Privacy Policy

This Privacy Policy has been updated from time to time, including reflecting changes in applicable privacy laws. This Privacy Policy applies to information we collect through our websites, services, and related communications. It does not apply to information collected by us offline or through any other means not linked to this Privacy Policy, or by any third party, including through any application or content that may link to or be accessible from our services.

Mulcahy Consulting, Inc. (d/b/a "Odigo") ("the Odigo Group," "we," "our," or "us"), values trust and transparency. This Privacy Policy explains how we collect, use, share, and protect information when you engage with us — whether through our websites, services, events, communications, or marketing activities. It includes the following:

1. What Personal Information we collect, how and why it is used, and the limited circumstances under which it may be disclosed to service providers or partners.
2. The choices and rights available to you regarding your Personal Information, including access, correction, deletion, and opt-out rights under applicable privacy laws.
3. How we protect your information, including the administrative, technical, and organizational safeguards we use to reduce the risk of misuse, loss, or unauthorized access.
4. How you can update or correct your information, submit privacy-related requests, or contact us with questions or concerns about our data practices.

Your trust matters. If you do not agree with this Privacy Policy, please discontinue use of our services.

We may update this Privacy Policy periodically. When we do, we will update the "Last Updated" date above and provide additional notice where legally required.

As used in this Privacy Policy, "Personal Information" means information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, to a particular individual, such as your name, email address, telephone number, mailing address, IP address, or payment information. Personal Information does not include publicly available information, de-identified or aggregated information, or information that cannot reasonably be used to identify an individual.

"Sensitive Personal Information" (or "SPI") means Personal Information that reveals or contains: (a) government-issued identification numbers (e.g., Social Security number, driver's license number, or passport number); (b) financial account information, including credit or debit card numbers, in combination with any required security or access code; (c) precise geolocation data; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) contents of mail, email, or text messages (where the business is not the intended recipient); (f) genetic or biometric data processed for the purpose of uniquely identifying an individual; (g) health information; (h) information concerning an individual's sex life or sexual orientation; or (i) account log-in credentials. For purposes of this Privacy Policy, SPI also includes Personal Information of individuals under age 18.

Information We Collect

When you visit our website, you are free to explore certain portions of the website without providing any Personal Information about yourself. However, even if you elect not to provide us with any Personal Information, we may collect Navigational Information (as described in Section 8 below) and other information from third parties as described in this Privacy Policy.

Information You Provide

This may include:

• Name, company name, job title.
• Email address, phone number, mailing address.
• Information submitted through forms, event registrations, or subscriptions.
• Communications with us (emails, messages, inquiries).
• Preferences or responses to surveys or content.
• Information provided for co-marketing or partner events.

Information Collected Automatically

We automatically collect:

• IP address, browser type, device identifiers, operating system.
• Website usage data (pages viewed, time on page, referral paths).
• Approximate location inferred from IP address.
• Cookie-based or pixel-based analytics data.

You may manage cookies through your browser settings.

Information from Third Parties

We may receive limited Personal Information from:

• Analytics and performance tools.
• Event or co-marketing partners (when you opt in).
• CRM or marketing tools acting as service providers.
• Social media platforms based on your settings.

Children's Data

Our services are not directed to individuals under 18.

We do not knowingly collect Personal Information from individuals under 18. If we become aware that we have unintentionally received such information, we will delete it.

Information Use and Sharing

In addition to the uses identified elsewhere in this Privacy Policy, we may use Personal Information to:

• Deliver, operate, and improve our services, including maintaining and enhancing our website, offerings, and overall user experience.
• Understand website performance and engagement, including analyzing usage patterns, measuring effectiveness, and improving functionality and content.
• Communicate with you and respond to requests, including inquiries, support needs, and information you ask us to provide.
• Share content, updates, or marketing communications you've chosen to receive, including newsletters, insights, event information, and other communications related to our business.
• Support events, partnerships, and engagements, including registrations, co-hosted activities, and related communications where you choose to participate.
• Manage administrative and operational matters, including billing, account management, fulfillment of transactions, and internal record keeping.
• Maintain security and prevent fraud, including protecting our systems, users, and data from unauthorized access, misuse, or disruption.
• Comply with legal, regulatory, and contractual obligations, including responding to lawful requests and enforcing our agreements.
• Fulfill the purposes for which you provided the information, or as otherwise described to you at the time of collection.
• Produce aggregated or de-identified insights, which may be shared for analytical or business purposes and are not used to identify any individual.

We do not sell or "share" Personal Information for cross-context behavioral advertising. We do not use Personal Information submitted through our services to train, improve, or develop any machine learning or artificial intelligence models. If this ever changes, we will update this Privacy Policy and provide clear opt-out options.

Use of Navigational Information

We use Navigational Information to operate and improve the Website and to provide you with a better experience. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about our services. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.

You may disable the collection and use of your location data through browser-operating system or device-level settings.

How We Disclose Information

We may disclose Personal Information to service providers, contractors, or partners who perform services on our behalf or as necessary to fulfill your requests. These parties are required to safeguard Personal Information under written agreements and may use it only for the purposes specified by The Odigo Group on a need-to-know basis.

We may disclose information to:

• Service providers/contractors (hosting, analytics, email tools, CRM systems).
• Partners, when you intentionally interact with co-branded content or events.
• Vendors involved in event operations or service delivery.
• Legal authorities where required to comply with the law or to protect our rights.

