to third parties. We may share your information in the following limited circumstances:

7.1 Third-Party Providers and Luxury Partners. We share relevant personal information with Third-Party Providers engaged to fulfill your Requests, including airlines, charter operators, hotels, restaurants, transportation companies, event organizers, and other luxury service providers. Such sharing is limited to what is necessary to fulfill the specific Request.

7.2 Identity Verification and AML/KYC Providers. We may engage third-party identity verification, fraud prevention, and compliance screening providers who process your identification information on our behalf in connection with membership acceptance and ongoing compliance obligations.

7.3 Payment Processors. We use secure, third-party payment processors to handle billing transactions. We do not store full payment card details on our own systems.

7.4 Professional Advisors. We may share personal information with legal, financial, or compliance advisors who are bound by professional confidentiality obligations, where necessary to protect our legal rights or comply with applicable law.

7.5 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or substantially all of Odysseia's assets, your personal information may be transferred to the acquiring entity, subject to equivalent privacy protections.

7.6 Legal and Regulatory Disclosure. We may disclose personal information where required to do so by applicable law, court order, governmental authority, regulatory requirement, or law enforcement request. We will, where permitted by law, notify you of such requirements.

7.7 Consent. We may share your information with additional parties with your express prior written consent.

7.8 Odysseia Concierge does not share mobile numbers, text messaging originator opt-in data, or consent with any third parties or affiliates for marketing or promotional purposes.

7.9 Mobile information may be shared only with subcontractors and service providers that support the delivery of SMS services, such as messaging platforms, telecommunications providers, or customer support vendors. This information is used solely to provide and operate the messaging service.

All other use case categories exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties.

8. INTERNATIONAL DATA TRANSFERS

Odysseia is based in Miami, Florida, United States. Your personal information may be transferred to, stored, and processed in the United States and in other countries in which our Third-Party Providers operate. Not all such countries provide the same level of data protection as your home jurisdiction.

For Members resident in the European Economic Area ("EEA"), United Kingdom ("UK"), or other jurisdictions with international transfer restrictions, Odysseia implements appropriate safeguards for cross-border transfers, including:

Standard Contractual Clauses (SCCs) approved by the European Commission or UK equivalents, where applicable.
Reliance on adequacy decisions where available.
Other appropriate transfer mechanisms required by applicable law.

You may request information about the transfer safeguards applicable to your personal information by contacting us through the Website.

9. DATA RETENTION

We retain your personal information for as long as necessary to fulfil the purposes described in this Policy, including to provide Services, maintain your Membership account, comply with legal obligations, resolve disputes, and enforce our agreements.

Specific retention periods include:

Membership and account data: retained for the duration of the Membership and for a period of seven (7) years following termination, to comply with tax, AML/KYC, and legal retention requirements.
Request and transaction data: retained for seven (7) years following the date of the Request or transaction.
Lifestyle and preference data: retained for the duration of the Membership and for two (2) years following termination, or until you request deletion, whichever is earlier.
Special category data: retained only for as long as necessary to fulfill the specific Request for which it was provided, and then securely deleted.
Website usage and analytics data: retained for up to twenty-four (24) months.
Communications: retained for the duration of the Membership and for five (5) years following termination.

When personal information is no longer required, it is securely deleted or anonymized in accordance with our data lifecycle management procedures.

10. DATA SECURITY

Odysseia implements appropriate technical, organizational, and physical security measures to protect your personal information against unauthorized access, loss, misuse, disclosure, alteration, or destruction. Our security practices include:

Encryption of data in transit using industry-standard protocols.
Restricted access controls, ensuring that personal information is accessible only to staff with a legitimate business need.
Secure payment processing through PCI-DSS-compliant third-party processors.
Staff training on data protection and confidentiality obligations.
Regular review of our information security practices and procedures.

While we implement robust security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your personal information, and we encourage you to take appropriate precautions to protect your own account credentials.

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and any applicable regulatory authority as required by applicable law.

Florida Breach Notification. For Members and Website users who are Florida residents, Odysseia complies with the Florida Information Protection Act, Florida Statutes §501.171. In the event of a breach of security of personal information of a Florida resident, Odysseia shall notify affected individuals without unreasonable delay and no later than thirty (30) calendar days after Odysseia determines that a breach has occurred, unless a law enforcement agency determines that notification would impede a criminal investigation. Notice may be delayed beyond thirty (30) days only with law enforcement authorization or where necessary to determine the scope of the breach and restore integrity to Odysseia’s systems. Notice shall be provided by written mail, email, or, where the cost of notification exceeds $250,000 or the number of affected individuals exceeds 500,000, by conspicuous Website posting and major statewide media notification, as permitted by law. Where a breach affects 500 or more Florida residents, Odysseia shall also notify the Florida Department of Legal Affairs.

11. YOUR RIGHTS AND CHOICES

Subject to applicable law and certain exceptions, you may have the following rights with respect to your personal information:

11.1 Right to Access. You have the right to request confirmation of whether we process personal information about you and, where we do, to receive a copy of that information.

11.2 Right to Rectification. You have the right to request correction of inaccurate or incomplete personal information we hold about you.

11.3 Right to Erasure. You have the right to request deletion of your personal information where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (where consent is the lawful basis), or where we have no legitimate overriding interest to retain it. Deletion requests are subject to legal retention requirements.

11.4 Right to Restriction. You have the right to request that we restrict the processing of your personal information in certain circumstances, including while a rectification or objection request is being assessed.

11.5 Right to Data Portability. Where processing is based on consent or contract performance and is carried out by automated means, you have the right to receive your personal information in a structured, commonly used, machine-readable format.

