Last Updated June 6, 2024

This is the privacy notice (“Privacy Notice”) for Rosie. It explains how we collect and use information through use of i) our AI phone receptionist to answer calls and set appointments (the “AI Receptionist”; ii) a Subscriber dashboard, software and applications integrated with a Subscriber’s existing systems (collectively, the “Application”); and iii) heyrosie.com and other websites or online channels we own or operate (collectively, the “Site”) (altogether, with the Site and Application, the “Services”). Any use of our Services is subject to this Privacy Notice and our Terms of Service, including its applicable limitations on damages and the provisions regarding resolution of disputes. 

Please read this Privacy Notice carefully to understand how we collect and use personal information. We may provide additional notices about our privacy practices, each of which will be considered to form part of this Privacy Notice. YOU CONSENT TO OUR PRIVACY PRACTICES BY INDICATING YOUR CONSENT WHERE THE OPTION IS MADE AVAILABLE OR USING OUR SERVICES IN ANY MANNER. If you do not agree with this Privacy Notice, do not access or use our Services.

This Privacy Notice does not apply to our Subscribers’ collection or use of Personal Information through our Services or otherwise. Callers should contact the business they called for privacy support. 

Rosie may update this Privacy Notice from time to time. We will notify you about material changes to this Privacy Notice through the Services or by email and we will collect your consent to these changes to the extent required by applicable law. Rosie Subscribers and prospective Subscribers may contact Rosie with questions at support@heyrosie.com.

1. Subscribers and Callers

This Privacy Notice does not apply to data collected by a third party, including the subscribing businesses and individuals that use an AI Receptionist to answer or make calls or perform other Services on their behalf (our “Subscribers”). Rosie provides the Services to our Subscribers, and each Subscriber determines how it will use the data collected from their Callers and other customers through the Services. Any processing of data by Rosie to train or develop AI technologies is governed by contracts with our Subscribers, not this Privacy Notice. 

Rosie Subscribers that use the AI Receptionist may choose to collect and process Personal Information about their Callers or other customers. Each Subscriber is responsible for their own Personal Information collection and storing or processing that data on the Services. This includes AI Receptionist functionality, privacy settings, data management, giving notice and obtaining consent from Callers, and responding to Callers’ privacy inquiries. Callers should contact the Subscriber with any questions about their Personal Information on the Services. 

2. “Personal Information” Defined 

As used in this Privacy Notice, “Personal Information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or device, such as:

• Identifiers (e.g., name, email, telephone number, address, username); 

• Sensitive Personal Information (e.g., biometrics like voice recordings, precise geolocation, health information, contents of messages when we are not the recipient; in some cases, information about a known child);

• Legally protected information (e.g., race, citizenship, marital status, sex);

• Employment-related information (e.g., current or past employment);

• Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);

• Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); 

• Internet or other similar activity (e.g., browsing history; content interactions); and

• Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes. 

Note that information may not be protected by privacy laws if it is: (i) publicly available (ii) aggregated, meaning data about a group or category of services or Callers from which individual identities and other Personal Information has been removed; or (iii) deidentified so that it cannot be easily linked back to the individual. 

3. Rosie’s Collection and Use of Personal Information

Rosie will only collect, use, retain, and disclose Personal Information as described in this section, and only as reasonably necessary and proportionate to provide the Services or for other purposes stated in this Privacy Notice or at the time of collection. 

Rosie collects identifiers, commercial history, internet and similar activity from Callers and Subscribers, as well as sensitive information or other categories of Personal Information that a Caller chooses to include in their call. We collect this information with consent, with a legitimate interest, or as authorized or required by law.

Collected from our Subscribers. Rosie collects and uses Personal Information from our Subscribers with their consent and as instructed by the Subscriber. 

• When a Subscriber registers to use our Services, we collect information about their business, like name, email, phone, and other identifiers to create and facilitate their account and use of the Services. Rosie also collects any information a Subscriber submits to the Services, such as account profile information, employee identifiers, and any Personal Information included in communications with us related to the Subscriber’s use of our Services. 

