ROLA PRIVACY POLICY

Last update:18 February 2022

This privacy policy explains in detail how we collect, use, and disclose your personal data. It also informs you about the choices that you have with respect to your personal data. Please read this privacy policy carefully before submitting your personal data to us.
  • 1. GENERAL INFORMATION

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  • 2. WHAT DATA DO WE COLLECT?

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  • 3. HOW LONG DO WE STORE YOUR DATA?

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  • 4. HOW DO WE DISCLOSE YOUR DATA?

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  • 5. HOW DO WE PROTECT YOUR DATA?

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  • 6. HOW CAN YOU MANAGE YOUR PERSONAL DATA?

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  • 7. COOKIES

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  • 8. CONTACT

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1. GENERAL INFORMATION
Here you can find some general information about us and Rola.

1.1 About the Privacy Policy. This Rola privacy policy (the “Privacy Policy”) governs the pro- cessing of personal data collected from individual users (“you” and “your”) through the social network application „Rola‟, the website available at www.rola.ai, and the related services (collec- tively, “Rola”). The Privacy Policy does not cover any third-party websites, applications or soft- ware that integrate with Rola or any other third-party products and services.

1.2 Data controller. Rola is owned and operated by Crystal Vision Developments Limited located at 8 Burn Road, #12-05 Trivex, Singapore 369977, Singapore, and the company number (BVI) 1975930 (“we,” “us,” and “our”).

1.3 Children. Rola is not intended for use by persons under the age of 18. We do not knowingly collect personal data belonging to persons younger than 18. If you become aware that such a per- son has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove the child‟s personal data from our sys- tems.

1.4 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.5 Amendments. This Privacy Policy can be changed from time to time to address the changes in our business practices, the functionalities of Rola, laws, regulations, and industry standards. The amended version of the Privacy Policy will be posted on this page and, if we have your email ad- dress, we will send you a notice about all the changes implemented by us. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.

2. WHAT DATA DO WE COLLECT?
Here we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use Rola, and how we communicate with you.

2.1 Sources of personal data. We obtain your personal data from the following categories of sources:

  • Directly from you. For example, if you submit your personal data when you register your user account, conclude a service agreement with us, or contact us;
  • Directly or indirectly through your activity on Rola. When you use Rola, we automatically collect technical information about your use of Rola by means of cookies and analytics services; and
  • From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for dis- closing your personal data to us (for example, for payment processing purposes).

2.2 Collection of personal data. We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that is necessary for your use of Rola. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. For example, we use it only for the purposes of providing you with access to Rola, main- taining and improving Rola, replying to your enquiries, and pursuing our legitimate interests. We do not repurpose your personal data. This means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.

  • Your account. When you register your user account, we collect your username, email address, and password. We use the said information to register and maintain your user account, enable you to access and use Rola, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are „performing a contract with you‟ and ‟pursuing our legitimate interests‟ (i.e., operate, analyse, grow, and administer Ro- la). We will store this data until your user account is deleted.
  • Payments. When you make a payment, our third-party payment processor Stripe collects your personal data, such as your name, billing address, and payment details (e.g., credit card de- tails). We do not have access to your full payment data. Your payment data is used to process payments and maintain our accountancy records. The legal bases on which we rely are „per- forming our contractual obligations‟ and „pursuing our legitimate interests‟ (i.e., to administer our business). We store such data for the time period prescribed by law.
  • Enquiries. When you contact us by email or through Rola, we collect your first name, last name, email address, and any information that you decide to include in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are „pursuing our legitimate interests‟ (i.e., to grow and promote Ro-la) and „your consent‟ (for optional personal data). We will store this data until you stop com- municating with us.
  • Cookies and IP address. When you browse Rola, we collect your cookie-related data and IP address. We use such information to analyse the technical aspects of your use of Rola, prevent fraud and abuse, and ensure the security of Rola. For more information on our use of cookies, please refer to the section “Cookies” below. The legal bases on which we rely are „pursuing our legitimate interests‟ (i.e., analyse our content and protect Rola) and „your consent‟. We will store this data as long as analytics records are necessary for our activities or you withdraw your con- sent.

2.3 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.

2.4 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of Rola, receive the requested information, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

2.5 Collection of analytics data. When you browse Rola, we collect certain technical analytics data collected from you. Such data includes the following information:

  • URL addresses from which you access Rola;
  • Your device type;
  • Your operating system;
  • IP address; and
  • Your other online behaviour.

2.6 Purposes of analytics data. We use your analytics data to analyse what kind of users access and use Rola, measure your engagement with Rola, see which parts of Rola are interesting to you, improve our content, develop new products and services, and investigate and prevent security is- sues and abuse. In most cases, such analytics data is non-personal and it does not allow us to iden- tify you as a natural person. However, some of such data like your IP address may be considered personal data and we will make sure that we have the necessary legal basis for processing such data. When we process your analytics data that is personal data, we rely on the „legitimate interest‟ (i.e., to analyse, improve, and protect Rola) and „your consent‟ bases.

2.7 Your feedback. If you contact us, we may keep records of any questions, complaints, recom- mendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).

2.8 Aggregate and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggre- gate data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.

2.9 Newsletters. If you opt-in for our newsletter, subscribe to our newsletter, or conclude a service contract with us, we will inform you about our new services, features of Rola, and special offers. The legal bases on which we rely is „your consent‟ (if you opt-in) and „pursuing our legitimate business interests‟ (i.e., promote Rola). You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.

2.10 Transactional notices. If we have your email address and it is necessary to do so, we may send you important informational messages, such as payment receipts, invoices, and other tech- nical or administrative emails. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior con- sent. You cannot opt-out from service-related notices.

