ROSE FINANCIAL PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) outlines how Rose Financial Solutions (“RFS”, “we”, “our” or “us”), collects Personal Information (defined below) from users of our website: www.rosefinancial.com (the “Site”), and from various social media platforms, collectively our “online presence”, and how that information is used and disclosed.

 

1. INTRODUCTION.

We strive to respect privacy and we recognize the need for appropriate protection and management of any Personal Information that is shared with us via our Site. As used in this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable person.

 

Our Site, www.rosefinancial.com, provides a pop-up message to all visitors requesting that they click a link to indicate their consent to our Privacy Policy or exit the Site. The link provided by the pop-up records information about the visitor who provided their consent, including IP address, a timestamp of when the consent was granted, and a copy of the then-current privacy policy that was consented to.

 

Throughout the Site you may choose whether or not to provide or disclose Personal Information in connection with your use of or interaction with our Site. If you choose not to provide the Personal Information we request, you may still visit and use parts of our Site, but may be unable to access or use certain features, options, and services. Our Site may contain links to third-party websites, products, services, and advertisements that are not owned or controlled by RFS. We are not responsible for the privacy practices or the content of those third-party websites, products, services, and advertisements, and you visit them at your own risk.

 

2. PERSONAL INFORMATION WE MAY COLLECT.

We and our third-party service providers may collect the below categories of Personal Information when you use our Site. We do not collect Social Security Numbers on our Site.

 

Name;

Address;

Email address;

Username;

Password;

Phone number;

Communications you send to us;

IP address and geo-locational data;

Hardware and software information received from your internet-enabled device

 

3. WHEN PERSONAL INFORMATION IS COLLECTED.

Our Site may invite you to submit Personal Information in the following ways:

 

(a) Contact Information.

When you interact with our Site, you may be presented with opportunities to provide Personal Information that allows us to keep in contact with you. For example, when you create or update an account or profile, or participate in a survey, contest, or other promotion. RFS uses such information to communicate with you on various professional inquiries, to subscribe you to newsletters and other communications, and to distribute promotional materials to you. If you no longer wish to receive these communications via email, the opt-out process is described in Section 7 of this Privacy Policy. You may also unsubscribe from any email by following the unsubscribe instructions found within that email.

 

You may prevent your mobile device from sharing your location data by adjusting the permissions on your mobile device or within the relevant app.

 

(b) Application for Employment.

Our Site allows users to apply to employment opportunities. If you submit an application for employment, we may request some or all of the Personal Information listed in Section 2, above. We request this information to process your application in accordance with our internal hiring practices and to comply with applicable employment law.

 

(c) Document Submissions.

Our Site allows users to submit documents to us relating to their application for employment (namely, a resume). If you choose to send documents to us, you may disclose certain Personal Information through the Site as a product of your submission. RFS uses commercially reasonable efforts to ensure the appropriate administrative, physical, and technical safeguards are in place as it relates to the Personal Information you provide through our Site as part of any document submission.

 

(d) Site Login Information.

We process the username and password of users to enable secure logging on to our Site, and we process information regarding your role to appropriately control access to restricted content. We process this Personal Information only as necessary to provide our Site under our Terms of Use and to further our legitimate interests in protecting our Site and content.

 

(e) Third-party Providers.

Please note that we use certain third-party service providers on our Site to enhance your experience or deliver certain features, functionality, products, and services to you. These third-party service providers may collect Personal Information about you when they are performing services on our behalf and/or when you are using certain functions on our Site that are operated by these third-parties. Any information, including Personal Information, collected by such third-party service providers will be subject to those third-parties’ privacy notices or privacy policies, rather than this Privacy Policy. For more information related to our third-party service providers, please see Section 6(a) of this Privacy Policy.

 

(f) Social Media.

We have worked with certain third-party social media providers to offer you their social networking services through our Site. For example, you can use third-party social networking services to share information about your experience on our Site with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Site. These third-party social networking services also may notify your friends, both on our Site and on the social networking services themselves, that you are a user of our Site or about your use of our Site, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.

 

4. INFORMATION COLLECTED AUTOMATICALLY

Certain information on our Site is collected automatically by means of various software tools, as described below. We have a legitimate interest in using such information to assist in systems administration, information security, abuse prevention, to understand the usage of our Site, to analyze the effectiveness of our Site, and to improve our Site and your experience. Alone or in combination with other information, some or all of the automatically collected information may constitute Personal Information under certain laws pertaining to data privacy depending on where you live.