• Subscribers authorize Rosie to collect data from the Subscriber’s website, online reviews, and other data sources to train the Subscriber’s AI Receptionist. 

• A Subscriber may also choose to link the Services with the Subscriber’s customer relationship management software (“CRM”), calendars, or other software. If so, Rosie will access this information to provide enhanced Services as requested by the Subscriber. 

• Note that the Subscriber is solely responsible for ensuring the Subscriber is authorized to share Personal Information with Rosie for any purpose.

• We will also collect data related to Services purchased and transaction history on the Services associated with the Subscriber’s account. 

• Subscribers may opt-out of receiving marketing communications from Rosie at any time. If a Subscriber chooses to opt-out, Rosie may continue to send the Subscriber product and support messages to keep them updated on the Services they receive. 

• Subscribers that collect technical information about their Callers may share that information with us. We may combine this information with other data to gather feedback about the Services and to run reports on behalf of our Subscribers. We only use information Subscribers provide to us in our capacity as a service provider as permitted by our contracts with Subscribers or as permitted by law. Note that Subscribers may use this information for their own purposes according to their own privacy practices. 

Rosie reserves the right to refuse Subscriber instructions to collect or process Personal Information about another individual without their consent or in a manner or for a purpose that Rosie determines violates others’ privacy or publicity rights, or otherwise violates our Terms of Service, and such instructions may result in termination of Services at our option. Rosie is not responsible for the privacy practices of any of our Subscribers or any third party.

Collected from Callers on behalf of a Subscriber. Our AI Receptionist collects Personal Information from Callers on behalf of our Subscribers. 

• We may collect the contact information or other identifiers of a Caller contacting a Subscriber and the contents of the Caller’s message to the Subscriber they are contacting. 

• Callers may include Personal Information in their conversations with a Subscriber’s AI Receptionist. The AI Receptionist will use the information to generate the Caller’s requested information or other outputs. 

• For example, if a Caller requests to set an appointment with a Subscriber, the Services will schedule the appointment on the Subscriber’s system. If the Subscriber uses text or email reminders, the Services will process the Caller’s Personal Information to generate and send those appointment reminders to the Caller. 

• The AI Receptionist technology collects and analyzes the Caller’s voice to understand and process the Caller’s request and to detect when different responses or human intervention may be necessary to complete their call.

• We collect this information as a service provider to our Subscribers and we use it as instructed by the Subscriber through our contract with them or as permitted by law. Any use of inputs or outputs by a Subscriber is subject to the Subscriber’s privacy practices, not ours, and Rosie has no control or responsibility for the Subscriber’s activities. A Caller should contact the Subscriber they called if they have questions about Personal Information included in their conversation with its AI Receptionist.

• When a Caller interacts with an AI Receptionist, Rosie will collect and record any information, including Personal Information, that the Caller chooses to share. A CALLER’S INTERACTIONS WITH AN AI RECEPTIONIST MAY BE ACCESSIBLE TO ROSIE OR OUR THIRD-PARTY SERVICE PROVIDERS SIMULTANEOUSLY AND IN REAL TIME. By interacting with an AI Receptionist, Callers consent to this access to their interactions by Rosie and our service providers. If a Caller does not consent to such access, they should not interact with the AI Receptionist.

• Rosie may also use the data provided to an AI Receptionist for our legitimate interest in training and improving our Services or for analytics and statistical purposes.

• By interacting with an AI Receptionist, a Caller consents to this collection of their information for these purposes. 

Call Recordings and Transcripts. The Services generate call recordings and transcripts of conversations.

• Calls with AI Receptionists are recorded for quality assurance, to improve the Services, and for other internal business purposes. Call recordings are used to generate transcripts of conversations and support our Subscribers’ use of our Services. 

• If you are a Caller, the AI Receptionist will notify you if a call is being recorded. By staying on the line after receiving the notification, you consent to the call recording. If you do not consent to call recording, you may end the call or ask to not be recorded. 

• Call recordings and transcripts are necessary for our Services to function. For example, Rosie’s technology may use a recording of the call to set the Caller’s appointment and send appointment reminders through the Subscriber’s CRM or other software. 

