We collect information, including Personal Information, only where we have a lawful basis to do so. Lawful bases on which we may rely include your consent where you have given it, a situation in which processing is necessary for us to perform our obligations pursuant to a contract with you, and the legitimate interests of our business, such as providing the Services to you.
We collect, store and use the following categories of information, which includes Personal Information:
1. Information you provide to us
We collect Personal Information through the Service in order to facilitate and support the features of the Service. Such Information may include your name, mailing and email addresses, and phone number; usernames and passwords; payment information; areas and topics of interest; and comments you post to the Service or otherwise provide to us.
2. Information that is automatically collected
The Service also automatically collects information as you use the Service, including your IP address, operating system, browser type, and other technical identifiers; referring website address; date and time of your use; content you search or access; details of financial transactions you participate in on the Services, including the amount, currency, and method of payment; information shared with us via social media; and your location information (but we will ask for your permission before we use GPS or other tools to identify your precise location). We collect this information for the purposes set out in section 3 below, including providing the Service to you, customizing it for you, and communicating with you.
Your browser may use small data files called “cookies” to automatically transmit some of this information to us, such as the date and time you access the Service. We use such information to monitor traffic to the Service and better understand how you interact with the Service, with the aim of improving the Service. In general, this information is not treated as Personal Information, unless we combine it with or link it to any Personal Information. While you may be able to disable cookies with your browser, doing so may affect the performance and functionality of the Service.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Service.
We use the Personal Information collected for the following purposes:
• Providing, updating and improving the Service;
• Fulfilling transactions and providing user support;
• Evaluating the performance of the Service;
• Diagnosing and correcting technical issues;
• Communicating with you about the Service and your Subscription;
• Customizing the Service for your Subscription;
• To allow access to third party services’ accounts if necessary;
• Displaying content to you that is relevant to your location, interests and use of the Service;
• Confirming legitimate Subscriber activity and detecting security threats;
• Analyzing use and traffic trends using tools like Google Analytics and developing Service enhancements;
• Comply with any procedures, laws, and regulations which apply to us where it necessary for our legitimate interests or the legitimate interests of others;
• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others; and
• For other purposes for which we obtain your consent.
When Personal Information is no longer necessary or relevant for ROSS’s purposes or required under applicable laws, ROSS will delete or destroy the Personal Information or render it anonymous.
Access to the Service is provided to you by ROSS. We do not disclose your Personal Information to third parties, except as stated below, or if we have your consent to do so at the time of collecting that information from you, or as otherwise permitted or required by law. However, we may aggregate, or strip information of personally identifying characteristics, and then share that aggregated or anonymized information with third parties.
We will disclose your Personal Information if we are required to make disclosure by law, for example, to respond to or comply with any law or court order; or to investigate and prevent security threats or fraud. We may also disclose your Personal Information if it is necessary for us to collect a debt from you or vindicate our rights under a contract with you (including our Terms and Conditions of Use and the ROSS Subscriber Agreement).
We may also share your Personal Information with our third party service providers in order to process information and data on the Service, process payments, provide user support service to you, and survey or assess your satisfaction with the Service. When we disclose your Personal Information to third party service providers, it is solely for the purpose of assisting us. Third party service providers are not entitled to use your Personal Information beyond the purposes for which it is disclosed to them. We do not sell or rent your Personal Information to others. We may work with payment processors to help process credit card transactions and other payment methods made through the Service. These payment processors will store certain information about you. Please refer to their privacy policies to learn more about how they use your Personal Information.
The Service may include access to social media applications, networks and other forums, platforms and features that permit you to post Personal Information and other content. When you use such features, any information you post should be considered to be public. Please make sure you trust these applications before sharing any information on them or with them, as we are not responsible for them. For information on how to disconnect your ROSS account from these applications, please see section 10 below.
ROSS may be sold, might sell or buy businesses or assets of businesses, or ROSS might merge with another business. Normally, in the instance such transactions, user information is one of the transferred business assets. In the event that ROSS, a line of business of ROSS, or substantially all the assets of ROSS are transferred as part of such a transaction, your information may well be one of the transferred assets. Where and as required by law, ROSS will make reasonable effort to provide notice on ROSS and to notify you via email to the most recent email address that you have provided to ROSS of any such change in ownership or control of your Personal Information.
We are serious about our responsibility to protect Personal Information. We take administrative, technical and physical measures to safeguard your Personal Information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access to and use of Personal Information. We take physical precautions to ensure that the computer servers on which your Personal Information is stored and archived are secure and that access to such servers is protected. We educate our employees with respect to their obligations to protect your Personal Information.
