This Privacy Policy describes how Roca Holdings Ltd, trading as Roca Holdings (together with its affiliated companies – “Roca Holdings”, “we”, “our” or “us”) collects, stores, uses and discloses the following categories of personal data:
(i) Customer Data: personal data that we collect, process and manage on behalf of our business customers (“Customers”), submitted to the Roca Holdings cloud-based services, including our platforms, products, applications, application programming interface (“API”), tools, and any ancillary or supplementary Roca Holdings products and services (including Upgrades) offered online and via a mobile application (collectively, “Platform”).
We process such Customer Data on behalf and under the instruction of the respective Customer in our capacity as a “data processor’’.
Accordingly, this Privacy Policy – which describes Roca Holdings’s independent privacy and data processing practices as a “data controller” – with respect to the Platform, Sites (as defined below) and any other services provided to Customer by Roca Holdings (“Services”), and does not apply to the processing of Customer Data. If you have any questions or requests regarding Customer Data, please contact your account administrator(s) (“Account Admin”) directly.
(ii) User Data: personal data concerning our Customers’ internal focal persons who directly engage with Roca Holdings concerning their Roca Holdings account (e.g. billing contacts and authorised signatories), Customers’ Account Admins, and authorised users of the Platform (collectively, “Users”);
(iii) Prospect Data: data relating to visitors of our websites (including but not limited to www.rocaholdings.com), participants at events, and any other prospective customer, user or partner (collectively, “Prospects”) who visit or otherwise interact with our programs, marketing and social activities and our websites, digital ads and content, emails, integrations or communications under our control (“Sites”).
(iv) Technology Partner Data: data relating to individuals participating and/or engaging as a participant, candidate, applicant or any other prospective or existing technology partners (including as developer or technology ambassadors) who interact with our Platform, Sites, events and/or other platforms utilized by Roca Holdings.
You are not legally required to provide us with any of your personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our services providers, please simply do not visit or interact with our Sites, nor use our Services.
You may also choose not to provide us with “optional” personal data (i.e. “not required” fields on forms), but please keep in mind that without it we may not be able to provide you with the full range of our Services or with the best user experience when using our Services.
1. Data Collection & Processing
When we use the term “personal data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or anonymised information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.We collect or generate the following categories of personal data in relation to the Services:
Usage and device information concerning our Users, Prospects and Technology Partners:
Connectivity, technical and usage data, such as IP addresses and approximate general locations derived from such IP addresses, device and application data (like type, operating system, mobile device or app ID, browser version, location and language settings used), activity logs, the relevant cookies and pixels installed or utilized on your device, and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) of Prospects, Users and Technology Partners in connection with our Services.
We collect and generate this information automatically, including through the use of analytics tools (including cookies and pixels) – which collect data such as: how often Prospects or Technology Partners visit or use the Sites, which pages they visit and when, which website, ad or email message brought them there, and how Users interact with and use the Platform and its various features.
Contact and profile information concerning our Customers, Users, Prospects and Technology Partners:
Name, email, phone number, position, workplace, profile picture, login credentials, contractual and billing details, and any other information submitted by Account Admins and Users or otherwise available to us when they sign up or log in to the Platform (either directly or through their social media or organizational Single-Sign-On account), when creating their individual profile, or by updating their account.
We collect this information directly from you, or from other sources and third parties such as our Customer (your employer), Users and colleagues related to your organizational Roca Holdings account, organizers of events or promotions that both you and us were involved in, and through the use of tools and channels commonly used for connecting between companies and individual professionals in order to explore potential business and employment opportunities, such as LinkedIn.
Communications with our Customers, Users, Prospects and Technology Partners:
Personal data contained in any forms and inquiries that you may submit to us, including support requests, interactions through social media channels and instant messaging apps, registrations to events that we host, organize or sponsor, and participation in our online and offline communities and activities); surveys, feedback and testimonials received; expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement; and sensory information including phone call and video conference recordings (e.g., with our customer experience or product consultants), as well as written correspondences, screen recordings, screenshots, documentation and related information that may be automatically recorded, tracked, transcribed and analysed, for purposes including analytics, quality control and improvements, training, and record-keeping purposes.
2. Data Uses & Legal Bases
We use personal data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services to you and others; providing customer services and technical support; and protecting and securing our Users, Customers, Prospects and Technology Partners, ourselves and our Services.
Specifically, we use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
Customer and User personal data
- To facilitate, operate, enhance, secure and provide our Services.
- To invoice and process payments.
- To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities.
Customer, User, Prospect and Technology Partner personal data
- To provide our Prospects, Users, Technology Partners and Customers with assistance and support, to test and monitor the Services, diagnose or fix technical issues, and to train our Customers’ and Customer-facing staff.
- To gain a better understanding of how Users, Prospects and Technology Partners evaluate, use, and interact with our Services, to utilize such information to continuously improve our Services, the overall performance, user-experience and value generated therefrom. We collect such information automatically through their usage of the Services, including through User’s utilization of artificial intelligence capabilities in the Platform.
- To create aggregated, statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or others may use to provide and improve our respective Services, or for any other business purpose such as business intelligence.
- To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our Services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby to increase your engagement and overall satisfaction with our Services. This includes contextual, behavioural and interests-based advertising based on User, Prospect and Technology Partner activities, preferences or other data available to us or to our Services Providers (as defined below), and business partners.