• Deidentified data from call recordings and transcripts may be used to understand how Callers interact with the AI Receptionist, train our AI technology, or to improve the Services. 

• Call recordings, transcripts, and other data from calls belong to the Subscriber, not Rosie. Each Subscriber determines how data is used and how long it is retained. Please contact the Subscriber you called if you have questions about call recordings. 

Rosie Does Not Process Payments. Rosie never collects, stores, or processes payment information. 

• Rosie charges Subscribers subscription fees and sometimes facilitates payments from Callers to Subscribers as a Services feature. 

• Rosie does not process any payments. Rather, we always use a PCI-DSS compliant payment processor collect, process, and store payment information, subject to the payment processor’s policies and terms. 

• Rosie is not a payment processor and we do not store payment information or process payments or receive, transmit, or otherwise handle or process any funds as part of the Services. 

About Children’s Privacy. The Services are designed for use by adults, not children. 

• Each Subscriber is responsible for using the Services in a manner that prevents children from providing their Personal Information. 

• If a Subscriber permits children to provide Personal Information through the Services, that Subscriber does so according to its own privacy practices, not ours. Please contact the Subscriber with any questions about children’s privacy.

• If we discover that a child under 16 has provided us with Personal Information, we will delete their information from our systems. If you believe we might have any information collected online from a child under 16, or if you become aware of any unauthorized submission of information to Rosie, please contact us at support@heyrosie.com.

Your Communications with Rosie. If you contact Rosie as a potential new Subscriber, Site visitor, or for any other reason, we will collect Personal Information from you to respond to your inquiry.

• If you request information about our Services, we will collect your contact information as needed to provide you with the information you request. 

• We collect this information with your consent, and we use it for the purposes stated at the time of collection, to provide you with our Services, and to communicate with you or send you direct marketing communications.

When you visit the Site or use our Application. Rosie may automatically collect technical data, which may include some Personal Information, from your visit to the Site or other uses of our Services. 

• Device information (e.g., IP address, operating system, browser type, device ID, mobile network information, caller ID) 

• Usage details (e.g., traffic data, search queries, content interactions) and stored information (e.g., metadata)

• Data collected from cookies and other technologies to track use of our Site. Rosie uses analytics cookies to understand how visitors interact with the Site, and marketing cookies to analyze and deliver marketing content across platforms. You can block or adjust how cookies interact with your device by changing your browser settings or by installing a third-party plugin.

• Rosie collects this information to achieve our legitimate interest of providing and improving our Services. We may also use this information to deliver targeted advertising.

In addition to the specific uses described above, Rosie may use Personal Information to (i) provide, administer, maintain, improve, or analyze the Services; (ii) communicate with Subscribers or others; (iii) develop new Services, products, or features; (iv) prevent fraud, criminal activity, or misuse of the Services, and protect the security of our information systems, architecture, and networks; (v) comply with legal obligations or protect our rights and the rights of others, or (vi) support or carry out a business transition or transfer. 

4. Disclosing Personal Information

Rosie discloses Personal Information to certain third parties to achieve our business purposes as described below, with your permission, or as required by law. In the preceding 12 months, we have disclosed Personal Information from all categories of collection to one or more of the following recipients:

• Our Subscribers. Personal Information that Rosie collects as a service provider to our Subscribers belongs to the Subscriber and is made available to our Subscribers to process and use according to their own privacy practices. Rosie does not control and is not responsible for the privacy practices of our Subscribers or third parties. Callers should contact the Subscriber they called with any questions about the Subscriber’s privacy practices. 

• Our Service Providers. Rosie uses a variety of service providers such as data storage providers, analytics services, and email services. The type of information that we disclose to a service provider will depend on the service that they provide to us. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.

• Law enforcement, and other governmental agencies, as permitted or required by law.

• Other third parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.

• Rosie does not sell Personal Information. Rosie does not disclose Caller Personal Information to third parties in exchange for monetary or other valuable consideration. 

• Rosie does not share Personal Information. Rosie will not share Caller Personal Information with third parties for cross-platform marketing purposes. 

