Rosalyn Privacy Policy

(Last Updated July 21, 2019)

Rosalyn, Inc., a Delaware Corporation, (“Rosalyn,” “we” or “us”) provides an online and mobile service, the Rosalyn website, www.rosalyn.ai (the “Site”), computer mobile applications (“App” or “Apps”) and programs hosted by or on behalf of Rosalyn and related services (together with the Site and the Apps, the “Service”). The terms “you” and “user” means all individuals and entities that access the Service.

This Privacy Policy describes how we use Personal Information (defined below) that we collect from you as part of you using our service. For EU users, please see our special provisions under the “Special Information for EU Users” section below. This Privacy Policy also describes the choices available to you regarding our use of your Personal and how you can access and update this information, and what information you provide that we will retain even if you decide to delete the App or stop using the Service. Our Privacy Policy is not a contract, and it does not create any legal rights or obligations.

You should also read our Terms of Service, available for Client Users at https://www.rosalyn.ai/terms-conditions/ which contains important information about the scope and nature of the Service, and the rules that apply to your use of our Service. All capitalized terms used in this Privacy Policy that are not defined in this Privacy Policy have the meaning given to them in the Terms of Service for Rosalyn.

Your use of the Service indicates that you consent to our collection, storage, use and disclosure of your personal information and other information as described in this Privacy Policy and the Rosalyn Terms of Service. If you do not consent to the use of your Personal Information as described in this Privacy Policy or do not agree to the Terms of Service, do not use the Service.

Data Controller

Rosalyn provides services to users throughout the world. If you use our services in the United States or in the European Union or elsewhere, Rosalyn, Inc. is the data controller. The address for the data controller of the information you provide or that is collected by Rosalyn or its affiliates is:
ATTN: Privacy Officer
Rosalyn, Inc.
6605 Longshore Street #240
Dublin OH 43017
privacy@rosalyn.ai

Types of Information We Collect

A. Personal Information. In order to access and utilize the Rosalyn services, one is required to become a registered user. As part of the registration process, one is required to provide the following: (1) name; (2) email address; (3) age; (4) user name; (5) password; (6) phone number; and (7) access information to hardware requirements in order to access and use the Service. All registration information provided to us must comply with the Rosalyn Terms of Use Agreement.

As part of the user experience, you may also exchange information with us that would be part of the personal information we collect. Examples include but are not limited to the following: (1) information provided when you download or use applications from us; (2) information you enter into our system and post as part of using our services (e.g. photos, videos, comments, voice recordings and other multimedia communication materials); (3) information you provide to us when contacting us for help; (4) profile information you provide for your personal user profile or information that is gathered as part of accessing your computer hardware and related devices (e.g. age, first and last name, picture, image or likeness, phone number, etc.); and (5) access to the data you provide to us via video and/or audio fees you send to us in order to use our services.

1. Specific Use of Personal Information. The information we collect allows us to provide you with a relevant user experience as well as a mechanism to keep you informed on Rosalyn’s latest product announcements, software updates, and promotional information. If you so desire, you can remove yourself from our mailing list by opting out by updating your profile preferences.

Other uses of personal information may be for validating a user account, fraud prevention, or other data safety precautions Rosalyn may elect to implement. Additionally, we may use personal information for our internal purposes such as data analysis, auditing, and research to improve our services to you.

B. Non-Personal Information. Rosalyn collects information that in and of itself does not permit direct association with any specific person. In the case of non-personal information Rosalyn has the right to collect, transfer, use, and disclose this information for any purpose. Examples of non-personal information and its intended use:

1. Device related information. We may collect information such as the user device identifier (IDFA), type of mobile device, IP address of your mobile device, mobile operating system, and type of mobile Internet browsers. The device identifier itself may deliver the information to us directly or we may obtain this information via a third party partner and/or affiliate. We use the information for the express purpose of better understanding customer behavior and improving our products and services.