- To contact our Customers, Users, Prospects and Technology Partners with general or personalized Services-related messages, as well as promotional messages that may be of specific interest to them.
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.
- To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences, including through partnerships with local distributors, resellers, business partners and providers of professional services related to our Services.
- To facilitate, sponsor and offer certain events, webinars, contests and promotions.
- To publish your feedback and submissions to our Sites, public forums and blogs
- To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards.
- For any other lawful purpose, or other purpose that you consent to in connection with provisioning our Services.
3. Data Disclosure
We may disclose personal data in the following instances:
Service Providers: We engage selected third-party companies and individuals as “Service Providers”, to perform services on our behalf or complementary to our own. These include providers of Third Party Services, such as: hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection, investigation and prevention services, web and mobile analytics, email and communication distribution and monitoring services, session or activity recording services, call recording, analytics and transcription services, event production and hosting services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content, lead generating and data enrichment providers, email, voicemails, video conferencing solutions, support and customer relation management systems, third-party customer support providers, and our legal, compliance and financial advisors and auditors.Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services or other activities, and may only use the data as determined in our agreements with them.
Partnerships: We engage selected business and channel partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our prospective and existing Customers and Users. In such instances, we may disclose relevant contact, business and usage details to the respective Partner, to allow them to engage with those Customers and Users for such purposes. If you directly engage with any of our Partners, please note that any aspect of that engagement which is not directly related to the Services and directed by Roca Holdings is beyond the scope of Roca Holdings’s Terms and Privacy Policy, and may therefore be governed by the Partner’s terms and privacy policy.
Customers and other Users: Your personal data may be disclosed to the Customer owning the Account to which you are subscribed as a User (including data and communications concerning your User Profile), as well as other Users of that Account. Your personal data and activity within the Services may also be monitored, processed and analysed by the Account Admin. This includes instances where you contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same Customer).
Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review publicly, on our Sites and Services. If you wish to remove your public review, please contact us.
Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and Services.
Protecting Rights and Safety: We may disclose your personal data to others if we believe in good faith that this will help protect the rights, property or safety of Roca Holdings, any of our Users or Customers, or any members of the general public.
Roca Holdings Subsidiaries: We disclose personal data internally within our group of companies, for the purposes described in this Privacy Policy. In addition, should Roca Holdings or any of its subsidiaries undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be disclosed with the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via email or prominent notice on our Services.
For the avoidance of doubt, Roca Holdings may disclose your personal data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.
5. Cookies and Tracking Technologies
Our Sites and Services (including some of our Services Providers) utilize “cookies”, anonymous identifiers, pixels, container tags and other technologies in order for us to provide and monitor our Services and Sites, to ensure that they perform properly, to analyse our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, as indicated by a Prospect, User or Technology Partner. To learn more about our practices concerning cookies and tracking, please see our Cookie Policy. You may also use the “Cookie Settings” feature available in our Services depending on your location and activity on our Services, as applicable.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.
6. Communications
We engage in Services and promotional communications, through email, phone, SMS and notifications.
Services Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. Our Customers, and other Users on the same Account, may also send you notifications, messages and other updates regarding their or your use of the Services. You can control your communications and notifications settings from your User Profile settings, or otherwise in accordance with the instructions that may be included in the communications sent to you. However, please note that you will not be able to opt-out of receiving certain Services communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable, as our Customer, User, Prospect or Technology Partner. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or email), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Roca Holdings at any time by sending us an email, changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.
7. Data Security
In order to protect your personal data held with us, we use industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.
8. Data Subject Rights
If you wish to exercise your privacy rights, such as (each to the extent applicable to you under the laws which apply to you) – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have disclosed personal data), to request rectification or erasure of your personal data held with Roca Holdings, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to obtain a copy or port such personal data, or the right to equal Services and prices (e.g. freedom from discrimination) – please contact us by email.
You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us. In such cases, we may request further information to verify such power of attorney and authorization.
Please note that when you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may instruct you on how to fulfil your request independently through your User Profile settings; refer you to your Account Admin; or require additional information and documents, including certain personal data and credentials in order to process your request in a proper manner (e.g. in order to authenticate and validate your identity so that we know which data in our systems relates to you, and where necessary, to better understand the nature and scope of your request). Such additional information will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request, and of how each request was handled).
We may redact from the data which we make available to you, any personal or confidential data related to others.
9. Data Controller/Processor
Roca Holdings Ltd. is the “data controller” of its Prospects’, Users’, Technology Partner’s and Customers’ personal data.
Roca Holdings is the “data processor” of personal data contained in Customer Data, as submitted by our Customers and their Users to their Accounts. We process such data on behalf of our Customer and in accordance with its reasonable instructions, subject to our Terms and other commercial agreements with such Customer.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the Customer. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
If you would like to make any requests or queries regarding personal data we process as a data processor on our Customer’s behalf, including accessing, correcting or deleting your data, please contact the Customer’s Account Admin directly.
10. Additional Notices
Updates and Amendments:
We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. When we make material changes to this Privacy Policy, we will give notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Services or by sending an email. Your continued use of the Services after the changes have been implemented will constitute your acceptance of the changes.If you have any questions, you can contact us via email.
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ROCA Holdings Limited Company. Registration No: 15653313. 68 Dalling Road London W6 0JA
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