Effective Date:\u00a08\/17\/2023<\/strong><\/p>\n ROTO Technology, LLC., and its affiliates, parents, and subsidiaries (“ROTO” or “we”, “us”, or the “Company”) take your privacy seriously. This Privacy Policy explains how we collect, use, share, and protect your Personal Information. If you do not want us to handle your Personal Information in this manner, please do not use the ROTO Platform. Personal Information is information that relates to you as an individually identifiable person, such as your name, e-mail address, and mobile number.<\/p>\n This Privacy Policy explains:<\/strong><\/p>\n This Privacy Policy applies only to (a) information that we collect on the websites Go-roto.com, go-roto.com\/wp-admin, WordPress.com and Cyberpanel.com (collectively, the\u00a0“Site”<\/strong>) and (b) through the ROTO mobile applications, including the mobile application for service requesters\/customers and the mobile application for service professional\/partners (the\u00a0“App”<\/strong>) (collectively the\u00a0“ROTO Platform”<\/strong>).<\/p>\n We collect information that you voluntarily share with us through the ROTO Platform.<\/p>\n If you are using the ROTO Platform to request service professional services, or contact ROTO or its third-party service providers, you may give us:<\/p>\n If you and\/or your company (with you as Owner or sole proprietor) participate on the ROTO Platform as a service professional you will be operating as an Independent Contractor<\/strong> and you may give us:<\/p>\n If you register your business on the ROTO Platform to accept request as an Independent Contractor<\/strong> with ROTO, you may give us:<\/p>\n More about payment card information:<\/u><\/p>\n Although users can submit credit card or other payment card information to pay for a service through the ROTO Platform, ROTO does not receive this information itself. Payment card information is transmitted directly to a third-party payment card processor, Stripe, through an Internet connection secured by industry-standard Transport Layer Security (TLS) encryption technology. Stripe then communicates to ROTO whether your payment has cleared, but does not provide payment card information to ROTO.<\/p>\n Surveys<\/strong><\/p>\n You may, at your choice, complete surveys on the ROTO Platform or distributed by ROTO about, for example, your level of satisfaction with the ROTO Platform, your engagement with the ROTO Platform, and your awareness of ROTO Platform features. In some cases, we may link the information you provide in the survey with Personal Information in your ROTO account, such as your name or email address. When linked to Personal Information, your survey information becomes Personal Information too.<\/p>\n We collect information through technology to enhance our ability to serve you. When you access and use the ROTO Platform, or contact ROTO or its third-party service providers, ROTO and, in some cases, our third-party service providers collect information about you or how you interact with the ROTO Platform. We describe below a few of the methods we use to collect information through technology.<\/p>\n When you visit the ROTO Platform, we collect your Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the Internet, like your Internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. However, we may link the last IP address you used to access the ROTO Platform to Personal Information you provide us. Where, according to local law, IP addresses and the like are considered Personal Information, we treat them as such.<\/p>\n We may also collect a unique identifier for your computer, mobile device, or other device used to access the ROTO Platform (“Device Identifier”<\/strong>). A Device Identifier is a number that is automatically assigned to the device you used to access the ROTO Platform. We may link the Device Identifier to other information about your visit, such as what pages you viewed, and to Personal Information you provide us, such as your name. In addition to these methods, we may also collect information about how you interact with the ROTO Platform through advertising partners and data enrichment tools.<\/p>\n Do We Use Cookies?<\/strong><\/p>\n Yes. For more information about cookies, please visit our Cookies Policy.<\/p>\n Web Beacons<\/strong><\/p>\n We may include small graphic images or other web programming code, called web beacons (also known as “pixel tags”, “web bugs” or “clear GIFs”), in our web and mobile pages and messages. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons help us better manage content on the ROTO Platform by informing us what content is effective, monitoring how users navigate the ROTO Platform, counting users of the ROTO Platform, and counting how many e-mails sent by us were actually opened.<\/p>\n Your ‘Do Not Track’ Browser Setting<\/strong><\/p>\n We do not support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser’s settings to let the websites you visit know that you do not want the websites collecting your Personal Information.<\/p>\n We do track your online activities over time and across third-party websites or online services. For example, we use web beacons to help us determine what links or advertisers brought you to our Site. We also use third-party service providers to display advertisements to you on other websites based on your activities while on the ROTO Platform.