• Aggregated and Deidentified Information. Rosie may de-identify or aggregate any Personal Information or other data input to or collected through the Services. De-identified and aggregated data is not Personal Information, and we will not attempt to reidentify it with any consumer except as required by law. We may use this data to analyze the effectiveness of the Services or improve the Services, such as to train our language learning models, improve or add features, or for research or related purposes. We reserve the right to disclose aggregated and de-identified data to third parties without limitation. 

  
  

5. Retention of Personal Information

As a service provider to our Subscribers, Rosie retains Personal Information about Callers until the Subscriber deletes it or instructs us to do so. Subscriber account information is retained while the account is active. We delete Subscriber account data 30 days after the Subscriber’s subscription is cancelled. Subscribers may retain Personal Information collected through the Services for different retention periods, subject to the Subscriber’s privacy practices.

Personal Information on our marketing lists is retained until you opt out or we determine that the information no longer serves our business purposes. For example, if you have never been a Subscriber and you do not interact with the marketing content we send you for two years, we will remove your Personal Information from our marketing lists. Other types of data are retained and disposed of according to our company policies. Rosie may retain Personal Information for longer if we feel it is necessary for legal or regulatory purposes. 

When we no longer have a business need for your Personal Information, we will either delete, de-identify, or anonymize it whenever feasible. Where not feasible (such as data in our backup archives) we will securely store it and keep it isolated from further processing until it can be permanently deleted. 

6. Third-Party Services

The Services may provide access or links to services offered by third parties. Please note that Rosie has no control over third-party websites, apps, devices, or systems, and you should exercise caution when deciding to disclose your Personal Information.

7. Privacy Controls on the Services

Rosie provides Subscribers, prospective Subscribers, and Site visitors with options to access and control how we collect and use your Personal Information on our Services. If you have interacted with an AI Mascot provided by a Subscriber, please contact the Subscriber to learn about your privacy controls.  

• Privacy Requests. If you are a Caller, please direct any privacy-related requests or inquiries to the Subscriber you contact via our Services. Otherwise, to exercise privacy rights as a Subscriber or Site visitor, express concerns, lodge a complaint, or request information, please contact support@heyrosie.com. Rosie responds to privacy requests as required by applicable law.

• Subscriber Accounts. Subscribers can access, correct, update, or delete certain Personal Information on their account by logging in and saving their changes or adjusting their settings. If you require assistance or want to revoke a consent you previously gave us, please contact support@heyrosie.com.

• Emails from Rosie. Rosie may send you support emails related to your account or, if you opt-in, we will send you marketing emails. You can unsubscribe or change your preferences via the links provided in the emails or send a request to support@heyrosie.com. If you opt out of marketing emails, we will still send support emails related to your account.

• Texts from Rosie. If you provide your wireless number, you consent to Rosie sending you service text messages. However, we will only send you marketing text messages if you opt in. The number of texts you receive will depend on the Services you use and the information you request from us. 

Callers may receive texts from Rosie on behalf of the Subscriber they called. These texts are sent according to the Subscriber’s privacy practices. Please contact the Subscriber with questions or concerns. 

You can unsubscribe from text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.

• Your Device Settings. You can control the data we collect through cookies and related technologies by adjusting your device settings or your cookie preferences on the website.

• Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.

  
  

8. Notice of Privacy Rights

Rosie currently offers the Services in the United States and Canada. This section lists the privacy rights applicable to individuals under consumer privacy laws in the United States and Canada.

If you are a Caller, you must contact the Subscriber you called to exercise your privacy rights related to a conversation you had with an AI Receptionist. The notices in this section are provided to Callers as a courtesy only. The Subscriber you called is ultimately responsible for how it processes your Personal Information and for supporting your exercise of privacy rights. 

United States. For those in the United States, consumer privacy is governed by federal privacy laws covering specific industries or data uses and more than a dozen state laws providing consumer privacy rights. Residents of states like California, Colorado, Connecticut, Nevada, Utah, Virginia, and other states that offer privacy protections may be entitled to some or all of the privacy rights listed below:

• Right to know. Rosie provides the required information for a consumer’s right to know in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Information through the Services or via email. Each Subscriber is separately responsible for providing its Callers with an explanation for the right to know.

