Effective Date: July 15, 2019
At Rosov Consulting (“Rosov” or “we” or “us”), we are committed to protecting your privacy. We firmly believe that electronic security and privacy are necessary for the continued success of the Internet. In support of this, we only use the personally identifiable information (“Personal Information”) that you provide in accordance with the terms outlined below.
1. Information We Collect
When you use our Sites, or participate in our research, you may choose to provide certain information directly to us to request more information or services, including the following Personal Information:
- first name, last name;
- email address;
- work address;
- phone number;
- date of birth;
- job title;
- job level;
- job role;
- company name;
- company size;
- company industry;
- geographic location;
- IP address;
- professional interests; and
- other related business/professional information.
You may, however, visit our Sites anonymously. We will collect personal identification information from you only if you voluntarily submit such information to us. You can always refuse to supply personal identification information, except that it may prevent you from engaging in certain Site-related activities.
- new or returning visitor;
- time of visit;
- duration of visit;
- pages viewed;
- where you found the Sites (search, direct, social media, etc.);
- country you’re visiting from;
- technology you’re using (browser, screen resolution, etc.); and
- gender and age range.
2. How We Collect Information
We collect Personal Information when you:
- visit our Sites;
- request information;
- request information from us;
- fill out a form;
- apply for a job; and
- participate in our research, including surveys, interviews, focus groups or on-site observation.
A “cookie” is a small data file stored on your web browser or on your mobile device that allows us to recognize your computer or mobile device when you visit the Sites by associating identification numbers with other user information you have provided us. Some cookies will remain on the hard drive of your computer or mobile device for the duration of your browser or user session, while others will remain until deleted by you. You may also be able to configure your computer or mobile device to limit the collection of these “cookies,” but that limitation may also limit our ability to provide all the services or functionality of the Sites. Some third party service providers may use “flash cookies,” which are saved on your computer, but cannot be rejected, disabled, turned off, opted out of, or deleted in the same way as regular cookies. To learn how to manage your flash cookie settings, visit the Flash player settings page on Adobe’s website.
3. How We Use Collected Information
Rosov collects and uses your Personal Information for the following purposes:
- to conduct research on behalf of our clients. In some cases, we may use your Personal Information in order to follow up with you about information you have provided in the past;
- to personalize user experience;
- we may use information in the aggregate to understand how users as a group use the services and resources provided on our Sites;
- to improve our Sites;
- to improve customer service;
- to more effectively respond to your customer service requests and support needs;
- to share your information with third parties;
- to administer a content, promotion, survey or other Site feature;
- to send you information you have agreed to receive about topics we think will be of interest to you; and
- if you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related service information, etc. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via our Sites.
4. How We Protect Your Information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information and data stored on our Sites. Sensitive and private data exchanged between the Sites and their users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.
5. Sharing Your Personal Information
Rosov also may disclose your Personal Information:
- in situations where sharing or disclosing your information is required in order to offer you services you desire;
- to third parties for marketing or any other legally permissible purpose at our sole discretion (if you are a user from the European Union, we will ask your consent before doing this);
- to a third party or parties, with your consent and where disclosure is required or permitted by law;
- if, in the reasonable judgment of Rosov, it is necessary to enforce compliance with our internal policies or to protect our Sites, customers, or others; and
- to any other entity that acquires all or a portion of our organization by merger, reorganization, operation of law, or a sale of some or all of Rosov’s assets.
- Qualtrics – To obtain relevant and accurate survey results
- SurveyGizmo – To obtain relevant and accurate survey results
Rosov may also be required to use or disclose your information in connection with a legal action or other proceeding, including without limitation, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.
Rosov may disclose Personal Information in response to lawful requests by public authorities, and to meet national security or law enforcement requirements.
6. Third Party Websites
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
Social Media Sites
We work with third parties, including social network sites like Twitter and LinkedIn, and with application developers who specialize in social commerce so we can connect to your social networks. All of these companies operate Social Media Sites. We provide access to our Sites by third parties and business partners so we can generate interest in our products among members of your social networks and to allow you to share product interests with friends in your network.
