7. CHANGES TO OUR PRIVACY POLICY
Roitman Apps may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how Roitman Apps will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.
8. YOUR CALIFORNIA PRIVACY RIGHTS
This section applies to you if you are a resident of the state of California (a “consumer”). California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with an identifiable consumer or device.
Collection and use of personal information. We collect personal information from and about you for a variety of purposes explained in this Privacy Policy.
In the last 12 months, we have collected the following categories of personal information:
Identifiers, such as your name, address, phone number, email address, unique device identifiers or other similar identifiers;
California customer records, such as birth date and payment information;
Commercial information, such as records of services purchased, obtained or considered;
Internet/Network information, such as device information, logs and analytics data;
Geolocation data, such as precise location data from your mobile device (e.g., GPS coordinates) or generated based on your IP address;
Inferences about your interests and preferences, generated from your use of our services; and
Other personal information, such as driving event and movement data collected from your mobile device, or content or messages you send through the Service.
We collect this information directly from you, from our business partners, from your browser or device when you visit our websites, download or use our mobile app, and from third parties that you permit to share information with us.
Disclosure of Personal Information. We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see Your Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) other users with whom you elect to share such information; (ii) our service providers and advisors, (iii) third party businesses that provide features or services you may use in connection with our Service; (iv) marketing and strategic partners; (iv) ad networks and advertising partners; (v) analytics providers; and (vi) social networks. To learn more about how we disclose personal information to third parties, please refer to Section 2 of this Privacy Policy.
In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose: Identifiers, California customer records, Commercial information, Internet/Network information, Geolocation data, Inferences, and Other personal information.
In the previous 12 months, we have sold the following categories of personal information to third party data partners and advertising partners for targeted marketing, attribution, analytics and research purposes (subject to your settings and opt-outs): Identifiers, Internet/Network information, Geolocation, Inferences, and Other personal information, including driving event and movement data. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.
Your Rights and Choices. As a California resident, you may be able to request to exercise the following rights:
The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: (i) the specific pieces of personal information we have collected about you; (ii) the categories of personal information we have collected about you; (iii) the categories of sources of the personal information; (iv) the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; (v) the categories of personal information we have sold and the categories of third parties to whom the information was sold; and (vi) the business or commercial purposes for collecting or selling the personal information.
The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales to third parties now or in the future.
You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
To Submit your California Consumer Rights Requests. You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.
To exercise your Right to Know or your Right to Request Deletion, please submit a request through the CCPA Rights for CA Users page in your in-App Privacy Settings, by selecting “Request my Data” or “Delete my Data”. We will process your request and send an email confirmation once your request has been fulfilled.
To exercise your Right to Opt Out of Personal Information Sales, please adjust the “Do Not Sell My Personal Information” toggle available through the CCPA Rights for CA Users page in your in-App Privacy settings.
Alternately, you may submit a request to exercise your California Consumer Rights via email by contacting us at roitmanapps@gmail.com and including your account name and mobile telephone number as well as the consumer right you would like to exercise. However, we recommend users submit all requests through the in-App Privacy Settings for a faster response.
Additionally, as is common practice among companies that operate online, we have permitted third party advertising networks, social media companies and other third party businesses collect and disclose your personal information (including Internet / Network Information, Commercial Information, and Inferences) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use this information for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell that information to other businesses for advertising and other purposes. By visiting here www.privacyrights.info or www.optout.privacyrights.info, you can opt out from sales of this type of personal information by businesses that participate in the opt out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices. To learn more about how third parties collect information automatically on our Service and the choices you may have in relation to those activities, please see “Third-Party Tracking and Online Advertising section” of our Privacy Policy.
Minors. We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at privacy@Roitman Apps.com to inform us if you, or your minor child, are under the age of 16. If you are under the age of 18 and you want to remove your name or comments from our website or publicly-displayed content, please contact us directly at privacy@Roitman Apps.com. We may not be able to modify or delete your information in all circumstances.
California’s “Shine the Light” Law. California's "Shine the Light" law (Civil Code Section § 1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please adjust the “Do Not Sell My Personal Information” toggle available through the CCPA Rights for CA Users page in your in-App Privacy settings.
9. YOUR NEVADA PRIVACY RIGHTS
Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@Roitman Apps.com or visit www.Roitman Apps.com/opt-out.
