1. Introduction
At Rooit Inc. (“Rooit,”“we,”“us,”or“our”), your privacy is top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections. We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.
To fulfill our commitment to respecting and protecting your privacy, we will adhere to the following principles:
1.We will inform you of the personal information that will be collected, and, where appropriate seek your consent to collect, process, use, or disclose your personal information.
2.We will identify the purposes for which we will collect and further process your personal information.
3.We will only collect information that is necessary to carry out the identified purposes of use.
4.We will use or disclose your personal information only for the purposes for which it has been collected, except with your consent, or as required or permitted by applicable law, and we will retain your information only as long as necessary to fulfill those purposes.
5.We will endeavor to ensure that your personal information is accurate, complete, and up-to-date.
6.We will implement appropriate technical and organizational measures to protect your personal information.
7.We will make our policies and practices for the handling of your personal information as transparent as is reasonably possible.
8.You will have access to your personal information and will be able to correct your personal information as appropriate in accordance with your rights under applicable law.
9.We will be accountable to you. We are interested in hearing your opinion regarding our compliance with these principles, this Privacy Policy, and applicable laws.
2. Purpose of This Privacy Policy
This Privacy Policy explains how Rooit will process and safeguard your personal information, and the rights and choices you have with respect to your personal information. This Privacy Policy applies to: personal information you provide us when you use the Rooit communication app (“Rooit App”), optional services made available within the Rooit App, and other apps that integrate with or work in conjunction with the Rooit App (collectively “Apps”); personal information we collect when you visit websites maintained by us relating to our Apps (“Websites.” Apps and Websites are collectively referred to as “Services”); and personal information about you provided by other users of the Service. This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").
To make our Privacy Policy easier to understand for non-native English users, we may provide translations in your native language as a reference. A Mandarin version is now available. However, in the event that any provision in the translations contradicts the English version of this Privacy Policy, unless otherwise specified, the Mandarin version takes precedence to the extent permissible under applicable law.
3. Types of Personal Information We Collect
a.What Personal Information Does Rooit Collect?
When you create an account and use Services, Rooit collects, uses, and transfers the following types of information:
i.Information Concerning Your Account
When you create a Rooit account in order to access the Services (an “Account”), Rooit will ask you to provide your phone number. This information is necessary because we may send a text message via SMS to the phone number you provide, as part of our ongoing efforts to detect and deter unauthorized or fraudulent use of or abuse of Services. This is also necessary for logging into Rooit on another mobile device. We may also use your registered phone number to provide you important information about Services.
We may also ask for your gender, birthday and a name to be identified as in the Services.
ii.Device Information and Access Logs When You Use Our Service
When you use Services, we may obtain and maintain certain electronic identification or log data that is automatically provided by your device such as: device type, OS type, IP address, browser information including type and language settings, device identifier, cookie data, advertising identifier or mobile application identifier.
This information is necessary as part of our ongoing efforts to detect and deter unauthorized or fraudulent use of, or abuse of, Services, as well as to provide you with customized options, and optimize the Service for your device. Also, please note that a third party advertising identifier may be associated with your Account through our internal identifier.
b.What Other Information Might Rooit Collect?
To improve the quality of Services, we provide additional functionalities, including the ability to access your Account from multiple devices, help you find friends via the Service, and to make Services more efficient, usable and enjoyable. If you choose to use such functionalities, we may ask you to provide the information below.
You may choose not to provide the following information, however, if you do so, there may be cases where you cannot use some parts of Services.
i.Location Information [OPTIONAL]
To use the Rooit App, you are not required to provide your location information (“geolocation data”). However, we provide features that utilize geolocation data for your convenience and to improve your user experience. Rooit will only collect your geolocation data in response to a request from you, and Rooit will delete the geolocation data once the relevant service has been provided to you. Rooit does not aggregate your geolocation data and does not record your geolocation history.
In other cases where we collect or use your geolocation data in the course of providing an Additional Service, we will provide you with prior notice and obtain your prior consent.
Furthermore, when you do not accept sending your geolocation data by your mobile device settings, geolocation data will not be sent to us.
ii.Contact Information for Customer Support [OPTIONAL]
There may be circumstances in which you might wish to contact us to seek our customer support. If you contact us via our Facebook fan page, we may obtain and maintain any information you choose to provide, including your name, contact info such as your email address, phone number, as well as information about your mobile device or personal computer such as its device type, and OS type. We will use this information to address and investigate the issues you have raised, to provide you support, and to improve our customer support service. We may process this information in connection with the assistance you have requested, the administration of your Account, and retain this information in accordance with the provisions of this Privacy Policy.
iii.Contact Information for Promotional Events and Customer Surveys [OPTIONAL] If you choose to participate in promotional events or surveys that Rooit offers from time to time, we may request your contact details (e.g., your name, mailing address, phone number, email address, gender and date of birth) in order to confirm your participation eligibility, enable you to fill out questionnaires, and to deliver any prizes you may win, and otherwise administer the event.