• Right to reasonable expectations. You can expect Rosie to collect, use, or disclose your Personal Information responsibly and not for any other purpose other than as stated at the time of collection or described in this Privacy Notice. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as required by law. You may withdraw your consent at any time with reasonable notice by contacting support@heyrosie.com. Subscribers must set expectations for their Callers separately. Please contact the Subscriber you called to change or withdraw your consent.

• Right to accuracy, and the right to correct your Personal Information. You can correct or update your Personal Information held by Rosie by updating your account or by contacting support@heyrosie.com. However, we do not make any guarantee that Personal Information contained in our Subscribers’ data (including information collected by AI Receptionists) is accurate. Rosie must rely on our Subscribers to ensure that the data we process on the Subscriber’s behalf is current, complete and accurate. Please contact the Subscriber you called if you become aware that your Personal Information processed through our Services is not accurate.

• Right to access your Personal Information. Callers should contact the Subscriber they called to request access to their Personal Information processed via an AI Receptionist. Others may submit a request to Rosie to receive a copy of their Personal Information held by us. We will provide copies upon request where required by law, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. Certain laws may limit the scope or frequency of requests we must fulfill.   

• Right to deletion. Callers should contact the Subscriber they called to request the deletion of their Personal Information. If Rosie collected your Personal Information for our own purposes, upon your request and when required by law, we will delete your Personal Information from our systems. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.

• Right to data portability. In some cases, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.

• No selling Personal Information. Rosie does not sell any Personal Information or share Personal Information with third parties for cross-contextual behavioral advertising purposes. Subscribers are free to sell or share Callers’ Personal Information according to the Subscriber’s own privacy practices. Please review the Subscriber’s privacy notice to learn more and to understand how to opt-out. 

• Limited use and disclosure of sensitive Personal Information. Rosie does not collect sensitive Personal Information, and in no case will Rosie use or disclose sensitive Personal Information for the purpose of inferring characteristics about a consumer. Subscribers are free to collect Callers’ sensitive Personal Information, through the AI Receptionist or other means. Please review the Subscriber’s privacy notice to learn more and to understand how to opt-out. 

• Right to non-discrimination. If you reside in a jurisdiction that extends a right to non-discrimination related to the exercise of privacy rights, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, (iv) retaliate against you as an employee, applicant for employment, or independent contractor; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised your statutory right unless permitted by law.

• Right to disclosure of certain information. You may have a right to request information about how we collect and use your Personal Information, such as (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting, using, disclosing, or selling that Personal Information, as applicable; and (iv) the categories of third parties with whom we disclose that Personal Information. Rosie does not sell or share your Personal Information, but if we did you could request two separate lists stating: (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) sharing for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.    

• Right to not be subject to automated decision-making and the right to opt out of profiling. Our Subscribers’ AI Receptionists leverage generative AI technologies that process data in a manner that may qualify as automated decision-making or profiling under privacy laws. Each Subscriber is responsible for this type of processing and for providing Callers with notice and a method to opt-out. A Caller can prevent their Personal Information from being processed in this manner by requesting human intervention through the Services or by discontinuing the call. 

• Right to restrict processing. You may have the right to request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object. Your right to restrict may be limited to Personal Information that is sensitive in nature, or that is sold or shared for certain purposes. Callers should contact the Subscriber they called to restrict processing of Personal Information collected through an AI Receptionist. 

• Right to object. You may have the right to request, under certain circumstances and where we are required to do so by law, that we limit our processing of your Personal Information as you request. 

• Right to disclosure of marketing information. If you are a resident of the State of California, California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California consumers to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.

• Health Data Rights. Rosie does not collect any health data. A Subscriber may choose to collect health data through the AI Receptionist or otherwise process health data through our Services. Some laws entitle consumers to certain details about health data collected about them, including (i) confirmation of whether the entity collects, shares, or sells the consumer’s health data and access that data, including a list of all third parties and affiliates with whom the entity has shared or sold the health data and a method to contact those third parties, (ii) a method to withdraw consent related to use of health data, and (iii) the right to have their health data be deleted. 