11.6 Right to Object. You have the right to object to processing of your personal information carried out on the basis of legitimate interests or for direct marketing purposes. We will cease processing unless we have compelling legitimate grounds that override your interests.

11.7 Rights Related to Automated Decision-Making. You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects, unless such processing is necessary for a contract, permitted by law, or based on your explicit consent.

11.8 California Rights (CCPA/CPRA). If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to delete, the right to correct, the right to opt out of sale (we do not sell personal information), and the right to non-discrimination for exercising your privacy rights. To exercise California rights, contact us as specified in Section 20.

11.9 European and UK Rights (GDPR). If you are a resident of the EEA or United Kingdom, you have the rights described in this Section 11 under the GDPR or UK GDPR. You also have the right to lodge a complaint with your local supervisory authority if you believe we have processed your personal information unlawfully.

To exercise any of the rights described in this Section, please contact us through the Website. We will respond within the timeframe required by applicable law (typically 30 days, subject to extension where permitted).

12. MARKETING COMMUNICATIONS

12.1 Where you have consented to receive marketing communications, or where we have a legitimate interest in contacting you about Services you may find of value, we may send you information about new Membership offerings, exclusive experiences, luxury lifestyle content, and related news.

12.2 You may opt out of marketing communications at any time by: (a) following the unsubscribe link in any email we send; (b) contacting us directly; or (c) updating your communication preferences in your Member account. Opting out of marketing communications will not affect transactional or service-related communications, which will continue for the duration of your Membership.

13. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to operate and improve our Website, enhance your experience, and understand how our Website is used. A detailed description of the cookies we use, their purposes, and how to manage your preferences is provided in our Cookie Policy, available on the Website and incorporated into this Privacy Policy by reference.

14. CHILDREN'S PRIVACY

Our Services and Website are directed exclusively at adults and are not intended for individuals under the age of 18. We do not knowingly collect personal information from individuals under 18. If we become aware that we have inadvertently collected personal information from a minor, we will take prompt steps to delete such information. If you believe we have collected personal information from a minor, please contact us immediately.

Where a Member provides information about family members or travel companions under the age of 18 as part of a Request (for example, arranging travel for a child), such information is used solely to fulfill that Request and is handled with the highest level of discretion.

15. THIRD-PARTY LINKS AND SERVICES

The Website may contain links to third-party websites, platforms, or services. These third-party sites operate under their own privacy policies, which we do not control and for which we are not responsible. We encourage you to review the privacy practices of any third-party site you visit. The inclusion of a link on our Website does not imply our endorsement of that site's privacy practices.

16. SPECIAL PROVISIONS FOR ULTRA-HIGH-NET-WORTH AND HIGH-PROFILE MEMBERS

Odysseia recognizes that Members of an ultra-high-net-worth or high-profile status have heightened privacy needs and security considerations. In recognition of this:

Odysseia maintains strict internal access controls, ensuring that Member information is accessible only on a need-to-know basis and that access logs are maintained.
All Odysseia staff and contractors are subject to robust confidentiality obligations as a condition of their engagement.
Members who require enhanced privacy arrangements, including bespoke data handling protocols, coded identifiers, or heightened communication security, are invited to discuss their requirements with their designated concierge manager.
Odysseia does not disclose the identity, preferences, or activities of its Members to any third party except as strictly necessary to fulfill a confirmed Request or as required by law.

17. CHANGES TO THIS PRIVACY POLICY

Odysseia reserves the right to update or modify this Privacy Policy at any time. We will post the revised Policy on the Website with an updated "Last Revised" date. For material changes, we will provide advance written notice to active Members via email or their designated communication channel. Your continued use of the Website or Services following the effective date of a revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.

18. DATA PROTECTION OFFICER AND SUPERVISORY AUTHORITY

18.1 Odysseia does not currently have a formally designated Data Protection Officer (“DPO”); however, privacy inquiries are handled by our designated Privacy Contact accessible through the Website. As Odysseia’s European client base grows, Odysseia will assess whether the appointment of a formal DPO is required under GDPR Article 37, including in circumstances where processing involves large-scale systematic monitoring of individuals or large-scale processing of special categories of data, and will make any required designation in a timely manner.

18.2 EEA and UK Members. If you are located in the EEA or UK and have concerns about how we handle your personal information that you feel have not been adequately addressed, you have the right to lodge a complaint with your local data protection supervisory authority. For example, UK residents may contact the Information Commissioner's Office (ICO); EU residents may contact the relevant national supervisory authority in their country of residence. We would, however, appreciate the opportunity to address your concerns directly before you contact a supervisory authority.

19. COMPLAINTS AND DISPUTE RESOLUTION

We take privacy concerns seriously and are committed to resolving complaints promptly and fairly. If you have a concern or complaint about our privacy practices, please contact us through the Website. We will acknowledge receipt of your complaint within five (5) business days and use reasonable efforts to resolve it within thirty (30) days. Where a complaint is complex or requires further investigation, we will keep you informed of progress.

For Members in jurisdictions with specific consumer privacy dispute resolution mechanisms, those mechanisms remain available to you in addition to the complaint process described above.

20. CONTACT INFORMATION

For all privacy-related inquiries, data subject rights requests, or complaints, please contact Odysseia through the designated privacy contact mechanism on our Website at www.odysseiaconcierge.com. We are committed to treating all privacy requests with the utmost confidentiality and discretion.

Odysseia Concierge, LLC

325 South Biscayne Boulevard

33131, Miami, Florida, United States

anastasia@odysseiaconcierge.com

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