Marketing Activities

 

If you are receiving promotional emails from us, you can choose to stop receiving those by following the unsubscribe/opt-out instructions in those emails. You can also opt-out by contacting us at roger@rogerthat.la.

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Accessing and Changing Your Information

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To request access to, or to make changes to, data that we have collected from you via the Customer Platforms, please email us at roger@rogerthat.la.

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Individuals in the EEA and the United Kingdom have additional rights.

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Notice to Nevada Consumers

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We do not sell your personal information within the scope of, and according to the defined meaning of a “sale” under, NRS 603A.

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Additional Information for Individuals in the EEA and the United Kingdom

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Note: for purposes of this section, “personal information” has the same meaning as “personal data” as such term is defined in applicable data protection laws.

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Categories of Recipients of Personal Information

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The categories of recipients of personal information with whom we may share your personal information are listed in Disclosure of Your Personal Information above.

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Purpose(s) of the Processing and Legal Bases

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RogerThat as ‘Data Controller’

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As a ‘data controller’, RogerThat processes your personal information for a number of different purposes. Some are essential for us to provide the Services or to fulfill our legal obligations, some help us run the Services efficiently and effectively, and some enable us to provide you with more relevant and personalized offers and information. In all cases, with respect to individuals in the EEA, we must have a reason and a legal ground for processing your personal information. The most common legal grounds on which we rely are briefly explained below:

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·         Performance of a Contract: we may process your personal information in order to enter into, or perform a contract to which you are a party –for instance, when a Customer signs up for the Services.

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·         Legitimate Interests: we may process personal information where it is necessary for our legitimate business interests, but only to the extent that they are not outweighed by your own interests or fundamental rights and freedoms. When we rely on this legal basis, if required, we will carry out a legitimate interest assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws.

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·         Consent: We rely on consent where it is required, such as when we are asking you to confirm your marketing preferences. When we rely on consent, you will be asked to confirm that you give your permission to RogerThat to process your personal information. You have the right to withdraw your consent at any time if you no longer want to be part of the RogerThat processing activity where your consent was sought.

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·         Legal Obligation: RogerThat may have legal obligations to retain and/or disclose your personal information, or may cooperate in a legal or governmental investigation. It is essential that RogerThat complies with its legal, regulatory, and contractual requirements, so if you object to this processing, RogerThat will not be able to provide its Services to you.

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The following breakdown illustrates in more detail our processing activities and how the above legal bases for processing apply (in brackets):

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·         Provide the Site [Legal Basis: Performance of a Contract]

·         Provide the Customer Platforms and our Services to Customers and End Users [Legal Basis: Performance of a Contract]

·         Ensure that the Site and Customer Platforms are operational and optimized for user experience [Legal Basis: Legitimate Interests or Performance of a Contract, depending on the specific use]

·         Improve the content and general administration of the Site, Services and Customer Platforms [Legal Basis: Legitimate Interests]

·         Enhance user experience, including to provide you with customer support [Legal Basis: Legitimate Interests]

·         Detect fraud, illegal activities, or security breaches [Legal Basis: Legitimate Interests]

·         Except with respect to End User Information, enable third parties to deliver advertising to you [Legal Basis: Legitimate Interests or Consent, depending on the specific circumstances]

·         Provide you with notices regarding Services that you have purchased [Legal Basis: Performance of a Contract]

·         Providing you information about Services that you may wish to purchase in the future including, in some cases, to send you direct marketing communications regarding other services that we may think are of interest to you [Legal Basis: Legitimate Interests]

·         Respond to your queries and requests, or otherwise communicate directly with you [Legal Basis: Legitimate Interests or Performance of a Contract, depending on the specific use]

·         Perform system maintenance and upgrades, and enable new features [Legal Basis: Legitimate Interests]

·         Understand how you access and use the Site and Customer Platforms in order to provide technical functionality and develop new products and services [Legal Basis: Legitimate Interests]

·         Conduct statistical analyses and analytics based on usage and activity on the Site Legal Basis: Legitimate Interests or Consent, depending on the specific circumstances]

·         Enforce our agreements with you if necessary [Legal Basis: Legitimate Interests]

·         Provide information to regulatory bodies when legally required, and only as outlined in this Privacy Policy [Legal Basis: Compliance with a Legal Obligations]

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RogerThat as a ‘Joint Controller’ with Facebook

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We have a presence on Facebook (including Instagram). With respect to our use of Facebook, we are jointly responsible with Facebook Ireland for the processing activities (“Joint Processing”) with respect to your personal information:

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Facebook Ireland Ltd.,

4 Grand Canal Square, Grand Canal Harbor

Dublin 2, Ireland

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Information about the personal information that is collected from you by Facebook, as well as how and why it is processed by Facebook, can be found at https://www.facebook.com/about/privacy.