iv.Payment Information [OPTIONAL]
If you choose to purchase an Additional Service or use a fee-based Additional Service and pay for such Additional Service by a means other than in-app purchases via iTunes or Google Play, we may engage a third party service provider to collect and process your credit card information. We will use your credit card information only to process your purchase or use our fee-based service. Please note that we will not retain your credit card information beyond the period necessary to facilitate the relevant payment. Your credit card settlement will be handled by appropriate third party payment agencies.
c.What About Information I Create About Myself and Share With Others?
i.User-Generated Content [OPTIONAL]
In addition to the information described above, you may choose to set your profile information (e.g., profile picture, the phrase you choose to show under your status message, etc.) and show who you are to other Rooit users within Services. Furthermore, you may choose to create “user-generated content” such as text messages, photos, geolocation data, or the contact information of your Rooit friends, and share this user-generated content with other users. For some of the profile information, such as age and horoscope, you may choose whether or not to make it public. You may also choose how much or little of your user-generated content to share, and with whom you share it, when you create messages by selecting the recipients of your user-generated content.
Please note that the profile information and user-generated content you share with others can be copied, stored, or disseminated by the recipients and potentially accessed by unintended third party recipients due to the nature of digital data. We encourage you to be very attentive and cautious when you generate and share your personal information or content with others.
4. How We Use and Handle Your Information
a.How Does Rooit Use My Information?
To provide Services and any Additional Services, Rooit, as a data controller or joint data controller, uses your personal information for the following purposes in accordance with this Privacy Policy:
■for developing, providing, and improving our Services:
•to provide Services and any Additional Services to you and to allow you to transmit your user-generated content to other Rooit users;
•to allow you to use your Account on multiple devices and transfer your Account to another device;
•to help you find people that are already Rooit users so that you can connect using Rooit and, subject to your prior agreement, to allow other Rooit users to connect with you;
•to enable you to sync other applications offered by Rooit, Rooit affiliates, and Rooit business partners together with your Account and to share information between the applications you use;
•to respond to requests you may make to use Additional Services;
•to enable us to provide customer support, and to respond effectively to your inquiries and claims;
•to conduct user surveys;
•to notify you of any other important information regarding Services and any Additional Services, if necessary;
•to identify winners of promotional contests, to send gifts to those winners, and to deliver purchased products and services;
•to aggregate anonymized statistical data regarding Services and any Additional Services;
•to comply with applicable laws or legal obligations;
■for maintaining the security of Services or preventing unauthorized use:
•to verify your identity;
•to monitor, detect and deter unauthorized or fraudulent use of, or abuse of, Services;
•to verify yourself or to notify you in case any unauthorized use occurred;
■for personalization or advertisement delivery:
•to improve and/or optimize Services and any Additional Services; and
•to measure the effectiveness of advertisements that we place on the Internet or in other media.
■Research and innovate for social good.
We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, health and well-being.
■Advertisers.
We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we provide general demographic and interest information to advertisers (for example, that a brand-related question was chosen by a woman between the ages of 25 and 34 who lives in Taipei and likes software engineering) to help them better understand their audience.
If, however, we provide you with more specific purpose(s) of use either at the time we ask you to provide your personal information or through other means, then such notice will take precedence over the general purposes of use stated in Section 4.a of this Privacy Policy.
In principle, we obtain your consent when we process your personal information. If, however, permitted under applicable laws, we may handle your personal information when any of the following applies:
1)processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
2)processing is necessary for compliance with a legal obligation to which we are subject (e.g., when following the information disclosure orders based upon laws and regulations announced by government agencies);
3)processing is necessary in order to protect vital interests of yours or of another individual;
4)processing is necessary to investigate, prevent and take measures against illegal or suspected illegal acts; or
5)processing is necessary for the legitimate interests pursued by us or by a third party, except where such interests are overridden by your privacy related rights, interests, and freedom (including improvement of operations or systems, prevention of fraud, maintenance of security, marketing, and research performed by us).
b.How Does Rooit Protect My Personal Information?
To fulfill our commitment to respecting and protecting your privacy and the confidentiality of your personal information, Rooit has implemented appropriate technical and organizational security standards, including industry-standard safeguards to prevent unauthorized access or disclosure, misuse, alteration, or destruction of your information. Because no method of electronic transmission or method of data storage is perfect or impenetrable, we cannot guarantee that your personal information will be absolutely safe from intrusion during transmission or while stored in our systems.
To help protect your privacy and confidentiality of your personal information, we also need your help. Please do not share your password with others, or use the same passwords you use for other services. Also, please notify us in the event you suspect any unauthorized use of your Account or any other breach of security via our our Facebook fan page.
c.Where Is My Personal Information Transmitted and Stored?
To provide Services in a reliable and responsible manner, Rooit processes and stores your information on secure servers located around the world. There may be a possibility that the data protection level in those countries do not reach to data protection law in your country or region requires. All such transfers are performed in accordance with the requirements of applicable law.
d.How Long Does Rooit Keep My Information?
Rooit retains the personal information you provide while: your Account is active; for the length of time needed to fulfill any of the applicable purposes of use described in this Privacy Policy; or to comply with applicable laws and regulations.