2. User activity with our services. We may collect and store details on how you interact with our services. This may help us improve our service offerings and to provide a better user experience.

3. Metadata. Metadata is unique technical data that is generally associated with User Content. Metadata allows one to make their User Content more searchable when interacting with our Service. An example of metadata would be a hashtag or some form of geotag that would allow others to more readily find your submitted content and/or its given location.

C. Location Based Information. Use of the Rosalyn services, permits us to collect precise information about the location of your particular device. Location may include but is not limited to background location information between Users. We may use your location information to provide requested location services and to allow tagging of files. Users who utilize our platform as test-taking applicants, agree and consent to the location based information we collect in order for us to verify and/or monitor test-taking activities

D. Information from Other Sources. This may include:

  1. User feedback;
  2. Requesting services for or on your behalf;
  3. Users or others providing information in relation to any claim or dispute;
  4. Rosalyn business partners including those with whom you may create or access your account, such as payment providers, social media users, or websites who use Rosalyn’s APIs or whose API Rosalyn uses;
  5. Publicly available sources.
  6. Marketing service providers.

Rosalyn may combine the information gathered from these other sources with other information in its possession.

Cookies and Other Tracking Technologies

“Cookies” are small data files that are sent to your web browser when you access a website, and the files stored on your device’s hard drive. We use “session” cookies to keep you logged in while you use the Site, to track your preferences and to track trends and monitor usage and web traffic information on the Site. These are erased when you close your browser. We use “persistent” cookies to relate your use of our Service to other information about you and store information about your preferences to make your user experience consistent and customized. For example, we may create a persistent cookie that includes some basic information about you, like your favorite website locations and whether customer support responded to your inquiry. These cookies stay on your hard drive until you erase them or they expire and associate your information with your account even if you are logged out.

Most browsers automatically accept cookies, but you can change your settings on the browser settings to refuse cookies or prompt you before accepting cookies. You can also use your browser settings or other tools to delete cookies you already have. However, if you disable or refuse cookies, then certain features of the Site may be inaccessible or not function properly.

Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Service and may associate that information with your account if you have one.

Certain features of the Site may use local shared objects (or “flash cookies”). Flash cookies are small files similar to browser cookies that collect and store information about your preferences and where you browse and what you look at on the Site. Flash cookies are not managed by the same browser or device settings that are used for browser cookies. You may adjust your Adobe Flash Player settings to prevent flash cookies from being placed on your hard drive.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

We may use “clear GIFs” (aka “web beacons” or “pixel tags”) or similar technologies, on our Service or in our communications with you to enable us to know whether you have visited a part of our Service or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a website or in an email or other type of message, which is retrieved from a remote website on the Internet enabling the verification of an individual’s viewing or receipt of a website or message.

We do not automatically collect Personal Information, but we may tie Personal Information with the automatically collected information using the above tools or information collected from other sources.

We may also log information using digital images called web beacons on our Service or in our emails. We may use web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We may also use web beacons to tell if you open or act on our emails.

We also use third party analytics services to collect usage data from our Apps in order to help us understand how users are interacting with our Apps. Third party analytic services are used to track general location information, and events that occur without our Services, such as how often you use our Services. This information, including your IP address, is transmitted and stored by 3rd parties as determined by us.

IP Address Information and Other Information Collected Automatically

We automatically receive and record log file information from your web browser when you interact with the Site, including your IP address and cookie information. Generally, the Site automatically collects usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Service so that we can analyze and improve them.

In terms of test-taking applicant users, you consent and agree for us to collect this information as part of the test taking/monitoring aspect of our Services. You understand and acknowledge that this information may be used to identify you personally as a condition to the test-taking policies you have consented to abide by. You also agree and consent for this information to be shared with our Client Users as a condition to your use of our Services.

Third-Party Sites and Services

Rosalyn products, services, and application may contain links to third-party services (e.g. Facebook, Google etc.), products, and websites. Information collected by third parties is governed by their privacy policies and practices. We encourage you to read and learn about their specific privacy practices.