<\/p>\n When you use the App, the App may automatically collect and store some or all of the following information from your mobile device (“Mobile Device Information”<\/strong>), Including, but not limited to:<\/p>\n We may also collect information about how you use the App, such as the amount of time you spend using the App, how many times you use a specific feature of the App over a given time period, how often you use the App, and actions you take in the App. In addition, we may gather information about the website from which you downloaded the App to help us determine what App download site is most effective (collectively\u00a0“App Usage Information”<\/strong>).<\/p>\n We may link your Mobile Device Information and App Usage Information to Personal Information you have provided us, in which case we will treat the combined information as Personal Information.<\/p>\n Location Tracking<\/strong><\/p>\n If you are a service professional using ROTO’s mobile application for service professional\/partners (the\u00a0\u201cROTO Partner\u201d)<\/strong>, we may collect your geographic location by using Global Positioning System (GPS) information sent to us from the ROTO Partner App. For more information on when this information is collected, how we use it, and with whom it is shared, services professional\/partners should refer to the Service professional Agreement available on the service professional portal.<\/p>\n We only collect location information about service professional\/partners who have been accepted to participate on the ROTO Platform and not about service requesters\/customers or about service professional\/partners applying to participate in the ROTO Platform.<\/p>\n If you choose to use our referral service to tell a friend about the ROTO Platform, we may collect your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the ROTO Platform. We store this information only to send this one-time email and to track the success of our referral program. We do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you refer a friend, your e-mail address may be included in the message sent to your friend.<\/p>\n If you are using the ROTO Platform to request service professional services, you may provide us ratings and reviews of the service professional\/partners you engage through the ROTO Platform. These ratings and reviews maybe shared with a 3rd<\/sup> party review platform (i.e., Google Business Pages).<\/p>\n Conversion Tracking<\/strong>: We may supplement the information we collect about you through the ROTO Platform with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you. For example, websites on which we have placed advertisements, such as Google, may tell us which ads about ROTO you clicked. This is often called “conversion tracking.”<\/p>\n Background Checks<\/strong>: In addition, when third parties such as Better Business Bureau (BBB), Federal Trade Commission (FTC), Security Exchange Commission (SEC), Hirease, Onfido or Checkr.com conduct background checks on service professional\/partners, those third parties share the results of the background check with ROTO.<\/p>\n Recording Phone Calls<\/strong>: Selected third-parties, including those who may assist in providing customer service support, may monitor and\/or record the contents of phone calls made through or in relation to the ROTO Platform, after notice to you and with your consent.<\/p>\n Social Networking Sites<\/strong>: If you login to the ROTO Platform through a social networking site, such as Facebook, we may collect your Facebook authentication token and account identification number and use that information to provide you with access to your account on the ROTO Platform.<\/p>\n Ratings and Reviews<\/strong>: If you are using the ROTO Platform as a service professional\/partner, we may receive information about you in the form of ratings and reviews from requesters\/customers who engaged your service professional services through the ROTO Platform.<\/p>\n These ratings maybe shared with additional third-party platforms (is Google Business Page) and the ratings will only list a first name and no personal or identifying information about ROTO Customers.<\/p>\n Photographs of before and after Services<\/strong>: If you are using the ROTO Platform to request services, service professional\/partners booked through the ROTO Platform may take photographs before service begins and after service is completed and provide them to ROTO.<\/p>\n Message Interception<\/strong>: If you call or text (SMS) message a service professional or service requester using the telephone number provided by ROTO, ROTO uses Twilio to mask your telephone number. During this process, ROTO and Twilio (Twilio.com) receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties\u2019 phone numbers, and the content of the text (SMS) messages.<\/p>\n If you send a message to a service professional or service requester in the App, ROTO uses Twilio to process the communications. During this process, ROTO and Twilio receive in real time and store message data, Including the date, time, and content of the messages.<\/p>\n If you are using the ROTO Platform as a service professional\/partner, we may receive information about you in the form of ratings and reviews from Requesters\/customers\/customers who engaged your service professional services through the ROTO Platform.<\/p>\n We will apply this Privacy Policy to any Personal Information received from third parties, unless we have disclosed otherwise.<\/p>\n The ROTO Platform includes links from the ROTO Platform to sites or applications operated by third parties (“Third-Party Sites”<\/strong>) and plug-ins (such as Facebook, Meta or Twitter buttons) from Third-Party Sites.