 

Some of our third-party service providers may also use cookies or other methods to gather information regarding your use of our Site. These third-party service providers may use these cookies or other tracking methods for their own purposes by relating information about your use of our Site with any Personal Information about you that they may have. The use of this information, including any Personal Information they may have about you, by these third-party service providers is subject to those third-parties’ privacy notices or privacy policies, rather than this Privacy Policy.

 

(a) Log Files On Our Site.

We maintain certain log files relating to the access and use of our Site. The information inside the log files includes internet protocol addresses, type of browser, Internet Service Provider, date/time stamp, clicked pages, the referring site (if applicable), screen resolution, color, and depth, and any other information your browser may send to us (collectively, “Log Data”). This Log Data may be used to see which areas and features are most popular, to count the number of computers accessing the Site, to personalize your experience, and to remember your preferences. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the purposes provided in this Privacy Policy.

 

(b) Cookies.

We use cookies to make interactions with our Site easy, efficient, and meaningful. When you visit our Site, our servers may send a cookie to your computer or other device.

 

The help function of your browser should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued or to not receive cookies at any time. If you set your device to not receive cookies at any time, certain personalized services cannot be provided to you, and accordingly, you may not be able to take full advantage of all of our features.

 

(c) Do Not Track Signals.

Please note that our Site may not recognize automated browser signals regarding tracking mechanisms, such as “do not track” instructions. RFS does not currently track users of our Site across third-party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to a web browser’s “do not track” signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about an individual consumer’s online activities over time and across third-party websites or online products/services.

 

(d) Analytics Service.

We may use certain third-party analytics services to improve the functionality, features, or delivery of our Site. We may also use these analytics services to record mouse clicks, mouse movements, scrolling activity, as well as any text that you type into our Site. For example, we use Google Analytics and Google AdWords on our Site to track user trends and usage.

 

5. THE PURPOSES FOR WHICH WE USE PERSONAL INFORMATION.

If you submit or we collect Personal Information through our Site, then such Personal Information may be used to:

 

Provide support for the Site;

Develop and improve products and services;

Inform users about products or services we think will be of interest;

Answer your questions;

Provide you with quotes for our services;

Deliver services that you request;

Analyze errors and improve the operation of the Site;

Prepare statistics about the use of the Site; and

Present offers that may be of interest to you.

 

6. HOW WE DISCLOSE PERSONAL INFORMATION.

We do not sell, lease, rent or otherwise disclose the Personal Information collected from our Site to third-parties unless otherwise stated in this Privacy Policy or unless you otherwise consent to us doing so.

 

(a) Third-party Service Providers.

We transfer Personal Information to third-party service providers that collect our employment application information, and to those third-party service providers that perform services on our behalf, such as sending communications to our customers and interested parties, conducting surveys, etc. We do not authorize these service providers to make any other use or disclosure of your information. We may also conduct business with certain third-parties to jointly offer services or promotions to our customers. We do not control these third-parties’ use of Personal Information we collect, and their use of the Personal Information will be in accordance with their own privacy notices or privacy policies.

 

Links to the privacy policies of third parties that play a role in the Site follow:

 

(b) Advertisers.

From time-to-time, we engage third-parties to provide advertising services to assist us in advertising our brand and Site. Those advertising services may target advertisements on third-party websites and apps based on cookies or other information indicating previous interaction with our Site.

 

(c) De-Identified and Aggregated Information.

To better serve you and improve our Site, RFS may conduct research utilizing certain anonymized Personal Information in statistical form. This research may be compiled and analyzed on an aggregate basis, and we may share this de-identified or aggregated information with our affiliates and third-parties with whom we do business. This de-identified or aggregate information does not identify a user personally. RFS may also disclose de-identified or aggregated information in order to describe our Site to current and prospective third-parties with whom we conduct business and to other third-parties for other lawful purposes.

 

(d) In the Event of Merger, Sale, or Change of Control.

We may transfer or assign this Privacy Policy and any Personal Information to a related or third-party entity as part of a merger, acquisition, sale, or other change of control of our business, assets, or stock, including in connection with any bankruptcy or similar proceedings.

 

(e) Other Disclosures.

We may disclose Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (1) comply with any applicable law, regulation, legal process or governmental request; (2) detect, prevent, or otherwise address fraud or security issues; or (3) protect against harm to the rights, property or safety of RFS, our users, or the public.

