Codomo Pte Ltd (“Codomo”) takes your privacy very seriously. We ask that you read this privacy policy (the “Policy”) carefully as it contains important information about what to expect when Codomo collects personal information about you and how Codomo will use your personal data.

17/04/2022

This privacy policy describes what data we collect, how and why we use it and where you can find out more.

Your privacy is important, both for you and for us. We will do our very best to ensure that the data you let us process is handled in a secure, responsible, and integrous way.

Whose data do we collect?

What data we collect depends on how you interact with us and, based on the main ways to interact with us, “you” are most likely:

a “User”, who has signed up for an Account directly with Rolljak for a Paid Version or Free Version;
a “Participant”, who anonymously interacts with a Rolljak session
an “Organization Contact Person”, who is Rolljak’s point of contact at an organization;
a “Visitor” who visits any of our Websites, attends webinars, sends us emails, participates in contests, surveys or in any other way interacts with us or uses parts of our Services without having signed up with Rolljak

What data do we collect?

Depending on who you are, we collect:

Contacts – such as your name, email address, billing address.
Interaction Information – meaning information on how you use the Services and your system activities (dates, times, and details of log-on and log-off including information on your history with Rolljak; technical data such as page response times, download errors, personal preferences; your interactions with the customer service, etc.)
Device Information – e.g. IP address, user agent, browser settings, operating system and platform, and screen resolution. We may, for example, use an IP address received from your browser or device to determine the approximate location.
Additional Information - means other information, when and to the extent submitted to our Websites or if you, for example, participate in a user study, focus group, contest, request support, leave reviews, or otherwise communicate with Rolljak. Examples of such collected information could be your job title and phone number if you decide to provide us with that.

We may use third-party sites to store this information for billing, marketing and analytics purposes. See the Third-party interactions section for more information.

You (or your organization as our Customer) are liable for personal data included in information submitted by you to a Rolljak session in your use of the Application (e.g. the documents, text, and pictures submitted electronically), including also personal data provided by Participants in their interaction with your Rolljak session. Rolljak will only store such personal data to the extent provided and as a result of your use of the Application.

How do we process your data?

The typical situations when we process your data are listed below, divided depending on who you are.

Users

We may process:	with the purpose to:	and the legal basis being:
Contacts and Device Information	set up your Account with your identifying information	contractual obligations
Contacts and Device Information	communicate with you and/or provide you support through chat and email	contractual obligations
Contacts and Device Information	send you invoices	contractual obligations
Contacts, Device Information and Interaction Information	detect multi-use, fraudulent behavior and other acts in violation of the Terms	contractual obligations
Contacts and Device Information	provide appropriate security measures	contractual obligations
Contacts, Device Information, Additional Information and Interaction Information	conduct research and service improvements through, for example, A/B testing, data analytics and other types of testing / optimization exercises	legitimate interest
Third Party Information	conduct marketing and analytics activities	legitimate interest
Contacts	conduct sales and marketing - when you have signed up with an email address that belongs to an organization, we may disclose your email address to that organization as a part of our marketing & sales towards potential or existing Customers	legitimate interest - if you would like to avoid this type of disclosure you should register an Account with your own personal email address
Contacts	conduct direct marketing via email	your consent
Contacts	enable and provide collaboration features within the Services	contractual obligations
Additional Information	communicate with you	legitimate interest and your consent

Organization contact person

We may process:	with the purpose to:	and the legal basis being:
Contacts and Additional Information	communicate with you and provide support	legitimate interest and/or your consent
Contacts and Device Information	send you invoices	legitimate interest
Contacts	maintain a good record keeping in the day-to-day business activities	legitimate interest
Contacts	conduct direct marketing via email	with your consent
Cookie Information	conduct marketing activities and provide appropriate security measures, as examples, please read our full Cookie Policy for more information	legitimate interest and your consent

Participants

We may process:	with the purpose to:	and the legal basis being:
Device Information	enable for you to participate in Rolljak sessions and prevent abuse	contractual obligations

Visitors

We may process:	with the purpose to:	and the legal basis being:
Contacts and Additional Information	host webinars, surveys and focus groups (as examples)	your consent
Contacts and Device Information	send you invoices (if you have requested an invoice on behalf of another person)	legitimate interest
Contacts (email address)	with the purpose to communicate, for example to send company data such as company reports, press releases and other company news	legitimate interest
Contacts (email address), Device Information, Interaction Information and Cookie Information	conduct research and service improvements through, for example, A/B testing, data analytics and other types of testing / optimization exercises	legitimate interest

Payment related data

We use Stripe which is a level 1 PCI compliant third-party vendor to process credit card payments. We never store or process any payment-related data other than as described herein. We may collect some limited information, such as your email address and transaction history. In addition, when processing your payment Stripe provides us with limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, your type of card, expiry date, and last four digits as well as IP address and VAT number, where applicable. If you choose to pay by invoice, we may need to collect and transfer additional information, like your company name, registration number, and phone number, to Stripe to enable credit checks and send you invoices. Stripe is the controller and responsible for the personal data that they themselves collect. The use of your data by Stripe is subject to their own privacy policy.

Contests, webinars, surveys etc.

From time to time, we may offer you the chance to participate in webinars, contests and surveys which may be governed by the this Privacy Policy or, if explicitly stated, by a specific separate privacy policy with specific terms. We may ask you to be part of surveys, regarding for example customer satisfaction, and with your consent give us feedback in relation to for example support matters or when we test new stuff for improvement purposes and sometimes this may include processing of personal data of you as the respondent. If you choose to participate, we may ask you for certain personal data in addition to what is stated in this Privacy Policy.