<\/p>\n For example, service professional\/partners may be directed to a Third-Party Site, so that the Third-Party Site can conduct a background check. The Third-Party Site may ask the service professional for identifying information to conduct the background check.<\/p>\n ROTO does not control any Third-Party Sites, and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by that site’s privacy policy.<\/p>\n We recommend that you read the Third-Party Site’s privacy policy if you choose to enter any Third-Party Site or click on a plug-in.<\/p>\n <\/p>\n <\/p>\n We \u2013Including without limitation our affiliates, parents, and subsidiaries \u2013 use the information we collect to serve our customers, consider applicants, market and promote our services, perform research and development for new products and services, conduct quality assurance for our services, prevent fraud on the ROTO Platform, ensure and improve security on the ROTO Platform, and improve your experience at the ROTO Platform. Some examples include:<\/p>\n By using the ROTO platform, you expressly consent and agree to accept and receive communications from us, including via text message, calls, and push notifications to the cellular telephone number you provided to us. Standard text messaging charges applied by your cell phone carrier will apply to text messages we send. By consenting to being contacted by ROTO, you understand and agree that you may receive communications, including marketing communications generated by automatic telephone dialing systems and\/or which will deliver prerecorded messages, sent by or on behalf of ROTO, its affiliated companies and\/or Users\/Professionals\/partners, including but not limited to: operational communications concerning your account or use of the ROTO Platform or Services, updates concerning new and existing features on the ROTO Platform, communications concerning promotions run by us, and news concerning ROTO and industry developments. You acknowledge that you are not required to consent to receive promotional messages as a condition of using the ROTO Platform or the Services. If a contact number you have provided to us is no longer your number, you agree to notify us promptly that you can no longer be reached at that number. You represent that you have received, and are authorized to convey to us, the consent of any authorized users on your account to be contacted by us as described in this Section. You agree that all consents provided in this Section will survive cancellation of your account. You may opt-out of receiving promotional or marketing texts or calls from ROTO at any time. You may opt-out of receiving all text (SMS) messages from ROTO (including informational or transactional messages) by replying with the word \u201cSTOP\u201d to a text message from us; however, you acknowledge that opting out of receiving all texts may impact your use of the ROTO Platform or the Services. You also acknowledge that ROTO or its third-party service providers may record customer service calls after notice to you and with your consent, in order to assist you when you contact our customer support services.<\/p>\n You agree to ROTO\u2019s use of a service provider to mask your telephone number when you call or exchange text (SMS) messages with a Service Professor or Service Requestor using a telephone number provided by ROTO. During this process, ROTO and its service provider will receive in real time and store call data, including the date and time of the call or text (SMS) message, the parties\u2019 phone numbers, and the content of the text (SMS) messages. You agree to the masking process described above and to ROTO\u2019s use and disclosure of this call data for its legitimate business purposes.<\/p>\n The information described in this section may be transferred to, or processed and stored in, the United States and other countries, which may employ greater or less restrictive data protection laws. In all cases, we will take appropriate measures to protect your personal information in accordance with the policies described herein.<\/p>\n Data Retention<\/strong><\/p>\n We delete the back-ups of the databases containing your Personal Information after 13 months.<\/p>\n III. HOW WE SHARE THE INFORMATION WE COLLECT<\/strong><\/p>\n We may sell, rent, or trade your Personal Information to third parties as disclosed in this Privacy Policy at the time you provide your information. The following are the ways and purposes for which we share your information:<\/p>\n We may share your Personal Information among our various affiliates, parents, and subsidiaries, including without limitation ROTO Technology LLC, for the purposes of facilitating aspects of services offered through the ROTO Platform or our affiliates’ platforms and for marketing purposes.<\/p>\n The ROTO Platform may display profiles of the service professional\/partners who participate on the ROTO Platform. These profiles may include the service professional\/partner\u2019s name, Business Name, Year Make and Model of their Car, License plate number and ratings and reviews about the service professional provided by their customers. The service professional\/partner\u2019s profile may be visible to the requestor\/customer once the Service professional has accepted the request\/job and will remain visible to the customer after the service in completed. Once the review has been completed the request will be under history and the Service Professionals Name and image will be there, but the remaining business and vehicle information may not be listed.