10. HOW TO CONTACT US
If you have any questions about this Privacy Policy or the Service, please contact us at privacy@Roitman Apps.com
Roitman Apps
ATTN: Privacy
539 Bryant St. Suite 402
San Francisco, CA 94107
Part 2 – Privacy Policy for EEA and Swiss users
This Part 2 of our Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access our Service from the European Economic Area, Switzerland or the UK.
This Part 2 of the Privacy Policy was last modified on April 16, 2021.
Roitman Apps, Inc is the data controller of the personal information we hold about you.
1. PERSONAL INFORMATION WE COLLECT ABOUT YOU
1.1 We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, create or edit your user profile on the Service, update your preferences, check-in at a particular location, correspond with us by phone, SMS, e-mail or otherwise, or use some other feature of our Service.
1.2 We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.
1.3 The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.
1.4 We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.
1.5 The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
1.6 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
1.7 We may de-identify any of the personal information we collect (so that it does not directly identify you) and use it for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features.
1.8 We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.
2. RECIPIENTS OF PERSONAL INFORMATION
2.1 We may share your personal information with the following:
(a) Others in your Roitman Apps Family or other Roitman Apps Circle: we may share your personal information, including your name, location and driving event data, with other users of our Service at your request and in accordance with your settings and preferences.
(b) Third parties for their marketing and related purposes with your consent. Where you have provided consent for us to do so, we may sell your personal information (specifically, your location data, driving sensor data, information about your device, and unique identifiers or AdIDs) to third parties for their marketing and business purposes, including without limitation, to inform and improved tailored advertising, attribution, analytics or market research purposes.
(c) Service providers, business partners and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, bot detection, web hosting, or providing analytic services.
(d) Third parties that provide features you use in connection with the Services: With your consent or on your instruction, we share personal information, including contact information and location data, with third-party partners that provide certain features and services you elect to use through or in connection with our Service. For example, we may provide your personal information and location data to emergency responders in the event we detect a crash. We also share personal information with third party partners that provide services and features available through our Premium subscriptions, such as Emergency Dispatch services. Similarly, we may share personal information with third parties that you have connected to your Roitman Apps account to facilitate the features or services, such as Google if you have enabled the Roitman Apps Action on any Google Assistant-enabled device. Any information provided to these third parties will be governed by that third party’s own privacy policy.
(e) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
(f) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of Roitman Apps, its users or others.
2.2 Annex 1 and Annex 2 contain further information about some of the parties with which we may share your personal information.
3. YOUR LOCATION
3.1 We don't collect information about your location.
3.2 We will only share your device location with whoever you choose to.
3.3 You can turn off location sharing in one or more of your Circles with the trigger word that you defined
3.4 If you no longer want to continue using the Service, uninstalling the app or logging out from the Service will also stop your location sharing.
4. MARKETING MESSAGES AND NOTIFICATIONS
4.1 From time to time, we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.
4.2 We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details.
4.3 You can change your preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters.
4.4 Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service.
5. TARGETED ADVERTISING
5.1 We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices you may use. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, and information about your use of third party applications, and may combine this information with information they collect directly through tracking technologies or that they receive from other partners, both online and offline, so that they may recognise you across various devices you use, including computers, mobile devices and Smart TVs.
5.2 Where you have consented to us doing so, we may also share your precise geolocation data with advertising partners. We and our advertising partners use the information we collect about you to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
5.3 To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices.
5.4 You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
5.5 Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out from receiving interest-based ads on that specific device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each device you use.
5.6 To opt-out of Roitman Apps sharing data with third parties for advertising purposes. To adjust your data sharing preferences and to opt-out of Roitman Apps sharing personal information (including location and movement data) with data partners for their own targeted advertising, research, attribution and similar purposes, you can opt-out or adjust your preferences through the Data Platform page in the in-App Privacy settings. Please note, some third-party data partners may continue to send you personalized or location-based ads based on your previous location or data they have collected from other websites and mobile apps.
6. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
6.1 Security. We implement appropriate, commercially reasonable technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
6.2 International Transfers of your Personal Information. As we are located in the USA, any information we collect from you will initially be collected and stored in the USA. If you are in the EEA, Switzerland or the UK, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will implement appropriate safeguards to ensure that your personal information is treated securely and in accordance with applicable EEA and UK privacy law and this privacy policy, including: (i) ensuring that we use your personal information in accordance with standard data protection clauses adopted by the European Commission for transfers of personal data to recipients outside the EEA and UK; and (ii) ensuring that any recipients of your personal information commit to the same standards. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy notice.
