GDPR — Your Data Rights

How the GDPR applies to an application that processes no personal data.

1. Who is responsible

The controller is CIBELE, Inc., a Delaware corporation, 425 E 13th Street, New York, NY 10009, United States — contact@cibeleinc.com. No Data Protection Officer has been designated: the conditions of Article 37 of the GDPR are not met.

2. What processing takes place

In the ordinary use of Odyssey, none. The app has no account, no server and no outbound connection; the information it keeps is written to your device and never transmitted. CIBELE therefore holds no personal data about its users and keeps no file on them.

Data stored by an application solely in the device's own storage, under the sole control of the user and never transmitted, does not give rise to processing by the publisher within the meaning of Article 4(2) of the GDPR.

3. The one exception: writing to us

If you contact us by email, we process your email address and the content of your message.

Purpose — answering you, and keeping a record of the exchange.
Legal basis — our legitimate interest in replying (Article 6(1)(f)).
Retention — up to three years after the last exchange.
Recipients — our email provider, as a processor.
Transfers — CIBELE is established in the United States; the transfer is covered by the European Commission's standard contractual clauses or by another mechanism recognised under Chapter V of the GDPR.

4. Your rights

Articles 15 to 22 of the GDPR give you the rights of access, rectification, erasure, restriction, portability and objection.

Over what the app keeps, you exercise these rights yourself, directly and immediately: the data is on your device. You can read it, change it in the app, and erase it entirely by deleting the app — no request to us, and no waiting.

Over an email exchange with us, write to contact@cibeleinc.com. We answer within one month.

5. No profiling, no automated decisions

Odyssey adapts what it suggests to the subjects you choose to follow, on your device alone. Nothing is inferred about you, nothing is sent anywhere, and no decision producing legal or similarly significant effects is taken within the meaning of Article 22.

6. Security

Since no data leaves the device, there is no central store to breach. The information kept by the app enjoys the isolation iOS applies to each application's container.

7. Complaints

You may lodge a complaint with your national supervisory authority — in France, the CNIL.