Privacy Policy

This privacy notice applies to any Rockoly Inc, Website, service, or tool (collectively “Services”) where this privacy notice is referenced, regardless of how you access or use them, including through mobile devices. This policy along with the Terms of service govern your use of the Rockoly Inc. Website.

This Privacy Policy sets forth our policy with respect to information that can be associated with or which relates to a person and/or could be used to identify a person (“Personal Data”) that is collected from Users on or through the Services.

We take the privacy of your Personal Data seriously. Because of that, we have created this Privacy Policy. Please read this Privacy Policy as it includes important information regarding your Personal Data and other information.

We may amend this privacy notice at any time by posting the amended version on this site including the effective date of the amended version.

Personal Information We Collect Automatically When You Use Our Services or Register For an Account with Us

We use cookies, web beacons, unique identifiers, and similar technologies to collect information about the pages you view, the links you click, and other actions you take when using our Services, within our advertising or email content.

For more information about our use of these technologies, and how to control them, see Cookies, Web Beacons and Similar Technologies (alternatively referred to as Cookie Policy).

We supplement the personal information we collect directly with information collected from third parties and add it to your account information. For example, we collect and use demographic and other information that is publically available in an applicable jurisdiction, additional contact information, credit check information, and information from credit bureaus, as allowed by applicable national laws

Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with inquiries, respond to one of our surveys or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address and any other information that you choose to provide and/or that enables Users to be personally identified.

We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy, and applicable privacy laws. We may use the Personal Data as follows:

If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.

If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.

We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.

We may use your Personal Data for our marketing and advertising purposes, including (without limitation) by email, SMS marketing, display media, and targeting other devices (such as tablets, mobile devices and televisions). We do this in order to inform you about services or events we believe might be of interest to you, develop promotional or marketing materials and display Rockoly Inc. or event-related content and advertising on or off the Services that we believe might be of interest to you. We may also do this on behalf of an Servicer, for example where your prior interactions with an Servicer suggest you may be interested in a particular type of service.

You may see advertisements for our Services (on third party Websites, including on social media platforms. Where you see an advertisement on a third party Website or social media platform, this may be because we engaged the third party or social media platform to show this advertisement to our Users, or to others who have similar attributes to our Users. In some cases, this involves sharing your email address or other contact details with the third party or social media platform so that they can identify you as one of our Users, or identify other individuals with similar attributes to you in order to show them advertisements for Services. If you no longer want your Personal Data to be used for these purposes please contact us.

We sometimes make inferences about the type of services you may be interested in. We may use these inferences to help target advertising or customize recommendations to you, including on behalf of Servicers. We may do this on an aggregated or generalized basis.

If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected or we will obtain your consent subsequent to such collection but prior to such use.

In an ongoing effort to understand and serve our Users better, we often conduct research on our customer demographics, interests and behavior based on Personal Data and other information that we have collected. This research is typically conducted on an aggregate basis only that does not identify you. Once Personal Data is in an aggregated form, for purposes of this Privacy Policy, it becomes Non-Personal Data.

When you sign in to your account on our Services, we give you the option to stay signed in to your account for certain amount of time. If you are using a public or shared cellular device, we encourage you not to choose to stay signed in. You or any other user of the cellular device/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorization. If you are using a public or shared cellular device, you should sign out and/or clear your cookies when you are done using our Services to protect your account and your personal information.

We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth in this Privacy Policy.

We may share your Personal Data with contractors and service providers who process Personal Data on Rockoly Inc. to perform certain business-related functions. We are not responsible for the actions of these Servicers, or their Third Party Servicers (or other downstream recipients of your Personal Data), with respect to your Personal Data. It is important that you review the applicable policies of the Servicers, and if applicable and available, their appointed Third Party Servicers, before providing Personal Data or other information in connection with that service.

Connecting Your Rockoly Inc. Account to Social Media Services. You can connect your Rockoly Inc. account to your accounts on third party services like Google, in which case we may collect, use, disclose, transfer and store/retain information relating to your account with such third party services in accordance with this Privacy Policy.

We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.

We may store Personal Data itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the Personal Data collected via the Services from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any Personal Data.

You can request access to some of your Personal Data being stored by us. You can also ask us to correct, update or delete any inaccurate Personal Data that we process about them.

If a Consumer initiates a data deletion request, Rockoly Inc. is authorized to delete or anonymize Personal Data of the requesting Consumer from the Services even if that means removing its availability to the Servicer through the Services. However, if you are a Consumer, you understand that even if Rockoly Inc. deletes or anonymizes your Personal Data upon your request or pursuant to this Policy, your Personal Data may still be available in the Servicer’s own databases if transmitted to the Servicer prior to Rockoly Inc. receiving or taking action on any deletion or anonymization activity.

We will consider and respond to all requests in accordance with applicable law.
Access, correction, and deletion of your personal information. Upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable national laws.