 

7. REVIEW, CORRECT, OR REMOVE PERSONAL DATA.

When we use your Personal Information in our communications and marketing efforts, we provide you with choices. To opt-out of receiving marketing or other promotional communications from us, to access, change or delete your personal information maintained by us, or to otherwise change your choices about how we use your Personal Information, we provide you with the following options: you may (1) follow the “Unsubscribe” instructions contained in the communication from us; or (2) e-mail us at privacy@rosefinancial.com.

 

If you are a resident of the European Union, then you have additional rights in regard to your personal data. If you are an individual in the EU and we are collecting your Personal Information, then you have several rights with respect to that information:

 

  • To learn whether we are collecting your personal information;
  • To receive a copy of your personal information;
  • To request that we correct any errors, outdated information or omissions in your personal information;
  • To request that we no longer use your personal data to contact you for marketing purposes;
  • To request that we provide the personal information you have provided to us to a third-party; and
  • To request that we delete your personal information.

 

We will require you to confirm your identity with approved identification when you contact us to exercise your rights.

 

Please note that while we will strive to meet your request regarding your rights to your personal data, there may be instances where local laws and regulations will require us to maintain your records despite your request.

 

To exercise any of your rights please contact us at privacy@rosefinancial.com.

 

8. RETENTION OF PERSONAL INFORMATION.

Your Personal Information is stored by RFS on the servers of the cloud-based services RFS engages. These third-parties do not use or have access to your Personal Information for any other purpose than cloud storage and retrieval. We reserve the right to retain any Personal Information as long as the Personal Information is needed to: (a) fulfill the purposes that are described in this Privacy Policy, and (b) comply with applicable law.

 

By entering your Personal Information into the Site, you consent to that Personal Information being hosted on servers of the cloud-based services we utilize. While your Personal Information will be stored on cloud-based servers, it will remain within RFS’ effective control at all times. Each data hosting provider’s role is limited to providing a hosting and storage service to RFS, and we’ve taken steps to ensure that our data hosting providers do not have access to, and use the necessary level of protection for, your Personal Information. They do not control and are not permitted to access or use your Personal Information, except for the limited purpose of storing the data. If you do not want your Personal Information to be transferred to a cloud-based server, you should not provide RFS with your Personal Information.

 

Your Personal Information may be accessed from, stored or processed in any country where RFS or its third-party providers are located. Your Personal Information may be accessed from, stored or processed in a jurisdiction that does not have privacy laws that provide equivalent protections to those in your home country. Please be assured that we will protect all Personal Information under our control in accordance with this Privacy Policy and take reasonable steps to ensure that as good stewards we protect your data using data security best practices.

 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to help prevent unauthorized access.

 

We retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Notice or until you request that your Personal Information be removed from our records, unless a longer or shorter retention period is required or permitted by applicable law.

 

9. DATA SECURITY.

The security of Personal Information is important to us. We use reasonable security measures in an effort to prevent loss, misuse, unauthorized access, disclosure, destruction and alteration of information while it is under our control. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.

 

10. CHILDREN’S PRIVACY.

We encourage parents to take an active interest in their children’s use of the Internet. We do no target and do not knowingly collect any Personal Information from children under the age of eighteen (18). When a user discloses Personal Information on our Site, the user is representing to us that he or she is at least eighteen (18) years of age. If at any point it is brought to our attention that we have collected the Personal Information of an individual under the age of eighteen (18), we will take commercially reasonable steps to permanently delete such information.

 

11. YOUR CALIFORNIA PRIVACY RIGHTS.

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Information about you by RFS to third-parties for the third-parties’ direct marketing purposes. To make such a request, please send an email to privacy@rosefinancial.com.

 

12. CHANGES TO THIS PRIVACY POLICY.

As our company changes over time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy on our Site.

 

13. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

The General Data Protection Regulation (GDPR) requires data collectors such as RFS to have a legal basis to use personal data collected from the EU and the UK. Therefore, this section applies to any such personal data collected by RFS.

 

The legal basis for processing your personal data is provided in your consent on our Site. RFS may also process your personal data if we haves a legitimate interest in doing so, and if this processing is permitted by law.

 

14. CONTACT US.

If you have any questions about this Privacy Policy, please contact us at: privacy@rosefinancial.com.