The use of any features made available to you on our Sites by a third party may result in information being collected or shared about you by us or by the third party. Information collected or shared through any such third party features is considered public information by us because the Social Media Sites made it publicly available. If you do not want us to be able to access information about you from Social Media Sites, you must instruct Social Media Sites not to share the information. Rosov is not responsible for how these third parties may use information collected from or about you so be sure to review the privacy policies and privacy settings on your social networking sites to make sure you understand the information they are sharing. If you do not want a Social Media Site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt out of sharing such information. However, we do identify any areas on our Sites where third parties share information about you.
We use features on Social Media Sites that allow you to express positive opinions about our services. Those Social Media Sites may collect or register your views about our services and make those views available to Rosov and on public portions of the Social Media Sites. If you do not wish any of this to happen, you should not express your views about our services on Social Media Sites and you should review your privacy settings on such Social Media Sites. We are not obligated to display your name or other identifying information, account name, profile photo or other information or content on our Sites even if you express an opinion about our services or have consented to our use of such information or content. We reserve the right to remove the information of any person for any reason. We may also remove from our Sites, in our sole discretion, any product offering or any photo or product description relating thereto. If you would like us to delete the data we have collected about you that we have received through any social media provider or Social Media Site, please contact us. However, if your information is deleted you may not have access to certain promotions, services information or opportunities as a result.
The Sites may list or link to third party products or services. Rosov does not have any control over the quality, safety or legality of the items advertised, the truth or accuracy of the listings, the ability of suppliers to sell items or the ability of buyers to buy items. For these reasons, Rosov and its affiliates cannot ensure that a buyer or supplier will actually complete a transaction. Rosov will not be a party to any transactions between you and such third parties and any correspondence concerning such transactions should be conducted between you and the third party.
7. Children’s Information
The Sites are not directed to children under the age of 13. Children under the age of 13 are prohibited from submitting any personally identifiable information to Rosov through the Sites. If you believe a child has provided us with information, contact us at privacy[at]rosovconsulting.com.
8. California Privacy Rights
If you are a California resident, you have the right to request information from us regarding the manner in which Rosov shares certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:
- The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
- the names and addresses of the third parties that received the information; and
- if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
This information may be provided in a standardized format that is not specific to you. The designated email address for these requests is: privacy[at]rosovconsulting.com.
Also, please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
9. EU-U.S. and Swiss-U.S. Privacy Shield
As described in the Privacy Shield Principles, available at https://www.privacyshield.gov/article?id=Requirements-of-Participation, Rosov remains responsible and liable under the Privacy Shield Principles for onward transfers if third-party agents that we engage to process personal information on our behalf do so in a manner inconsistent with the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Rosov commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Rosov at: privacy[at]rosovconsulting.com.
We have further committed to refer unresolved Privacy Shield complaints to JAMS (Judicial Arbitration and Mediation Services, Inc.), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles. For details, please see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Rosov is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
10. European Users’ Rights
Legal Basis for Processing Information
If you are located in the EU or Switzerland, we rely on several legal bases to process your Personal Information. These legal bases include where:
- The processing is necessary to perform our contractual obligations, such as to provide you with our services;
- You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
- The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
- The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing our services, marketing new features or products that may be of interest, and promoting safety and security as described above.
If you have any questions about or would like further information concerning the legal basis on which we collect and use your Personal Information, please contact us by emailing privacy[at]rosovconsulting.com.
If you are a Rosov customer or a participant in Rosov research, we will retain your Personal Information as long as we are providing the services to you, or up to five years after the conclusion of research. We retain Personal Information after we cease providing services to you to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Information to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
Rights Under the General Data Protection Regulation
If you are located in the EU or Switzerland, you have the following rights in respect of your Personal Information that we hold:
- Right of access. The right to obtain access to your Personal Information.
- Right to rectification. The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
- Right to portability. The right to portability allows you to move, copy or transfer Personal Information easily from one organization to another.
- Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
If you wish to exercise one of these rights, please email us at privacy[at]rosovconsulting.com . You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Obligations to Data Protection Authorities (DPAs)
We will respond diligently and appropriately to requests from DPAs about this policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of Personal Information, we will (1) cooperate with inquiries from the DPA responsible for the entity exporting the data and (2) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.
Accountability for Onwards Transfers
11. Your Consent and Updates to this Policy
If you have any questions about your privacy or security on our Sites, please contact us using the following information:
Rosov Consulting LLC
2095 Rose Street, Suite 101
Berkeley, CA 94709