Information Sharing and Disclosures

From time-to-time, Rosalyn may make certain personal information available to product and service partners. Specific ways Rosalyn shares with third parties are described below:

A. Third-Party Service Providers. Rosalyn may elect to outsource some of its technical and customer support, tracking and reporting functions, quality assurance testing, and other services that it may deem necessary. In these specific instances, we may share information about or from you in order for them to provide their services. Additional examples may include:

  1. Payment processors and facilitators.
  2. Cloud storage providers.
  3. Data analytics providers including Full Story and Google Analytics.
  4. Research partners.
  5. Consultants, accountants, lawyers, and other professional service providers.

In these specific instances, we may share information about or from you in order for them to provide their services.

B. Business Affiliates and Transfers. Rosalyn may share information from or about you with its subsidiaries, joint ventures, or companies under common control, in which case we will require them to adhere to this Privacy Policy. In the event Rosalyn, Inc. is acquired in total or by a substantial amount of its assets, we will make best efforts to ensure that the purchaser will assume the rights and obligations of this Privacy Policy. However, Rosalyn cannot make any guarantees or promises with respect to a purchaser adopting the current rights and obligations of this Privacy Policy.

C. Investigations. As described in the Rosalyn Terms and Conditions of Use, Rosalyn reserves the right to provide and/or disclose necessary information for investigatory matters. Examples include but are not limited to: 1) compliance with law enforcement or the necessary legal process; 2) behavior and/or use violative of the Terms and Conditions of Use, and 3) instances whereby it is necessary to protect our rights and obligations.

D. User Request. This includes sharing your information with:

1. Rosalyn business partners. For example, we may share your location and/or that of the Rosalyn sensor(s) when you engage the services, we may make available to you through our business partners and their affiliates.

E. With your consent. Rosalyn may share your information other than as we have described in this policy if we notify you and you consent to the sharing.

Storage of Your Information

The information you provide Rosalyn may be collected through our services and processed in the United States or any other country in which Rosalyn, its subsidiaries, affiliates, and/or service providers maintain facilities.

As a result, Rosalyn its subsidiaries, affiliates, and/or service providers may transfer information we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. For example, you may reside in another country or region with differing data protection and privacy laws than the United States. Consequently, when you register to use the Service you acknowledge and consent to Rosalyn transmitting your information to the United States or to any country in which Rosalyn and/or its subsidiaries, affiliates, and/or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

In turn, Rosalyn uses commercially reasonable standards, measures and/or protocol to keep the information collected through the Service secure and as a result we take cautionary steps to verify your identity before granting you Service access. Moreover, Rosalyn cannot ensure the security of any information submitted or transmitted by you to Rosalyn nor can we guarantee that said information may not be disclosed, destroyed, and/or altered.

Protection of Personal Information

Rosalyn preserves the security of your personal information with the utmost caution. As such, we follow the generally accepted industry standards to protect all user information submitted to us. Although we implement accepted industry standards, we cannot guarantee absolute security with respect to your personal information. Given the fact that no one method of transmission over the Internet or via mobile device is 100% secure, we urge you to take the utmost care when transmitting personal information.

When you use some of the features of the Rosalyn services, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. Please take care when using these features.

Data Retention

Rosalyn will retain your personal information for a minimum of 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. Rosalyn thereafter deletes or anonymizes such information with applicable laws. Users may request deletion of their account at any time. Following such request, Rosalyn deletes the information that it is not required to retain and restricts to or use of information it is required to retain. You may request deletion of your account by contacting us here at privacy@rosalyn.ai.

Rosalyn may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if Rosalyn shuts down a user’s account, Rosalyn may retain certain information about that account to prevent that user from opening a new Rosalyn account in the future.

Access to Personal Information

In order to ensure that your personal information is current and accurate, please log in to your account using the Rosalyn Site and go to user profile.