6.3 Privacy Shield. We comply with the EU-U.S. Privacy Shield framework and Swiss-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union countries (including Lichtenstein, Norway and Iceland) and Switzerland transferred to the United States pursuant to the Privacy Shield ("Privacy Shield"). We have certified that we adhere to the Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, and recourse, enforcement and liability ("Principles") with respect to such data. If there is any conflict between the policies in this policy and the Principles, the Principles shall govern. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/. As of September 2020, the E.U.-U.S. Privacy Shield has been invalidated. Nonetheless, we have committed to adhere to these Principles with respect to the protection of personal data to ensure that your personal information is treated securely and in accordance with applicable laws.
6.4 Onward Transfer. Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with our Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage. In certain situations, we may be also required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
7. USERS' RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION
7.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
(a) Right of access. You have the right to obtain:
(i) confirmation of whether, and where, we are processing your personal information;
(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
(iii) information about the categories of recipients with whom we may share your personal information; and
(iv) a copy of the personal information we hold about you.
(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
(f) Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
7.2 If you wish to exercise one of these rights, please submit your request through the GDPR Rights for EU Users section of your in-App Privacy Settings and click on the option to “Request my Data,” “Delete my Data,” or “Reset Your Data Sharing Settings,” respectively.
7.3 You may also review and edit your contact and profile information by logging into your account on the app, and opt out of certain processing activities, such as the collection and sharing of your driving event data and movement data, by updating your in-App Privacy Settings. Please note that we may not be able to provide some functionalities of our Services to you if you opt-out of the collection and/or sharing of motion data or driving event data.
7.4 You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
8. CONSENT
8.1 We are not required to obtain your consent for most of the processing activities that we undertake in respect of your personal information.
8.2 We may, however, need your consent for certain processing activities. If we need your consent, we will notify you of the personal information we intend to use and how we intend to use it.
8.3 If you have provided consent for certain processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our processing of your personal information before your withdrawal.
8.4 Where we share your personal information with your consent with third parties for marketing and related purposes, you may withdraw consent at any time via our in-app Privacy Centre.
9. COOKIES AND SIMILAR TECHNOLOGIES
9.1 Our websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website or access any of our other websites and also allows us to improve our websites.
9.2 Please see our for more information about the cookies we use on our website, and how to manage cookies.
9.3 Deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.
10. JURISDICTION AND ENFORCEMENT
10.1 As part of our participation in the Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).
10.2 You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
11. CONTACT Roitman Apps AND RECOURSE
11.1 In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Privacy Shield. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at privacy@Roitman Apps.com.
11.2 In the event that you are concerned about how personal information you have provided to Roitman Apps has been used, please address your inquiry or complaint first to us at the address listed above. Roitman Apps takes all concerns about privacy and use of personal information very seriously, and shall endeavour to reply to you within 45 days of receiving a complaint.
11.3 We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism provided by JAMS. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information and to file a complaint. This service is provided free of charge to you.
11.4 If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshieldfiling.html for more information and to file a complaint.
12. LINKS TO THIRD PARTY SITES
Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
13. OUR POLICY TOWARDS CHILDREN
13.1 The Service may only be used by children with the consent of a parent or person with parental responsibility over the child.
13.2 The age at which children need parental consent varies between EEA Countries. Please refer to Annex 3 to verify the minimum age at which children no longer need consent to use our Service (the "Minimum Age").
13.3 If you would like to grant your child access to the Service, you must provide consent through one of our available consent mechanisms, for example, by verifying your government-issued identity document (not available in all jurisdictions) or returning the consent form available at https://www.Roitman Apps.com/pdf/consent.pdf by mail or email using the contact details at the end of this policy.
13.4 We will use the personal information of users under the relevant Minimum Age as set out in this privacy policy. We do not, however, use or share personal information collected from accounts of children under the Minimum Age for marketing or advertising purposes, nor permit our third party partners to collect and use such information for advertising purposes. We also do not contact, or permit third parties to contact any children under the Minimum Age who access or use our Service. However, other users with whom the child has added to his or her Circles will be able to contact the child.
13.5 If you become aware that your child has provided us with personal information without your consent, please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
13.6 If you would like to review or delete any personal information we have collected from the child, or to withdraw permission for us to collect any information from the child, please contact us at privacy@Roitman Apps.com.
14. CHANGES TO THIS POLICY
We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
15. NOTICE TO YOU
If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.
16. CONTACTING US
16.1 Please contact roitmanapps@gmail.com if you have any questions, comments and requests regarding this Privacy Policy.