<\/p>\n If you provide a rating or review about a service professional\/partner, we may post your first name, the initial of your last name, and the name of your neighborhood along with your rating or review on the service professional\/partner\u2019s profile on the ROTO Platform, on Booking Partners\u2019 websites and your review may be shown on third party review sites such as Google business pages. In addition, service professional\/partners may use your ratings and reviews, as well as this personal information about you, in their own marketing materials (partners will not disclose any confidential or personal information.<\/p>\n If you provide information about your home to request a booking or a quote for a service, we may post your first name, the type of service requested, your zip code or region, the number of service providers requested, the month and year of your booking or quote request and any description of the requested service or service instructions or notes that you provide on the ROTO Platform.<\/p>\n Third party companies and individuals provide or facilitate certain aspects of the Roadside Assistance services offered through the ROTO Platform on our behalf. We may provide these third-party service providers with access to your information, including your Personal Information, so that they can perform these services for us. We require these third-party service providers to provide safeguards for your Personal Information similar to the ones that we provide.<\/p>\n The following are some examples of how we share your information with third-party service providers.<\/p>\n We may disclose your Personal Information to banks and credit card companies in the process of investigating payment fraud and\/or responding to disputed charges.<\/p>\n By using the ROTO Platform, you may be contacted, either by ROTO or directly by selected third parties, with opportunities to receive information on available services or marketing offers. If you agree to share your Personal Information to receive this information or marketing offers, your Personal Information may be disclosed to such third parties. All the information you disclose to the third parties will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to sharing your Personal Information with them. If you later decide that you no longer want to receive communication from such a third party, you will need to contact that third party directly.<\/p>\n We may share your Personal Information and\/or aggregate data derived from your Personal Information with Booking Partners. For example, Roadside Assistance Providers, Mobile mechanic business, Auto Repair Shops and additional independent contractors, customers can book services through the ROTO Platform from the ROTO Customer App. Upon request, we may provide our Booking Partners with information about the services you booked or provided through the ROTO Platform, as applicable, as well as your Personal Information.<\/p>\n If you are an Independent Contractor, Sole Proprietor, Partnership, Corporation, S Corp, Limited Liability. Company (LLC), contractor or other affiliate of any company participating on the ROTO Platform as a service professional or accessing the ROTO Platform in partnership with a Partner, we may share your Personal or Company Information with the customer and\/or service requestor.<\/p>\n We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the ROTO Platform that may require providing Personal Information to register. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and\/or likeness in advertising or marketing associated with the Promotion. Please read the official rules carefully. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners’ list.<\/p>\n If you choose to log-in to the ROTO Platform through Facebook, Twitter, or another social networking site, we may share information about your account with the social networking site.<\/p>\n Required Disclosures:<\/strong><\/p>\n We may be required to disclose Personal Information in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.<\/p>\n Legal Compliance and Protections:<\/strong><\/p>\n We may disclose account and other Personal Information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of ROTO Technology LLC, our users, or others. This includes exchanging Personal Information with other companies and organizations for fraud prevention and credit risk reduction.<\/p>\n We reserve the right to disclose and transfer your information, including your Personal Information:<\/p>\n CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE<\/strong><\/p>\n We do not collect any information from anyone under 17 years of age. The ROTO Platform, and products and services offered through it, are all directed to people who are at least 17 years old or older. If you are under the age of 17, you are not authorized to use the ROTO Platform.<\/p>\n The security and confidentiality of your Personal Information is important to us. We have implemented technical, administrative, and physical security measures to protect your Personal Information from unauthorized access or disclosure and improper use.