3. HOW LONG DO WE STORE YOUR DATA?
Here we explain for how long we keep your data in our systems and how we delete it.

3.1 Storage of personal data. We and our data processors store your personal data only for as long as such personal data is required for the purposes described in this Privacy Policy or until you re- quest us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please refer to section 2.2. After your per- sonal data is no longer necessary for its purposes and there is no other legal basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any per- sonal data longer than strictly necessary.

3.2 Storage of non-personal data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include storing non-personal data for the period of time needed for us to examine our activities, fulfil our contractual obliga- tions, pursue our legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

3.3 Storage as required by law. When we are obliged by law to store your personal data for a cer- tain period of time (e.g., for keeping accounting records), we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.

4. HOW DO WE DISCLOSE YOUR DATA?
Here you can find information about third parties that may have access to your personal data.

4.1 Disclosure to data processors. We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment pro- cessing, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations

when it is required for the following purposes:

  • Ensuring the proper operation of Rola;
  • Delivering you the requested services;
  • Processing your payments;
  • Responding to your enquiries;
  • Pursuing our legitimate interests;
  • Enforcing our rights, preventing fraud, and security purposes;
  • Carrying out our contractual obligations;
  • Law enforcement purposes; or
  • If you provide your prior consent to such a disclosure.

4.2 List of data processors. We choose our data processors carefully and make sure that they en- sure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that will have access to your personal data are:

  • Our hosting service provider Amazon Web Services (AWS) located in the United States;
  • Our payment service provider Stripe located in the United States;
  • Our database service provider MYSQL; and
  • Our independent contractors and consultants.

4.3 International transfers. Some of our data processors may be based outside the country where you reside. For example, if you reside in the UK or a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the UK or the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre- approved Standard Contractual Clauses).

4.4 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving Rola, responding to lawful requests from public authorities or developing new products and services.

4.5 Legal requests. If requested by a public authority, we will disclose information about the users of Rola to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

5. HOW DO WE PROTECT YOUR DATA?
Here you can find information on how we protect your data against breaches.

5.1 Security measures. We implement technical and organisational information security measures that protect your personal data from loss, misuse, unauthorised access and disclosure. The security measures taken by us include proper authentication, secured networks, strong passwords, encryp- tion, limited access to your personal data by our staff, DDoS prevention, anonymisation of person- al data (when possible), and carefully selected data processors.

5.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a seri- ous breach occurs, we will take reasonable measures to mitigate the breach, as required by the ap- plicable law. Unless the applicable law states otherwise, we will not be responsible for security breaches that occur outside of our reasonable control.

6. HOW CAN YOU MANAGE YOUR PERSONAL DATA?
Here you can find detailed information about the rights that you have with regard to your person- al data and how to exercise those rights.

6.1 The list of your rights. You have the right to control how we process your personal data. Sub- ject to any exemptions provided by law, you have the following rights:

  • Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
  • Right to rectification: you can rectify inaccurate personal data that we hold about you;
  • Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
  • Right to restriction: you can ask us to restrict the processing of your personal data;
  • Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal da- ta to another processor;
  • Right to object: you can ask us to stop processing your personal data;
  • Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
  • Right to complaint: you can submit your complaint regarding our processing of your per- sonal data.

6.2 How to exercise your rights? If you would like to exercise any of your legitimate rights, please contact us by using our contact details available at the end of the Privacy Policy and explain in de- tail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will an- swer your request within a reasonable time frame but no later than 30 days.

6.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

7. COOKIES

7.1 What should you know about cookies? A cookie is a small piece of data typically consisting of letters and numbers. When you visit a website, that website may send a cookie to your browser. Subsequently, the browser may store the cookie on your computer or mobile device for some time (cookie expiration date depends on its type). Cookies are used to recognise your device and collect certain information about your use of websites. Thus, over time, cookies allow websites to “re- member” your actions and preferences. There are several types of cookies, namely, (i) persistent cookies, which remain valid until deleted by you, (ii) cookies that remain valid until their expira- tion date, and (iii) session cookies that are stored on a web browser and remain valid until the moment the browser is closed. Cookies may also be (i) first-party cookies (set by the original web- site itself) and (ii) third-party cookies (placed by third-party websites).

7.2 Our cookies. Below, you can find a list of cookies that we use on Rola, including their purpose and expiration time:

Essential technical cookies
Name Type Provider (location) Expiration Purpose
Preference cookies
Name Type Provider (location) Expiration Purpose
Marketing cookies
Name Type Provider (location) Expiration Purpose
Statistics cookies
Name Type Provider (location) Expiration Purpose
_ga First-party HTTP cookie rola.ai (US) 2 years The cookie is used to set a unique ID that is used to gener- ate statistical data on how you use Rola.

7.3 Cookie consent.When you visit Rola, we may ask you to provide us with your consent to our use of all cookies via a cookie consent banner (for example, if you come from the EU). If you do not provide your opt-in consent, we will not serve you our non-essential cookies. Please note that we may not be able to provide you with the best possible user experience on Rola if not all cookies are enabled.

7.4 Disabling cookies. If we ask you to provide your consent to our use of non-essential cookies, you have the freedom not to provide such consent. If you would like to refuse our use of non-essential cookies later, you can do it at any time by declining cookies in your browser or device. For more information, you can consult the cookie management instructions of your browser.

8. CONTACT

If you have any questions about this Privacy Policy, your rights, or our data protection practices, please contact us by using the following contact details:

Email: info@rola.ai

Postal address: Crystal Vision Developments Limited, 8 Burn Road, #12-05 Trivex, Singapore 369977, Singapore