We do not sell your data
We do not sell your personal data. Our business model is to provide you with a free edition and we charge you for extra services or features, according to the plan you choose. What you process within Rosa is yours and stays your.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Cookies and Usage Data
- We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you, if you have provided consent to this processing or if we can base this processing on a legitimate interest that is not overridden by your fundamental rights. You may in the future withdraw that consent or object to receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us
Rosa requires that you register for a personalized account. Account data may include in addition your account name, authentication information, registration date, contact information, payment information, and any other information associated with your account.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service, incl. by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, the IP address of your mobile device, your mobile operating system, the app version, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
As a byproduct of the usage data within a Rosa Administrators may choose to share aggregated and therefore anonymous, non-personal data with us to help us learn more about how our product is being used.
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service (only to allow you to share your location to another user via Rosa, if it was enabled by the administrator).
You can enable or disable location services when you use our Service at any time, through your device settings.
Content you provide
When you use our Services you may provide content into that service (e.g. upload file, send a message).
We regularly monitor aggregated activity data on our infrastructure, but it is not tracking of individual users in the sense of this paragraph, which only occurs when we have a legitimate interest to do so (e.g. for security and compliance purposes). We do perform regular tracking on Rosa.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
How do we use information?
We collect and use your personal data to the extent necessary to carry out our operations and provide our services as well as to comply with any regulatory obligations in our activities.
These purposes are defined in more detail below:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about if you have provided consent to receive this information or the processing is in our legitimate interests and it’s not overridden by your rights.
Legal Basis for Processing Personal Data
In accordance with the applicable regulations, we may only use your personal data for at least one of the following reasons:
To comply with legal and regulatory obligations
We collect and use your personal data to comply various legal and regulatory obligations, such as:
- Anti-money laundering regulations and counter-financing of terrorism regulations, including Know Your Customer (KYC) obligations.
- Regulations relating to international financial sanctions and embargoes.
To fulfil our legitimate interest
We also use your personal data to fulfill our legitimate interests, which include the following:
- Provision and delivery of our products and services.
- Marketing and customer communication and development of our customer relationships.
- Development of our products and services.
- Security and safety of our IT and facilities.
Based on your consent
If processing of certain personal data requires your consent (e.g. cookies), we will inform you of this including details of the specific processing activity and request your consent to such processing. You may request to revoke your consent at any time.
Retention of Data
Douglass P.B.C will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States or other jurisdictions deemed not not have an adequate level of data protection deemed by the competent authorities of your residence.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Douglass P.B.C. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Douglass P.B.C. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Douglass P.B.C.
- To prevent or investigate possible wrongdoing in connection with the Service.
- To protect the personal safety of users of the Service or the public
In accordance with applicable regulations and where applicable, you have the following rights:
- To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
- To rectify: where you consider that your personal data are inaccurate or incomplete, you can request that such personal data be modified accordingly.
- To erase: you can require the deletion of your personal data, to the extent permitted by law.
- To restrict: you can request the restriction of the processing of your personal data.
- To object:you can object to the processing of your personal data, on grounds relating to your particular situation. You have the right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
- To withdraw your consent:where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
- To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.