<\/p>\n For example, when users book services, the information they input is encrypted through TLS encryption. We do not store credit card information on our servers, and we use TLS encryption to protect your credit card information when it is transferred to our third-party payment processor. In addition, access to your Personal Information is restricted in our offices. Only employees who need the Personal Information to perform a specific job, for example, sales representatives, managers, and customer service staff, are granted access to Personal Information. All employees with access to Personal Information are kept up-to-date on our security and privacy practices. After a new policy is added, these employees are notified and\/or reminded about the importance we place on privacy, and what they can do to enhance protection for our users’ Personal Information.<\/p>\n It is important for you to protect against unauthorized access to your account password and to your computer. Be sure to log out of your account or to close your browser after you have completed your visit to our Site.<\/p>\n Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your Personal Information.<\/p>\n You may contact support@go-roto.com<\/a> to update, correct, or delete your Personal Information. You may also update, correct, and delete some of your Personal Information through your account on the ROTO Platform.<\/p>\n In addition, you may cancel or modify the email communications you have chosen to receive from the ROTO Platform by following the instructions contained in emails from us.<\/p>\n This California Consumer Act Privacy Notice (\u201cCCPA Notice<\/strong>\u201d) applies to \u201cConsumers\u201d as defined by the California Consumer Privacy Act (\u201cCCPA<\/strong>\u201d). For the purpose of this CCPA Notice, personal information applies to \u201cPersonal Information\u201d as defined by the CCPA (also referred to herein as \u201cCA PI<\/strong>\u201d).<\/p>\n We collect and share the categories of CA PI set forth in the foregoing Sections I and III of this Privacy Policy from the sources set forth in Section I and for the purposes set forth in Sections II and III.<\/p>\n In addition, we may collect, use and disclose your CA PI as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.<\/p>\n We do not \u201csell\u201d personal information that we collect from you, in accordance with the definition of \u201csell\u201d in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a \u201csale\u201d of your CA PI as defined by the CCPA. You can exercise control over browser-based cookies by adjusting the settings on your browser. Further, you can learn more about your choices regarding certain kinds of online interest-based advertising in our Cookies Policy. We do not represent that these third-party tools, programs or statements are complete or accurate.<\/p>\n Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.<\/p>\n California Consumers have the right to exercise the privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (\u201cVerifiable Consumer Request<\/strong>\u201d). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected CA PI. Please follow the instructions below and respond to any follow up inquiries we may make.<\/p>\n Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer\u2019s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.<\/p>\n We will make commercially reasonable efforts to identify Consumer CA PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.<\/p>\n To make a request according to your right to request deletion of your CA PI set forth below, you may send a request by email (including the email address that you have used to transact with ROTO) to\u00a0support@go-roto.com<\/a>.<\/p>\n You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date, by sending a request by email (including the email address that you have used to transact with ROTO) to\u00a0support@go-roto.com.<\/p>\n You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your CA PI that we have collected in the period that is 12 months prior to the request date and are maintaining, by sending a request by email (including the email address that you have used to transact with ROTO) to\u00a0support@go-roto.com<\/a>.<\/p>\n Please note that CA PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.<\/p>\n Except to the extent, we have a basis for retention under CCPA, you may request that we delete your CA PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.<\/p>\n You may alternatively exercise more limited control of your PI by instead exercising one of the following more limited opt-outs: opting out of marketing emails by clicking the \u2018unsubscribe\u2019 link or sending an email to\u00a0support@go-roto.com<\/a>.<\/p>\n We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your CA PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and\/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.<\/p>\n Under Nevada law, Nevada residents may opt out of the sale of certain \u201ccovered information\u201d collected by operators of websites or online services. We currently do not sell covered information, as \u201csale\u201d is defined by such law, and we don\u2019t currently have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please email\u00a0support@go-roto.com<\/a> to provide your name and email address. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our plans change. At that time, we will create a process for verifying your identity and providing an opportunity to verified consumers to complete their opt-out. Please become familiar with our data practices as set forth in this privacy policy. We may share your Personal Information as explained in this privacy policy, such as to enhance your experiences and our services, and those activities will be unaffected by a Nevada do not sell request. You may also have other choices regarding our data practices as set forth elsewhere in this privacy policy.