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RogerThat and Facebook have entered into entered into an agreement in order to determine the respective responsibilities for compliance with our obligations in connection with the Joint Processing within the meaning of the GDPR. This joint controller agreement, which sets out the reciprocal obligations, is available here.

RogerThat’s legal basis for processing your personal information via Facebook is our legitimate interest in promoting our Services.

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PLEASE NOTE THAT FACEBOOK IRELAND IS RESPONSIBLE FOR ENABLING DATA SUBJECTS’ RIGHTS UNDER ARTICLES 15-20 OF THE GDPR WITH REGARD TO THE PERSONAL DATA STORED BY FACEBOOK IRELAND IN CONNECTION WITH THE JOINT PROCESSING, AS FURTHER DESCRIBED IN FACEBOOK’S PRIVACY POLICY. TO EXERCISE YOUR RIGHTS, PLEASE GO TO YOUR FACEBOOK SETTINGS OR CONTACT FACEBOOK AS SET FORTH IN ITS PRIVACY POLICY.

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It cannot be excluded that some processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc.

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How Long Do We Keep Your Personal Information?

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We use the following criteria to determine our retention periods: the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal information, the length of time we have an ongoing relationship with you and provide you with access to our Services, and applicable legal requirements. We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax, or accounting requirements), when we are unable to reasonably verify your identity, or as may otherwise be required under GDPR. Additionally, we cannot delete information when it is needed for the establishment, exercise, or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.

When we have no ongoing business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible. If you have questions about, or need further information concerning, our data retention periods, please email roger@rogerthat.la.

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Staying in Control of Your Information: Your Rights

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IF YOU ARE AN END USER, YOU MUST CONTACT THE CUSTOMER(S) (ACTING AS ‘DATA CONTROLLER’) ON BEHALF OF WHICH RogerThat PROVIDES THE SERVICES AND COLLECTS PERSONAL INFORMATION, AS EXPLAINED HERE. IF WE RECEIVE REQUESTS FROM END USERS, WE WILL SEND THOSE REQUESTS TO THE RELEVANT CUSTOMER, WHO WILL BE RESPONSIBLE FOR RESPONDING TO AND ADDRESSING RIGHTS REQUESTS, WITH OUR COOPERATION.

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If the GDPR (or its equivalent in the United Kingdom) applies to you because you are in the EEA or the United Kingdom, you have certain rights in relation to your personal information:

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·         The right to be informed – our obligation to inform you that we process your personal information (and that is what we are doing in this Privacy Notice)

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·         The right of access – your right to request a copy of the personal information we hold about you (also known as a ‘data subject access request’)

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·         The right to rectification – your right to request that we correct personal information about you if it is incomplete or inaccurate (though we generally recommend first making any changes in your Account Settings)

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·         The right to erasure (also known as the ‘right to be forgotten’) – under certain circumstances, you may ask us to delete the personal information we have about you (unless there is an overriding legal reason we need to keep it)

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·         The right to restrict processing – your right, under certain circumstances, to ask us to suspend our processing of your personal information

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·         The right to data portability – your right to ask us for a copy of your personal information in a common format (for example, a .csv file)

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·         The right to object – your right to object to us processing your personal information (for example, if you object to us processing your data for direct marketing)

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·         Rights in relation to automated decision-making and profiling – our obligation to be transparent about any profiling we do, or any automated decision-making.

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These rights are subject to specific rules around when you can exercise them. If are located in the EEA and wish to exercise any of the rights set out above, please get in touch with us (see How to Contact Us about Privacy).

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You will not have to pay a fee to access your personal information (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under those circumstances.

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We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.  Note that if we are unable to reasonably confirm your identity, we will not be able to honor certain requests.

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We will respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law.