Canada. For users in Canada, the Personal Information Protection and Electronic Documents Act and other provincial privacy laws give Canadians specific rights regarding their Personal Information. The rights afforded under Canadian privacy laws are described below. 

• Right to know why your Personal Information is collected, used, and distributed. This Privacy Notice explains Rosie’s privacy practices for the right to know. We may provide additional notices about other ways we process Personal Information through the Services or via email. Each Subscriber is separately responsible for providing its Callers with an explanation for the right to know. 

• Right to expect us to collect, use or disclose Personal Information responsibly and not for any other purpose other than which you consented. Rosie sets your expectations in this Privacy Notice and collects express or implied consent at various stages of collection or processing for our own processing. You may withdraw your consent from Rosie at any time with reasonable notice by contacting support@heyrosie.com. Subscribers must set expectations for their Callers separately. Please contact the Subscriber you called to change or withdraw your consent. 

• Right to accuracy of your Personal Information. Rosie takes steps to reasonably ensure that the Personal Information we collect for our own purposes is accurate. However, we do not make any guarantee that Personal Information contained in our Subscribers’ data (including information collected by AI Receptionists) is accurate. Rosie must rely on our Subscribers to ensure that the data we process on the Subscriber’s behalf is current, complete and accurate. Please contact the Subscriber you called if you become aware that your Personal Information processed through our Services is not accurate.

• Right to access your Personal Information. Callers should contact the Subscriber they called to request access to their Personal Information processed via an AI Receptionist. Others may submit a written request to us at support@heyrosie.com to access their Personal Information collected by Rosie under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfil the request. If limited by law or potential infringement on another’s privacy rights, we may not be able to provide access to some or all of the Personal Information you request. If we must refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps that are available to you.

IMPORTANT NOTE: The Services are not currently marketed or intended for Subscribers or Callers located anywhere outside of the United States or Canada. Subscribers are prohibited from making the Services available to Callers in other jurisdictions. If Rosie later offers the Services in additional markets, we will update this Privacy Notice to include the necessary notices and disclosures required under the applicable laws governing consumer privacy in those additional markets.

9. Owned and Operated in the United States

Rosie is a United States company using technical infrastructure in the United States. We only market the Services for Subscribers to use to interact with Callers located in the United States and Canada. CALLERS AND OTHERS OUTSIDE THE UNITED STATES OR CANADA SHOULD NOT USE THE SERVICES. We do not warrant that the Services are appropriate or authorized for use in any other jurisdictions. Each Subscriber is responsible for determining whether its use of the Services complies with applicable laws. 

If you access the Services from outside the United States, please be aware that your Personal Information may be transferred to, processed, stored, and used in the United States or other jurisdictions. When your information is moved from your home country to another country, the laws and rules that protect your Personal Information in the country to which your information is transferred may be different from those of the country where you live. For example, if your information is in the United States, it may be accessed by government authorities under United States law. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this section.

10. Rosie Data Security

Rosie has implemented and maintains reasonable security measures to secure Personal Information on our Services from accidental loss and unauthorized access, use, alteration, and disclosure. All data is securely stored in a cloud environment and encrypted using AWS AES256 encryption. Rosie personnel are required to follow security protocols and are trained to handle sensitive data. Data and systems are subject to regular backups and audits. Our service providers are contractually bound to adhere to the same security protections. Rosie has policies and protocols in place to respond to security incidents in compliance with our customer agreements and applicable law. Our security measures are appropriate to the volume, scope, and nature of the Personal Information processed and designed to meet our duty of care. 

Subscribers are responsible for securely storing and processing Personal Data on the Subscriber’s information systems and through their use of our Services. We cannot guarantee the security of information transmitted over the Internet. Any data transmissions are at the risk of the person initiating the transfer.

The Services are owned and provided by Rally Commerce, Inc. dba Rosie.