<\/p>\n If you have any questions about this Privacy Policy, we’ll do our best to answer them promptly. Here’s how to contact us:<\/p>\n Email: Mailing Address: VII. OUR PRIVACY SHIELD PRIVACY POLICY AND INFORMATION SPECIFIC TO NON-U.S. USERS<\/strong><\/p>\n The Personal Information collected through the Site is downloaded to a server maintained by ROTO in the United States. ROTO will comply with requests to exercise individual data rights in accordance with applicable law. You can contact support@go-roto.com<\/a>\u00a0to request to exercise your data rights.<\/p>\n To provide an adequate level of protection for Personal Information received from the Member States of the European Economic Area (“EEA”) and from Switzerland, ROTO Technology, LLC., (“ROTO US”) complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce (\u201cPrivacy Shield Principles\u201d) when processing the Personal Information of natural persons located in the EEA and Switzerland (collectively, “EEA Individuals”) whose data is transferred into the US pursuant to the Privacy Shield. EEA Individuals include users of the ROTO Platform, such as service requesters\/customers and service professional\/partners. EEA Individuals also include employees of ROTO US\u2019 affiliated companies located in the Member States. Please note that service professional\/partners who provide services through the ROTO Platform are independent contractors and are not employees of ROTO US or employees of any of ROTO US\u2019 affiliated companies, including those located in the Member States.<\/p>\n ROTO US has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https:\/\/www.privacyshield.gov\/<\/p>\n Before processing the Personal Information of any EEA Individual, ROTO US, or its local affiliate, provides the EEA Individual with a notice concerning the processing of his or her Personal Information. The notice, including this Privacy Policy, are available for review on the ROTO Platform and\/or provided directly to the EEA Individual.<\/p>\n ROTO US receives the Personal Information of ROTO Platform users and processes it for the purposes described in this Privacy Policy. ROTO US may disclose this Personal Information to third parties as described in the Privacy Policy.<\/p>\n ROTO US receives the Personal Information of applicants for employee positions located in the Member States and Switzerland (“Applicants\u201d) to<\/strong> administer the recruitment process and, of employees, to administer the employment relationship. Examples of the purposes for which ROTO US collects and uses employee and Applicant Personal Information include, without limitation, recruitment; workforce management; to administer compensation, payroll, and benefits; to address various legal obligations related to the employment relationship, including discovery obligations in civil litigation; to administer training; to administer ROTO US\u2019 compliance process; and for emergency contact purposes.<\/p>\n The employee and Applicant Personal Information that ROTO US receives from the EEA and Switzerland consists largely of information provided by Applicants, such as resumes and completed job applications and information created by ROTO US or its affiliates to administer the employment relationship, such as business contact information, and compensation and benefits information.<\/p>\n ROTO US may disclose employee and Applicant Personal Information, subject to written agreement, to authorized service providers who provide services related to the administration of the recruitment process and\/or the employment relationship. ROTO US also may disclose employee and Applicant Personal.<\/p>\n Information to corporate affiliates in connection with the recruitment process and for internal employment administration purposes, such as to administer access to physical facilities and information systems and for succession planning.<\/p>\n ROTO US may be required to disclose, and may disclose, EEA and Swiss Personal Information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.<\/p>\n The Personal Information collected through the Site will be transferred to the United States. The recipients of Personal Information collected through the Site (listed in Section III above) are located in the United States and the Philippines or in the country where the data was collected and the data that is transferred will be subject to Privacy Shield.<\/p>\n Consent and as Required by Law: ROTO processes your Personal Information with your consent and as required by law.<\/p>\n Contract: Users can enter into two different types of contracts through the ROTO Platform: (1) a contract between service requesters\/customers and service professional\/partners regarding service professional services, and (2) a contract between the user and ROTO whereby ROTO facilitates the arrangement of the service professional services contract in exchange for a share of the fee for the contracted service professional services. To take steps necessary to respond to users\u2019 requests to enter into both types of contracts, ROTO processes Personal Information from service requesters\/customers, including contact information, services requested, and Vehicle location information, Service requested and from service professional\/partners, including contact information, skills and experience, background check information, preferred times, and preferred locations. To facilitate the performance of the service professional agreement and to perform the contract with users, ROTO must process Personal Information, including the service requester\u2019s billing information, the service professional\/partner\u2019s receivables information and geographic location information, and both parties\u2019 text messages and phone calls through the ROTO Platform.