Children

Rosalyn is aware of the importance of protecting the privacy and safety of children who may use our services. In that regard, we do not knowingly solicit data from or market to children under the age of 13. In the event a child’s parent and/or legal guardian becomes aware that their child has provided us with information without their consent, please contact us immediately at privacy@rosalyn.ai. Once notified, we will delete the information as soon as reasonably possible.

Privacy Concerns

In the event you believe there to be a conflict and/or concern with the terms of this Privacy Policy, you may contact us directly at:
ATTN: Privacy Officer br 6605 Longshore Street #240
Dublin OH 43017
privacy@rosalyn.ai

Privacy Policy Modifications

Rosalyn reserves the exclusive right to change, modify, or alter the terms of this Privacy Policy. The most current version of this policy will govern our use of your information. Continued access and use of the Rosalyn services after changes to our Privacy Policy occur indicate that you agree to be bound by the revised Privacy Policy.

Consent

Your continued access and use of the Rosalyn services, subject to the Terms of Use and Conditions, signifies your unequivocal consent to the terms of this Privacy Policy.

Special Information for EU Users

Beginning May 25, 2018, the processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”). This section summarizes Rosalyn’s grounds for processing personal information under the GDPR, and the rights of EU users as relates to Rosalyn’s handling of personal information. This section provides information as relates to EU users’ rights, and Rosalyn’s responsibilities, under this regulation.

A. EU User Rights

If you are an Rosalyn user in the EU, you have the following rights with respect to Rosalyn’s handling of your personal information. To exercise these rights, please see below or submit your request at privacy@rosalyn.ai. Users outside the EU may also request explanation, correction, deletion or copies of their personal data by contacting us at privacy@rosalyn.ai.

  1. Explanation and copies of your data
    ▪ You have the right to request an explanation of the information that Rosalyn has about you and how Rosalyn uses that information.
    ▪ You also have the right to receive a copy of the information that Rosalyn collects about you if collected on the basis of consent or because Rosalyn requires the information to provide the services that you request.
  2. Correction
    ▪ If Rosalyn has information about you that you believe is inaccurate, you have the right to request correction of your information. Please see the section titled “Explanation, Copies and Correction” below for more information on correcting, or requesting correction of, your information.
  3. Deletion
    ▪ Users may request deletion of their accounts at any time. Users may request via Rosalyn’s website at privacy@rosalyn.ai. We may retain certain information about you as required by law and for legitimate business purposes permitted by law.
    ▪ Please see the “Data Retention & Deletion” section above for more information regarding Rosalyn’s retention and deletion practices.
  4. Objections and complaints
    ▪ Users in the EU have the right to object to Rosalyn’s processing of personal data, including for marketing purposes based on profiling and/or automated decision making. Rosalyn may continue to process your information notwithstanding the objection to the extent permitted under GDPR.
    ▪ You may also submit questions, comments or complaints to Rosalyn directly at ATTN: Privacy Officer
    Rosalyn.com
    6605 Longshore Street #240
    Dublin OH 43017
    privacy@rosalyn.ai

B. Grounds for Processing

The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, Rosalyn processes the information of EU users based on one or more of the grounds specified under the GDPR:

  1. The processing is necessary to provide the services and features you request

    ▪ Rosalyn must collect and use certain information in order to provide its services. This includes:
    ▪ User profile information that is necessary to establish and maintain your account, including to verify your identity; enable communications with you about the products you order from us, orders and accounts; and to enable you to make payments.
    ▪ Integration into your and/or licensed third party’s real time proctoring services.
    ▪ Usage information, which is necessary to maintain, optimize and enhance Rosalyn’s services, including to determine, sometimes in combination with other information, incentives, etc.
    ▪ Collection and use of this information is a requirement for using Rosalyn’s website and services.

