Privacy Policyupdated: Nov 2024

Data Controller

For the purposes of this Privacy Policy, RootstockLabs Limited is the data controller of your personal data. If you have any questions about this policy or how we handle your data, please contact us at legal@rootstocklabs.com.

Information We Collect

We may collect and process the following types of personal data:

• Identity Data: Name, social media handles.
• Contact Data: Address, email address.
• Technical Data: IP address, device type (including operating system).
• Usage Data: Information on your location, time, date, and duration of visits to our websites, as well as previous visits.

How We Use Your Information

We process your personal data for the following prposes:

• Service Provision: To deliver our services and allow you to use our websites.
• Service Improvement: To analyze and improve our services and user experience.
• Direct Marketing: To send you communications about products, services, and promotions.

Legal Bases for Processing

We rely on the following legal bases for processing your personal data:

• Consent: For sending marketing communications and processing specific data.
• Legitimate Interests: For providing services, improving security, and operations.
• Contractual Necessity: To fulfill our contractual obligations to you.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including legal, accounting, or reporting requirements. Our data retention periods are as follows:

• Marketing Data: Retained until you opt-out.
• Other Data: Retained to fulfill the purpose, then securely deleted.

Use of Third Party Applications & Cookies

We use the following cookies listed below on our Websites. We also engage with third party services that may also include the use of cookies. Cookies are a feature of web browser software that allows web servers to recognize the computer or device used to access a website. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. They allow the website to remember your actions and preferences over a period of time, so you don’t have to keep re-entering them whenever you visit one of our Websites or browse from one page to another. They also enable us to track and monitor activity on our Websites to improve our services (for marketing and functionality purposes) as well as allowing you to interact with social media services.

In addition to the uses of cookies described above, these entities may use other methods, such as the technologies described below, to collect information about your use of our website and other websites and online services. These are:

• Pixels tags – Pixel tags (which are also called clear GIFs, web beacons, or pixels), are small pieces of code that can be embedded on website and emails. Pixels tags may be used to learn how you interact with our Websites pages and emails and this information helps us and our partners provide you with a more tailored experience.
• Device Identifiers – A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyze and improve the performance of the website and ads delivered.

We use the following third party services:

Google Analytics

We use Google Analytics to analyze the use of our Websites. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our Websites is used to create reports about the use of our Websites. More information on how Google collects and processes data can be found here https://policies.google.com/technologies/partner-sites/. The relevant cookies are: “_gat. _anonymizeIp”.

You may prevent Google Analytics from using cookies when you visit our Websites at any time by means of a corresponding adjustment to the settings of your web browser.

You also have the option of objecting to the collection of Personal Data by Google Analytics from our Websites by downloading and installing a browser add-on which can be found under the link https://tools.google.com/dlpage/gaoptout.

Further information and the applicable data protection provisions of Google please visit https://www.google.com/intl/en/policies/privacy/ and http://www.google.com/analytics/terms/us.html.

Google Analytics, its purpose and function are further explained under the following link https://www.google.com/analytics/.

Facebook

We use Facebook pixels to analyze and optimize the use of our Websites and our marketing. Facebook gathers information about website use by means of cookies. The information gathered relating to our Websites is used to create reports about the use of our Websites, and for marketing purposes.

Facebook’s Data policy is available at: https://www.facebook.com/about/privacy/update. The relevant cookies are: “Facebook Pixel Code”.

You may prevent Facebook from using cookies when you visit our Websites at any time by means of a corresponding adjustment to the settings of your Facebook account.

Further information and the applicable data protection provisions of Facebook please visit:

• https://www.facebook.com/business/gdpr
• https://www.facebook.com/business/news/facebooks-commitment-to-data-protection-and-privacy-in-compliance-with-the-gdpr

Facebook Pixel, its purpose and function are further explained under the following link:https://www.facebook.com/business/learn/facebook-ads-pixel.

Amazon Web Service

We use Amazon Web Service to host our Websites. Amazon Web Service is a cloud-based service with servers located throughout the world. Therefore, it is possible that your Personal Data will be stored outside the EEA. However, Amazon Web Service is part of the EU-US Privacy Shield scheme that seeks to secure your data to an equivalent level as that required within the EEA.

Amazon Web Service’s Privacy Policy can be found athttps://aws.amazon.com/privacy/.

Social Media Links

We use links to our social media profiles on our Websites. When you click on those links, those services might also collect Personal Data. Please refer to the respective privacy policies below for more information:

• Facebook: https://www.facebook.com/policy.php
• Twitter: https://twitter.com/privacy
• Instagram: https://help.instagram.com/519522125107875
• LinkedIn: https://www.linkedin.com/legal/privacy-policy
• Telegram: https://telegram.org/privacy

OPT-Out

When you visit our site, you are able to opt-out of the use of all cookies which are not strictly necessary. If you opt-out, you may continue to browse our Websites, but certain functionality may not be available due to technological constraints as some features of our Websites rely on cookies to operate correctly.

Data Sharing & Disclosure

We may pass your information to our related entities, affiliates, administration centers, third party service providers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing our services to you.

In addition, when we use any other third party service providers, we will disclose only the Personal Data that is necessary to deliver the service required and we will ensure that they keep your information secure and not to use it for their own direct marketing purposes.

In addition, we may transfer your Personal Data to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganization, or if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.

International Transfers

We may share your Personal Data with third party companies where we have a legal basis for doing so such as to provide you with our services or because we ourselves use service providers outside of the European Economic Area (EEA). The EEA includes the European Union countries as well as Iceland, Liechtenstein and Norway. Transfers outside of the EEA are sometimes referred to as ‘third country transfers’.

If we transfer your information outside of the EEA to third parties, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Policy. This may require us to take certain additional steps to ensure that appropriate safeguards are in place if that third country is not deemed by the European Commission to offer an adequate level of protection for your privacy rights, which may include use of contractual safeguards to allow you to be able to enforce your rights and ensure these are preserved. In certain circumstances, we may need to ask you for your explicit consent to such third country transfers and will always do so in writing and will give you full information about why we need your consent and your right to withdraw that consent at any time (together with the consequences of withdrawal).

Your Data Protection Rights

• Right to access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object

To exercise any of these rights, please contact us at legal@rootstocklabs.com.

Security of Your Data

We use technical and organizational measures to protect your data from unauthorized access or disclosure.

Changes to This Privacy Policy

Updates to this policy will be indicated by an updated “Revised” date and will become effective once accessible.

Regulatory Authority (GRA)

You may contact the GRA on the below details:

You also have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of our rights has taken place, if that is based in the EEA.

Contact Us

Any questions regarding our Policy or your rights as a Data Subject should be sent to: legal@rootstocklabs.com