Service providers and contractors who process Personal Information on our behalf are subject to contractual obligations that limit their use of that information and require appropriate safeguards. They may also maintain their own privacy policies, which apply to their general business practices. We encourage you to review those policies for additional information.

We do not monitor the contents of your private files or access your device activity, except as necessary to provide our services, maintain security, or comply with legal obligations.

International Data Transfers. Our services are operated in the United States. If you are located outside the United States, please be aware that any information you provide to us, including Personal Information, may be transferred to, stored, and processed in the United States or other jurisdictions where our service providers operate. By using our services, you authorize the transfer of your information to the United States for processing.

Your Access To and Control Over Personal Information

You may opt out of any future contacts from us at any time.

You can do the following at any time by contacting us via the email address or phone number given on our Website:

• Access the Personal Information we maintain about you.
• Correct or update your information.
• Request deletion of your information.
• Opt out of marketing communications.
• Ask questions about our data practices.

California residents may have additional rights and choices related to their Personal Information, which are set forth below.

Data Security

We use reasonable administrative, technical, and physical safeguards, designed to protect Personal Information, including:

• Encrypted transmission of sensitive information.
• Controlled access and authentication measures.
• Secure servers and monitoring.
• Staff training and internal access limitations.

While no system can be guaranteed secure, we take data protection seriously, continually assess our practices, and conduct periodic reviews of our security measures. In the event of a data breach involving Personal Information, we will notify affected individuals and relevant authorities within the timeframes required by applicable law.

Data Retention

We retain Personal Information only for as long as reasonably necessary to:

• Provide or support our services.
• Meet legal, operational, or contractual obligations.
• Satisfy the purposes for which the information was collected.

When no longer needed, information is securely deleted or de-identified.

Retention schedules may vary by data category.

Analytics

We use analytics tools to understand how our website is used. These tools collect technical and usage data, including:

• IP address
• Browser or device data
• Usage information

These tools are not permitted to use information for their own independent purposes.

Sensitive Personal Information

We do not collect or use Sensitive Personal Information (SPI) for inferring characteristics or for advertising purposes.

If, in the future, we collect SPI for operational necessity:

• We will use it only for legally permitted purposes.
• We will honor your right to limit SPI use.
• We will clearly disclose this in an updated Privacy Policy.

SPI includes information such as precise location, account log-in details, biometric data, and Personal Information of users under age 18.

Automated Decision-Making Tool (ADMT)

We do not currently use Personal Information in any automated decision-making system that produces legal or significant effects.

If our use of automated decision-making technology changes in the future, we will update this Privacy Policy, provide any notices and choices required by applicable law, and offer you the right to opt out of such processing where legally required.

State-Specific Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data under applicable law. These rights may include:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information, and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain. Deletion requests will be fulfilled in accordance with applicable law.
• Personal Data for Targeted Advertising, Profiling, and Sales. We do not use your data for these purposes as of the date of this policy.

The exact scope of these rights varies by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, contact us using the information in the "Contact Us" section below. We will fulfill access requests in accordance with applicable law. To appeal a decision regarding a consumer rights request, resubmit your request, and we will escalate internally and respond in accordance with applicable law. If you are unsuccessful on appeal you may contact your state attorney general in connection with the denial.

Cookies and Tracking

We use or have used in the past a variety of online analytics products that automatically deploy analytics and strictly necessary cookies, pixel tags, local storage and session storage, and other technologies to collect information in order to help us with analyzing how users use our website. Providers of these tools are required by contract to use the information collected only for the purposes we specify and are not permitted to use it for their own independent purposes.

A "cookie" is a piece of data sent to your browser by a website you visit. Depending on the type of information collected, cookies may constitute Personal Information. Depending on your device specifications and settings, you may be able to configure your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. Note that refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website.

Cookies and tracking technologies that are not essential to the functioning of our website will not be activated until a visitor provides affirmative consent through our website's consent-management tool. Visitors may withdraw or update consent and manage preferences by category at any time through our website's consent-management tools. To request deletion of Personal Information, please follow the process described in Section 19, "Right to Delete Your Personal Information."

Right to Delete Your Personal Information

You may request that we delete the Personal Information we maintain about you, subject to certain legal exceptions.

You may submit a deletion request using one of the following methods:

• Online: Submit a request through our data deletion request form at https://na1.hs-data-privacy.com/request/KQ-QAI1Ylk1xtJco3zuF_Q
• Email: Contact us at support@theodigogroup.com

To protect your information, we may verify your request by confirming that it was submitted from the email address associated with the Personal Information we maintain. We will confirm receipt of your request and respond within 45 days, in accordance with applicable law. If additional time is required, we will notify you.

Right to Opt Out of Sale or Sharing of Personal Information

The Odigo Group does not sell or share Personal Information for cross-context behavioral advertising.

If you would like to opt out of any future sale or sharing of your Personal Information, you may do so at any time by contacting us through one of the following methods:

• Email: support@theodigogroup.com
• Phone: 425-256-3020

You may submit an opt-out request without creating an account. We do not require identity verification to process opt-out requests.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

The Odigo Group
Email: support@theodigogroup.com
Phone: (425) 256-3020

Please reach out and contact us using the information below to:

• Access this Policy in an alternative format.
• Exercise your rights related to your Personal Information.
• Learn more about your rights or our privacy practices.
• Submit a request through an authorized agent acting on your behalf.

Telephone

425-256-3020

Email

support@theodigogroup.com

Mailing Address

207 Anthes Avenue, Suite 101
PO Box 1615
Langley, WA 98260