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In addition, if you no longer wish to receive our marketing/promotional information, we remind you that you may withdraw your consent to direct marketing at any time directly from the unsubscribe link included in each electronic marketing message we send to you. If you do so, we will promptly update our databases, and will take all reasonable steps to meet your request at the earliest possible opportunity, but we may continue to contact you to the extent necessary for the purposes of providing our Services.

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Finally, you have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us directly first.

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Last updated: Jan 20, 2023

 

Cookie Statement

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When you visit the Site or use the Services, we and our service providers acting on our behalf automatically collect certain data using tracking technologies like cookies, web beacons, and similar technologies:

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·         A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a website’s computers and stored on your computer’s hard drive.

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·         Other technologies (such as SDKs) incorporate third party computer code into our Services.

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·         Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon.

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These technologies are used to help us better understand Site visitors and End User behavior, and facilitate and measure the effectiveness of our Site, Customer Platforms and/or and Services. We use cookies and similar techologies for many different reasons as explained in the table below.

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All modern Internet browsers allow you to control your cookie settings. These settings are usually accessed in the ‘Options’ or ‘Preferences’ section of your browser. On your mobile device, go to Settings, then go to the specific web-browser, and then to the Cookies section. Please note that certain features of the website will not be available once cookies are disabled.  For further information about cookies and how to manage them, please visit www.allaboutcookies.org.

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Some cookies (i.e., essential) cannot be disabled, while others may but this may impact your use of the Site or Services.

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Here is a basic description and overview of the type of cookies RogerThat uses:

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Essential Cookies

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Essential cookies make it possible for you to access the Site and/or Customer Platforms, navigate within the Site and/or Customer Platforms, and access information related to your account.

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With respect to Customer Platforms, each time you log in, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow RogerThat to uniquely identify you when you are logged into the Customer Platforms and to process your requests.

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Essential cookies are necessary to operate the account portal, so you can’t opt out of them.

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Functionality Cookies

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Functionality cookies allow the Site and/or Customer Platforms to remember information you have entered or preferences you select, and provide enhanced, more personal features. These cookies allow you to optimize your use of the Services after logging in. These cookies can also be used to remember changes you have made to the portions of your account that you can customize.

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You can use your browser settings to opt out of functionality cookies. For more information on how to do that, click here. Note that opting out may affect the functionality of our Site or Services for you.

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Third party service providers that currently place functionality cookies within the Services or Site include:

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Performance Cookies

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These cookies collect data about how visitors use the Site or Services. This includes data like which pages visitors go to the most. These cookies don’t collect information that individually identifies visitors. The data these cookies collect is aggregated and intended to be anonymous and used to improve how the site functions and performs.

Third party service providers that currently place performance cookies within the Services or Site include:

Google Analytics: We use Google Analytics to help analyze page statistics and user behavior to the Site and Services. For information on how to opt-out of tracking technologies from Google Analytics, click here.

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Advertising Cookies

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RogerThat uses External Ad Partners, which use cookies and similar technologies to track and analyze usage and volume statistical information from those who visit the Site and serve targeted advertisements. RogerThat also uses cookies placed by its External Ad Partners to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Sites. NOTE THAT EXTERNAL AD PARTNERS MAY SHARE YOUR INFORMATION WITH A NUMBER OF OTHER THIRD PARTIES WITH WHOM RogerThat HAS NO DIRECT RELATIONSHIP.

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To learn more about how to opt out of targeting and advertising cookies, you can go to the Your Online Choices page, the Network Advertising Initiative page, and the Digital Advertising Alliance’s Consumer Choice page. Third parties, not RogerThat, provide these opt-out tools. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

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Third party service providers that currently place advertising cookies within the Site include:

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LinkedIn: We use LinkedIn Ads for marketing and advertising. Learn more about LinkedIn’s Privacy Policy here.

The above table lists the third-party service providers that RogerThat currently authorizes to place cookies or similar technologies.  This table is subject to change and may not necessarily include all third-party service providers that RogerThat uses at any given time.

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If you have any questions, contact us at roger@rogerthat.la.

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Last updated: Jan 20, 2023

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• From our website at www.RogerThat.com (“Site”);From the Customer Platforms (which may include a dedicated app) in connection with our Services; andWhen you otherwise communicate with us, such as through email or via social media platforms.