Last Updated: May 9, 2022
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.
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 Data That We Collect
- When you use or interact with us through the Services, we may collect Personal Data.
- Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Sometimes this will be on our own behalf and other times this will be on behalf of a Servicer using our Services. This is an important distinction for EU data protection law purposes and is explained in more detail below.
- Identifying information such as your name, address, telephone number, email address, business seller information, or tax identification number when you register for an account with us. Information you provide us when creating a profile on Rockoly Inc, which may include:
- A profile picture and access to your camera and/or photo library (if you choose to enable this service on your device);
- Information you provide during a transaction, or other transaction-based content that you generate or that is connected to your account as a result of a transaction you are involved in.
- In some instances, when you use our Services, you may provide age, gender, interests, and favorites.
- You may also provide us with other information, by updating or adding information to your account, through your participation in community discussions, chats, dispute resolution, or referral services, or when you otherwise communicate with us.
- Additional information we are required or authorized by applicable national laws to collect and process in order to authenticate or identify you or to verify the Information We Have Collected.
Categories and Purposes for Which We Will Use Your Personal Data
- Account Data, including your phone number, username, and password.
- Contact Data, including billing address, email address and telephone numbers.
- Payment Data, including payment card/account details, account verification data and transaction data.
- Technical Data, including internet protocol (IP) address, your login data, device IDs, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Service.
- Profile Data, including your first name, last name, marital status, age, gender, other information and preferences you decide to add to your profile, including financial data and Special Categories of Personal Data, blog posts, photos used in connection with your Account, and information you provide in relation to specific services you request, such as Certified Millionaires and photograph verification.
We use your Personal Data for the following purposes:
|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|
Personal Information We Collect Automatically When You Use Our Services or Register For an Account with Us
- We collect information about your interaction with our Services, your advertising preferences, and your communications with us. This is information we receive from devices (including mobile devices) you use when you access our Services. This information could include the following: Device ID or unique identifier, device type, ID for advertising, and unique device token.
- Location information, including location information from your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of location services by any Website on your mobile device in the device’s settings menu.
- Cellular device and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history, and your web log information.
Personal information collected from other sources
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
- We allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you, and information about the advertisements you have been shown or have clicked on, etc.). If you provide us with access to any site with video content, then you agree that we can share your video viewing with, or obtain information about your video viewing from, third-party social media sites for at least two years or until you withdraw authorization or connection to the social media site.
- You control the personal information you allow us to have access to through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to the personal information retained by the respective social media site about you. By associating an account managed by a social media site with your account and authorizing us to have access to this information, you agree that we can collect, use and retain the information provided by these social media sites in accordance with this privacy notice. We may also use plug-ins or other technologies from various social media sites. If you click on a link provided via a social media plug in, you are voluntarily establishing a connection with that respective social media site.
- If you give us personal information about someone else, you must do so only with that person’s authorization. You agree to inform them how we collect, use, disclose, and retain their personal information according to our privacy notice.
Information Collected From All Users
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.
- When you register for the Services or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you.
How We Use Your Personal Data
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.
- We use your personal information to provide and improve our Services, provide you with a personalized experience on our sites, contact you about your account and our Services, provide you customer service, provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities.
- We use the personal information we collect from you for a range of different business purposes and according to different legal bases of processing.
Access and Use
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.
Internal Business Purposes
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.
Rockoly Inc Marketing
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.
Use of Interest-Based Data
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.
Aggregated Personal Data
Staying Signed in
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.
How We Disclose and Transfer Your Personal Data
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.
Google, Social Media and Other Third Party Connections
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.
How We Store Your Personal Data
How You Can Access, Update, Correct or Delete Your 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.
How Long We Retain Your Personal Data
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.
Limit the Personal Data You Provide
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.
Do Not Track
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.
Personal Data Provided to Others
Third Party Links
Third Party Privacy Practices
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.
Notice for Nevada Residents
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 email@example.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 firstname.lastname@example.org.
Children – Children’s Online Privacy Protection Act (COPPA)
International Privacy Laws
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) for EEA, SWITZERLAND AND UK ONLY.
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:
- You provided your consent; it is necessary for our contractual relationship;
- The processing is necessary for us to comply with our legal or regulatory obligations;
- And/or the processing is in our legitimate interest as a service platform.
Transfers of Personal Data
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.
Your Rights and Personal Data Retention
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.
Rockoly Inc. as a Data Controller and a Data Processor
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.
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:
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:
54 MERION ROAD, PO 723
DOVER, DE 19904