<\/p>\n ROTO cannot facilitate service professional contracts through the ROTO Platform or enter into contracts with users unless users provide this Personal Information.<\/p>\n Legitimate Interests: ROTO also processes Personal Information as necessary for its legitimate interests as follows:<\/p>\n Right to Object to Processing for Direct Marketing or Legitimate Interests:<\/p>\n EEA Individuals have the right to object to the processing of their Personal Information for purposes of ROTO\u2019s direct marketing or legitimate interests by contacting ROTO at support@go-roto.com<\/a>.<\/p>\n Automated decision-making:<\/p>\n ROTO sometimes uses EEA Individuals\u2019 Personal Information submitted through the Site for automated decision-making. For example, ROTO may display advertisements and send emails to you containing content automatically chosen based on the services you have ordered through the ROTO Platform in the past. However, ROTO will not use EEA Individuals\u2019 Personal Information submitted through the Site for automated decision-making, including profiling, which produces legal effects or similarly significantly affects the EEA Individual.<\/p>\n Individual Rights:<\/p>\n EEA Individuals have the right to access their Personal Information collected by the Site and to request that ROTO update, correct, or delete their Personal Information as provided by applicable law. EEA Individuals also have the right to object to, or restrict, ROTO\u2019s processing of their Personal Information.<\/p>\n In addition, EEA Individuals have the right to data portability concerning their Personal Information. Subject to certain limitations, the right to data portability allows EEA Individuals to obtain from ROTO, or to ask ROTO to send to a third party, a digital copy of the Personal Information that they provided to the Site. EEA Individuals\u2019 right to access their Personal Information includes their right to receive a copy of all, or a portion, of their Personal Information in ROTO\u2019s possession as long as ROTO\u2019s providing the Personal Information would not adversely affect the rights and freedoms of others.<\/p>\n ROTO US may disclose EEA Individuals\u2019 Personal Information transferred to the United States pursuant to the Privacy Shield to non-agent third parties as described in Section III above. In some cases, as described in Section III of this Privacy Policy, our third-party service providers may in turn share the Personal Information of ROTO Platform users with other third parties. You may opt out of such disclosures and onward transfers by writing to support@go-roto.com<\/a>.<\/u><\/p>\n ROTO US will offer EEA Individuals whose Personal Information has been transferred to the United States pursuant to the Privacy Shield the opportunity to opt out from: (a) the disclosure of their Personal Information to any non-agent third parties not already listed in Section III above and (b) the use of their Personal Information for purpose(s) that are not compatible with the purpose(s) for which the Personal Information was originally collected or subsequently authorized by the Individual. ROTO US will provide EEA Individuals with clear, conspicuous, and readily available mechanisms to exercise choice. should such circumstances arise. Any withdrawal will apply only prospectively, and ROTO will continue to retain the Personal Information that EEA Individuals provided before they withdrew their consent for as long as allowed or required by applicable law.<\/p>\n ROTO US acknowledges EEA Individuals\u2019 right to access and correct their Personal Information. Upon reasonable request, ROTO US will grant EEA Individuals reasonable access to their Personal Information and will permit them to correct, amend or delete Personal Information that is inaccurate or incomplete. EEA Individuals wishing to exercise these rights may do so by contacting support@go-roto.com Employees should contact their local manager to exercise these rights.<\/p>\n In compliance with the Privacy Shield Principles, ROTO US commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact ROTO US at support@go-roto.com<\/a>.<\/p>\n ROTO US has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org\/EU-privacy-shield\/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.<\/p>\n ROTO US commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the EU DPA\u2019s and Swiss FDPIC with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.<\/p>\n If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https:\/\/www.privacyshield.gov\/article?id=ANNEX-I-introduction<\/p>\n Contact details for the EU data protection authorities can be found at http:\/\/ec.europa.eu\/justice\/data-protection\/bodies\/authorities\/index_en.htm. Contact details for the Swiss Federal Data Protection and Information Commissioner can be found at https:\/\/www.edoeb.admin.ch\/edoeb\/en\/home\/the-fdpic\/links\/data-protection—switzerland.html<\/p>\n\n
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\nSupport@go-roto.com<\/a><\/p>\n
\nROTO Technology, LLC.
\nPO Box 9488
\nWilmington, 19809<\/p>\n\n
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