We may retain your Personal Data as long as you are registered to use the Services. You may close your account by contacting us. However, we may retain Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services.

We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personal Data.

This Privacy Policy does not apply to any Personal Data that you provide to another User or visitor through the Services or through any other means.

This Privacy Policy applies only to the Services. The Services may contain links to other Websites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

This privacy notice addresses only our use and handling of personal information we collect from you in connection with providing you our Services. If you disclose your information to a third party, or visit a third party Website via a link from our Services, their privacy notices and practices will apply to any personal information you provide to them or they collect from you. We cannot guarantee the privacy or security of your personal information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your personal information. This is true even where the third parties to whom you disclose personal information are bidders, buyers or sellers on our site.

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by info@rockoly.com Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

If you are a California resident, you may ask for a list of third parties that have received your information for direct marketing purposes during the previous calendar year. California law may also require us to compile the following metrics for the previous calendar year. To make such a request, contact us at info@rockoly.com.

We do not knowingly collect Personal Data from children under the age of eighteen (18). If you are under the age of eighteen (18), please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to us through the Services, please contact us and we will endeavor to delete that information from our databases.

We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. We use this data to analyze trends, gather demographic information, and cooperate with law enforcement activities.

If you are visiting the Services from outside the United States, please be aware that you are sending information (including Personal Data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your Personal Data will at all times continue to be governed by this Privacy Policy.

We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time (collectively, “Modifications”). Modifications to this Privacy Policy will be posted to the Site with a change to the “Updated” date at the top of this Privacy Policy. In certain circumstances Rockoly Inc. may, but need not, provide you with additional notice of such Modifications, such as via email or with in-Service notifications.

Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was updated on the date indicated above. Your continued use of the Services following the effectiveness of any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing and otherwise using the Services.

If you have a complaint about Rockoly Inc’s privacy practices you should contact us. We will take reasonable steps to work with you to attempt to resolve your complaint in accordance with the “Terms” incorporated with these policies.

The GDPR requires Rockoly Inc. and Servicers using the Service to provide Users with more information about the processing of their Personal Data. The GDPR requires us to tell you about the legal ground we’re relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out above will typically be because:

As Rockoly Inc. is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA, Switzerland and the UK which have no data protection laws or laws that are less strict compared with those in Europe.

Whenever we transfer Personal Data outside of the EEA, Switzerland or the UK, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data. For Personal Data we receive from the EEA, Switzerland and the UK, Rockoly Inc. has certified its compliance to the EU-U.S. and Swiss-U.S. Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from those countries.

We have certified that we adhere to the Privacy Shield principles of Notice, Choice, and Accountability for Onward Transfers, Security, Data Integrity & Purpose Limitation, Access and Recourse, Enforcement & Liability when processing Personal Data from the EEA, Switzerland or the UK in the United States.

We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. If you have an account with us, we will typically retain your Personal Data for a period of ninety (90) days after you have requested that your account is closed or if it’s been inactive for seven (7) years.

Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications.

For the most part, you can exercise these rights by logging in and visiting the My Account page or changing the “cookie settings” in your browser (see our Cookie Policy for more information). There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.

EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.

Rockoly Inc. may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances.

AdRoll and Partners

Collection of Data

Our site uses technologies of third-party partners [such as NextRoll] to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the [products and/or services] that are likely to be of more interest to you. Specifically, [NextRoll/these partners] collect information about your activity on our site(s) to enable us to:

Measure and analyze traffic and browsing activity on our site(s);
[Optional: if you are using our Media Services to run campaigns include this disclosure] show advertisements for our products and/or services to you on third-party sites;
[Optional: if you are using our Cross Channel Measurement Services include this disclosure] measure and analyze the performance of our advertising campaigns;

Cross-Device [Optional: if you are using our Cross Device or AdRoll Email Services]

We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with [NextRoll/ our advertising partners]. This allows our partners to recognize and deliver you ads across devices and browsers. To read more about the technologies used by [NextRoll/our partner] and their cross device capabilities please refer to NextRoll’s Privacy Notice.

Opting-Out

Our partners [such as NextRoll] may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason you can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising:

Change of Ownership

If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.

If you have a question or a complaint about this privacy notice, our global privacy standards, or our information handling practices, you can reach us at:

PURPOSE	DATA CATEGORY
Account and membership management	(a) Account Data (b) Contact Data (c) Payment Data
Provision of our services on the website and app, including customer services	All data categories
To maintain our services	All data categories
To improve our services	All data categories
To contact you (including sending information and updates relating to our services)	(a) Account Data (b) Contact Data
To improve user relationships and experiences on the basis of data analytics	(a) Contact Data (b) Technical Data (c) Profile data
To monitor the use of our services and prevent blocked users from accessing the site or the information of other users.	All data categories