  2. The processing is necessary to protect the vital interests of our users or of others
    ▪ Rosalyn may process personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.
  3. The processing is necessary for Rosalyn’s legitimate interests
    ▪ Rosalyn collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information:
    ▪ To prevent, detect and combat fraud in connection with the use of our services. For example, Rosalyn uses user profile, location, Rosalyn sensors, device and usage information, to identify and prevent circumstances when users attempt to defraud Rosalyn or other users.
    ▪ To inform law enforcement officials regarding criminal acts or threats to public safety.
    ▪ To provide customer support.
    ▪ To optimize our service and develop new services. This includes, for example, identifying and perfecting our AI models.
    ▪ To aggregate, analyze, and interpret the data collected by the Rosalyn services.
    ▪ For research and analytical purposes. This includes, for example, analyzing usage trends to improve the user experience and enhance the safety and security of our services.
    ▪ For direct marketing purposes. This includes, for example, analyzing data to identify trends and tailor marketing messages to user needs.
    ▪ To enforce Rosalyn’s Terms of Service.
  4. The processing is necessary for the legitimate interests of other persons or parties
    ▪ Rosalyn collects and uses personal information to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others.
    ▪ Rosalyn may also process personal information when necessary in regard to a substantial public interest, on the basis of applicable laws.
  5. The processing is necessary to fulfill Rosalyn’s legal obligations
    ▪ Rosalyn is subject to legal requirements in the jurisdictions in which it operates that require us to collect, process, disclose and retain your personal data. For example, Rosalyn is subject to laws and regulations in many cities and countries that require it to collect and retain information about the Rosalyn products, to retain such information for extended periods of time, and to provide copies of such information to governmental or other authorities. Rosalyn uses your information to comply with such laws to the extent they apply to your use of the Rosalyn apps.
    ▪ Rosalyn may also share information with law enforcement, or requests by third parties pursuant to legal processes. For more information about such sharing, please see
  6. Consent
    ▪ Rosalyn may collect and use your information on the basis of your consent. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.
    ▪ Rosalyn relies on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you. If you are an EU user, the following types of data collections or uses are done on the basis of your consent.
    ▪ Location Information (Users and Rosalyn products)
    ▪ Rosalyn sensor data aggregation, analysis, and interpretation by our third-party partners
    ▪ Notifications: Account Updates
    ▪ Notifications: Discounts and News
    ▪ Address Book / Contacts
    ▪ Please see the Choice & Transparency section below for further information about these data collections and uses, how to opt in or out of them, and the effect of opting out of these on your use of Rosalyn’s apps.
    ▪ Rosalyn may also collect personal information about you through voluntary surveys. Your responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

Choice and Transparency

Rosalyn provides means for you to see and control the information that Rosalyn collects, including through:

  • device permissions
  • marketing opt-outs

You may also request that Rosalyn provide you with explanation, copies or correction of your data.

A. DEVICE PERMISSIONS

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that websites cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Rosalyn website wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Rosalyn website seeks before you first use the website, and your use of the website constitutes your consent.

B. EXPLANATIONS, COPIES AND CORRECTION

You may request that Rosalyn:

  • Provide a detailed explanation regarding the information Rosalyn has collected about you and how it uses that information.
  • Receive a copy of the information Rosalyn has collected about you.
  • Request correction of any inaccurate information that Rosalyn has about you.

You can make these requests by contacting Rosalyn at privacy@rosalyn.ai. You can also edit the name, phone number and email address associated with your account through the Settings menu in Rosalyn’s website You can also look up your transactions, history, etc. in the Rosalyn website.

C. MARKETING OPT-OUTS

You may opt out of receiving promotional emails from Rosalyn at privacy@rosalyn.ai. You may also opt out of receiving emails and other messages from Rosalyn by following the instructions in those messages. Please note that if you opt out, we may still send you non-promotional messages, such as receipts for your rides or information about your account.

Privacy Policy Modifications and Updates

Rosalyn reserves the exclusive right to change, modify, or alter the terms of this Privacy Policy. The most current version of this policy will govern our use of your information. Continued access and use of the Rosalyn services after changes to our Privacy Policy occur indicate that you agree to be bound by the revised Privacy Policy.

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