We may retain your personal information following the closure or termination of your Account if retention is reasonably necessary:
•to comply with applicable laws, regulations or legal obligations;
•to provide and complete customer support service;
•to resolve disputes between or with Rooit users, for the duration of the applicable limitation period; or
•to detect and deter unauthorized or fraudulent use of, or abuse of, Services.
e.Does Rooit Use Outside Service Providers or Agents?
To provide Services, it sometimes is necessary for Rooit to enlist third party service providers to process user data, which may include your personal information. These service providers include payment agencies, delivery agencies, providers of customer support services, and so on. These service providers may store your data in countries or regions where do not have the data protection laws at the level that is required in your country or region. In such a case, we will take measures to protect your personal information such as entering into a contract regarding data protection. We strictly evaluate all such third party service providers. We take reasonable steps to ensure that they have established appropriate and secure information administration and organizational control systems. We impose binding contractual obligations on such service providers to comply with applicable laws and regulations regarding the processing of personal information. We also require that they access your personal information only to the extent necessary to perform tasks in accordance with our instructions, and for no other purposes.
f.Does Rooit Give My Information to Third Parties?
Other than as described in this Privacy Policy and other applicable privacy policies or addendums, Rooit will not provide your information to any third parties without your consent, unless we believe in good faith that we are required or permitted to do so under applicable laws.
g.Does Rooit Use Cookies or Other Similar Technologies?
We use cookies and similar local storage technologies.
A cookie is a small text file that is stored on your computer when visiting a website. This text file stores information that can be read by the website when visiting it again at a later date. Some of these cookies are necessary because otherwise the site is unable to function properly. Other cookies are convenient for the visitor: they remember your username in a secure way as well as your language preferences, for example. Cookies mean that you do not need to fill out the same information each time you visit a website.
We use cookies:
•to help us maintain your session when you use Services and/or any Additional Service;
•to enhance security of our systems;
•to store your preferences and provide customized services to you; and
•to help us understand how people use Services and to improve them.
We also use the following third party cookies on the Website:
•Google Analytics
By continuing to use Services, you consent to our use of cookies and similar technologies in accordance with this Privacy Policy.
Most Internet browsers allow you to control whether or not to accept cookies. If, however, you deactivate cookies or limit the ability to set cookies, you may not be able to obtain the full benefit of the Website or access all of its functions, which may limit your overall user experience.
h.Does Rooit Use Third-Party Modules?
Rooit may use third party advertising agencies to place advertisements on the Internet or in other media. To measure the effectiveness of advertisements and determine how much to pay to advertising agencies, we install third-party modules within Apps. We may also install third-party modules within Apps in order to help us understand how Services and/or Additional Services are being used.
5. Your Choices, Your Rights
There is a possibility that Rooit may obtain personal information relating to individuals who are currently not users of Services. Please note that, regardless of whether or not you are a user of Services, you have the choices and rights set out in this section if we hold your personal information.
a.How Do I Control My Information?
Subject to applicable law (including any exemptions or derogations under such law), you may have a right to access your personal information, to have errors in your personal information rectified, to object to the processing of your personal information on legitimate grounds, data portability, etc. You can exercise some of these rights directly within the Rooit App at any time.
To exercise any of your other rights under applicable law, you may contact us via private message on our Facebook fan page. Upon verification of your identity, we will respond to your request within a reasonable period of time, and in accordance with relevant law. If, however, permitted under applicable laws, we may not be able to respond to your request when any of the following applies:
•disclosure is likely to harm the life, body, property, or other rights or interests of yours or another individual;
•disclosure is likely to seriously impede the proper execution our business;
•disclosure violates other laws; or
•when you failed to verify your identity upon your disclosure request.
If you no longer wish to use the Service or if you no longer wish to consent to Rooit’s collection and use of your personal information, you may choose to delete your entire Account directly by calling us. We will delete your information in accordance with Section 4.d.
If you exercise any of your rights permitted under the applicable law, we may charge a fee taking into account the administrative costs of responding to the request, in accordance with the procedures defined separately.
b.What If I Change My Mind?
If you change your mind regarding how much information you wish to continue to share or disclose on Services going forward, you can always change the settings in the Rooit App relating to, for example:
•your profile information (e.g., your profile picture, your display name, or a personal phrase shown under the status message);
•whether to block or unblock certain Rooit users.
6. Other Important Information
a.A Special Note about Children in the United States of America or in Europe
The Service is intended for a general audience and is not directed at or intended to be used by minors under the age of 13 (under the age of 16 in Europe) (“Children”).
We understand the special necessity to protect Children's online privacy, and we do not knowingly collect any personal information from Children.
If, however, you believe we have collected any personal information from Children, then please let us know via our Facebook fan page.
If we learn that we have inadvertently collected personal information from Children, we will deactivate the relevant Account(s) and will take reasonable measures to promptly delete such personal information from our records.
b.Questions/Comments/Concerns
If you have any questions, comments, or concerns about this Privacy Policy or our other privacy policies or practices, please contact us via our Facebook fan page or by writing to:
Subject: Rooit Privacy Policy Related
Rooit Inc.
3F, No. 12, Zhouzi Street, Neihu District, Taipei City, 114