Third-party integrations

We may also cooperate with third parties to, for example, host webinars, provide login functionality or provide a combination of our respective services via plug-ins, APIs or to enable integrations in third party services. In the event you choose to use such third-party functionality, services or integration, that third party may be an independent or joint controller together with us for the collection and processing of your personal data in connection therewith. We will process your personal data in accordance with this Privacy Policy and the relevant third parties terms and conditions and/or policies apply to their services and their processing of your personal data. We recommend that you get to know them before you use any functionality or services provided by a third party. They are responsible for the personal data they collect when providing you with their functionality or services.

Google reCAPTCHA

We use "Google reCAPTCHA" (hereinafter "reCAPTCHA") on our Websites which is a service provided by Google used to check whether the data entered on our Websites (such as contacts) has been entered by a human or by an automated program. To be able to do this, reCAPTCHA analyzes the behavior of the Website Visitor based on various characteristics and various information such as IP address, how long the Visitor has been on the Website or even mouse movements made. This analysis starts automatically as soon as you enter the Website. The reCAPTCHA analyses take place completely in the background, meaning that you who visit our Websites are not advised that such an analysis is taking place. The data collected during the analysis will be forwarded to Google. This data processing is mainly based on legitimate interest since we have a legitimate interest in protecting our site from abusive automated crawling and spam. For more information about Google reCAPTCHA and Google's privacy policy, please visit the following links: https://policies.google.com/privacy and https://www.google.com/recaptcha/about/

For how long is my data stored?

You can at any time delete your Rolljak session and results when you are logged into our Application. You may also always delete your entire Account on request by email to hello@rolljak.com. We will comply with your request promptly and at the latest within 30 days. If you are part of an organization, the Organization Contact Person may get in touch with us to deactivate your Account and if you wish to request the removal of your personal data.

How long we store personal data that we may receive in relation to the third party integrations depends on the type of data and the purpose for which we process it, but will only be retained for the period necessary to fulfill the purposes of the specific integration unless a longer retention period is required or permitted by law.

We store personal data as long as needed for the purpose described in this Privacy Policy but please note that we may store personal data for a longer period of time if needed to fulfill legal requirements.

Other situations when your data may be processed, shared or disclosed

Notifications. If you have subscribed to be notified of changes to our Terms and Policies we will use your email address to communicate with you.

Customer access. If you use an email address to access the Services and that email address was provided by an organization, such as an employer or school, that organization can request information about your Account as well as, if that organization is a Customer, request us to move your Account to that organization’s Team Workspace in which case you will become a Team Member. The organization may then apply its own policies to your use of the Services and control, administer, suspend and delete access to, as well as downgrade your Account. Please see the Terms for more information on what happens when you use an email address provided by an organization to access the Services. If you would like to be sure to avoid this type of disclosure you should register an Account with your own private email address.

During a change to Rolljak’s business. If Rolljak engages in, for example, a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Rolljak’s assets or stock, financing or similar transactions or proceedings, or steps in contemplation of such activities (e.g. due diligence), some or all your personal data may be shared or transferred, subject to standard confidentiality arrangements.

Aggregated or de-identified data. We may disclose or use aggregated or de-identified data for any type of business-related purpose such as with prospects, partners for business or research purposes.

To enforce our rights, prevent fraud, and for safety. We reserve the right to disclose all kinds of data to protect and defend the rights, property or safety of Rolljak or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

To comply with laws. If we receive a request for information, we may disclose all kinds of data, if this is required by mandatory applicable laws, governmental regulations or rules or by any order of court of competent jurisdiction, arbitral tribunal or governmental authority.

With consent. We may share personal data and other data with third parties when we have consent to do so.

Third-Party Service Providers

We engage third-party companies or individuals as service providers or business partners to process your Account to support our business. These third parties are our processors and may, for example, provide and help us with computing and storage services. From time to time, we may remove or engage new processors and when we do Rolljak will ensure via a written contract that the processor may access and use your data only to deliver the services Rolljak has retained them to provide and is prohibited from using such data for any other purpose. Rolljak will ensure that processors are bound by written agreements that require them to provide at least the level of data protection required of Rolljak.

Your rights

We will get back to you promptly and at the latest within 30 days after receipt of your request, but please note that Rolljak may be required by law to keep some personal data despite your request.

In cases where we process your personal data based on your consent or explicit consent, you can at any time revoke this consent, which you do by unsubscribing to emails we send you or by contacting us at hello@rolljak.com (please see our Cookie Policy if you want to revoke consent to cookies). Revoking consent for the purpose of direct marketing via email will not lead to any detriment for you, as we do not require this type of information to provide our Services, but if you revoke your consent in relation to other matters, exercise your right to erasure or restrict our processing of your personal data in any other way, our Services can no longer be provided.

Age Restrictions

The Services are addressed to organizations and individuals being sixteen years of age or older. By registering an Account, you warrant and represent that you have that legal age as further described in the Terms.

Furthermore, our Services are not directed to children under the age of 13 years or to children whose age makes it unlawful to process their personal data or requires parental consent under applicable laws. Accordingly, we do not intend to collect personal data from anyone we know to be under this age limit. If we learn that we have collected personal data of a child under the age of 13 years we will take reasonable steps to delete such personal data as quickly as possible. If you are the parent or legal guardian of a child under the aforementioned age limit and become aware that the child has provided personal data to us, please contact us by emailing hello@rolljak.com.

Contact

Rolljak is fully owned and operated by Codomo Pte Ltd, a Singaporean limited liability company with Unique Entity Number 201535740K and registered address 426A Joo Chiat Road, Singapore 427644. You can always reach us at hello@rolljak.com.

Changes To This Privacy Policy

This Privacy Policy is not part of the Terms and we may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice through the Services or via email if you have subscribed for email notifications. If you disagree with the changes to this Privacy Policy, you should delete your Account.

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