Please see the ROSS Terms and Conditions of Use or your applicable ROSS Subscriber Agreement for the terms and conditions regarding ROSS IDs and passwords.
We take precautions against possible breaches of our security systems, and we require your cooperation in maintaining the integrity of ROSS IDs and restricting access by persons other than Authorized Users. However, no company can fully eliminate the risks of unauthorized access to Personal Information, and no website, platform or application is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of its security will never occur. The use of our Service is at your own risk.
The Service is not directed to children under the age of 16 years. We do not solicit and will not knowingly collect Personal Information from children under the age of 16. If we learn that any personal information has been collected inadvertently from a child under 16, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 16, please contact us at email@example.com.
You may review, update, correct, or delete any User Data and/or Personal Information. Please contact us if you would like to review or request an update, correction or other change to User Data Personal Information. We will respond to your request as quickly as possible. See “Contact Information” below for instructions for doing so. We may take steps to verify your identity, and make a record of communications with you. If you completely delete all User Data or Personal Information, your user account may become deactivated. Please note that we may retain information that is otherwise deleted in anonymized or aggregated form, in archived or backup copies as required pursuant to record retention obligations, or otherwise as required by law.
Subscribers may have access to a user account under the terms of the ROSS Subscription License Agreement or other agreements, which permits Subscribers to access, correct and update certain Personal Information and other data which they have provided. The accuracy of such Information and data is the responsibility of the Subscriber. If you wish to cancel your user account, you may contact your company’s account administrator or contact us at firstname.lastname@example.org. If you do, Personal Information associated with your user account will be deleted as soon as is reasonably practicable or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymized or aggregated form, in archived or backup copies as required pursuant to record retention obligations, or otherwise as required by law.
You can ask us for a copy of your Personal Information, as well as information about its processing, and can ask for a copy of your Personal Information (including in machine readable form). See “Contact Information” below for instructions for doing so.
Email Communication. You can unsubscribe from our email list by emailing us at email@example.com.
Marketing Communication. We may use some of the information we collect for marketing purposes, including to send you promotional communications about new ROSS features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions by clicking “Unsubscribe” (or similar opt-out language) in those communications. You can also contact us at firstname.lastname@example.org to opt out.
If you are a California resident, there are some additional rights that may be available to you under the California Consumer ProtectionAct (“CCPA”). This policy explains the tools that we have made available to you to exercise some of your data rights under the CCPA, such as the right to deletion and the right to request access to categories of information we have collection about you. We encourage you to manage your information, and to make use of the privacy controls we have included in our Services. You will not be discriminated against for exercising any of your privacy rights under the CCPA.In order to protect your information from unauthorized access or deletion, we may require you to provide additional information for verification. If we cannot verify your identity, we will not provide or delete your information.
This policy explains the tools that we have made available to you to exercise some of your data rights under the CCPA, such as the right to deletion and the right to request access to categories of information we have collection about you. We encourage you to manage your information, and to make use of the privacy controls we have included in our Services. You will not be discriminated against for exercising any of your privacy rights under the CCPA.In order to protect your information from unauthorized access or deletion, we may require you to provide additional information for verification. If we cannot verify your identity, we will not provide or delete your information.
Some browsers, Apps and devices support a “Do Not Track” feature. Our Services does not currently change the way it operates based upon detection of a Do Not Track or similar signal.
If you own a copyright or have authority to act on behalf of a copyright owner and want to report a claim that a third party is infringing that material on or through our Site and/or Services, please send a notice to our copyright agent that includes all of the items below and we will expeditiously take appropriate action. Our designated copyright agent to receive such claims can be reached at email@example.com. This process does not limit our ability to pursue any other remedies we may have to address suspected infringement.
• A description of the copyrighted work that your claim is being infringed;
• A description of the material you claim is infringing and that you want removed or access to which you want disabled and the URL or other location of that material;
• Your address, telephone number, and email address;
• The following statement: “I have a good faith belief that the use of the copyrighted material I am complaining of is not authorized by the copyright owner, its agent, or the law (e.g., as a fair use)”;
• The following statement: “The information in this notice is accurate and, under penalty of perjury, I am the owner, or authorized to act on behalf of the owner, of the copyright or of an exclusive right that is allegedly infringed”; and
• An electronic or physical signature of the owner of the copyright or a person authorized to act on the owner’s behalf.