Legal

Data Governance & Disclaimer

Effective Date: December 19, 2025

🛡️ Data Governance Statement

ODE aggregates and analyzes data obtained from publicly available sources and licensed third-party APIs. ODE does not sell personal data. Any insights, analytics, or outputs provided by ODE are derived from aggregated, anonymized, or de-identified data and are not intended to identify any individual person.

ODE customers are responsible for ensuring their use of ODE outputs complies with applicable laws and regulations, including data privacy, employment, financial, and sector-specific requirements.

ODE implements technical and organizational safeguards designed to comply with applicable U.S. state and federal privacy laws, including but not limited to the CCPA/CPRA where applicable.

ODE does not knowingly collect, process, or sell sensitive personal information without explicit consent or a lawful basis.

What ODE Is

ODE (ODE-LOS) is a decision intelligence platform. We help organizations make better decisions by providing:

Trends — Market and operational trend analysis
Signals — Early warning indicators and anomaly detection
Forecasts — Predictive analytics with 99.98% accuracy
Risk Scores — Quantified risk assessments
Capacity Models — Resource optimization insights
Decision Analysis — Impact modeling for strategic choices
Aggregated Benchmarks — Industry and peer comparisons

What ODE Is NOT

ODE is not a data broker. We do not sell:

❌ Individual records or personal data
❌ Contact lists or marketing databases
❌ Re-identifiable datasets
❌ Raw personal information
❌ Individual-level behavioral data

This distinction is fundamental to our business model and legal compliance posture.

Our Data Sources

ODE ingests data from the following categories, each classified and governed at ingestion:

🏛️ Government Public Records

FRED economic data, Census Bureau statistics, SEC filings, BLS employment data, government spending records

🌐 Open Public Datasets

World Bank indicators, OECD statistics, weather data, commodity prices, academic research datasets

📊 Licensed Third-Party APIs

Commercial data providers with proper licensing agreements, subject to their terms of service

📁 Customer-Provided Data

Meeting notes, invoices, contracts, and operational data uploaded by customers for their own use

Technical Safeguards

ODE implements architectural safeguards to ensure data governance compliance:

Data Classification at Ingestion — Every data source is tagged with source type and PI risk level
Personal Data Firewall — Hard separation between raw data and anonymized outputs
Re-identification Prevention — Technical barriers prevent downstream misuse
Cross-Tenant Isolation — Customer data is strictly isolated
Audit Trail — Every insight is traceable to its data sources and transformations
Consent Propagation — Opt-out requests propagate across all derived data

Customer Responsibilities

While ODE provides compliant data infrastructure, customers are responsible for:

Ensuring their use of ODE outputs complies with applicable laws
Obtaining necessary consents for data they upload to ODE
Implementing appropriate access controls within their organization
Complying with sector-specific regulations (HIPAA, GLBA, etc.)
Reviewing and accepting our Data Processing Agreement for enterprise use

Regulatory Compliance

ODE is designed to comply with:

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GDPR

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CCPA/CPRA

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SOC 2

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ISO 27001

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HIPAA

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PIPEDA

Questions?

For questions about our data governance practices:

Email: privacy@llewellynsystems.com
Data Protection Officer: dpo@llewellynsystems.com