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Privacy Policy

Roqad Privacy Notice


We are delighted that you have interest in our company. Data protection is a high priority for Roqad (“we”, “us”, “our” or “Roq.ad”).  


This privacy notice (“Notice”) describes the nature, scope, and purpose of the personal data we collect, use and process on the Roqad website, through our enterprise services, our pixel, and through any other means through which you may interact with us (the “Services”).  In addition, this Notice also describes your rights and how you can access them.  If you are a resident of California please see additional disclosures at the end of this Notice.


About Roqad

Roqad delivers identity solutions across North America and Europe for the marketing and advertising sectors, including data onboarding and probabilistic identity graph generation. It’s machine-learning algorithms predict that various identifiers represent one person, and group them together so that marketers can reach the people they want to wherever they are consuming ad supported content, including through targeted advertising. 

How We Protect Your Personal Data

Roqad has implemented numerous technical, administrative and organizational security measures designed to protect personal data processed through this website as well as through the various data collection methods Roqad uses in connection with providing its Services. However, Internet-based data transmissions may in principle have security gaps, so absolute protection is not guaranteed and no website, application or platform is 100% secure.   

Data Protection Officer

 

  • ePrivacy GmbH represented by Prof. Dr. Christoph Bauer
  • Burchardstrasse 14, 20095 Hamburg

For all requests concerning the security of your data you can contact our privacy team and data protection officer at privacy@roq.ad.

 

Name and Address of the Controller

 

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and the United Kingdom are:

  • Roq.ad GmbH
  •  Karl-Liebknecht-Str. 32, 5th floor
  • 10178 Berlin, Germany
  • +49 172 589 7954
  • privacy@roq.ad
  • www.roq.ad

Overview 

I. Personal Information We Collect

II. How We Collect Personal Information

III. How We Use Personal Information We Process 

IV. Who We Share Information With

V. Your Rights and Choices

VI. Information for EU Users

VII. Additional Information 

     a. On Subscriptions to our Newsletters

     b. On Job Applicants

     c. On Third Party Technologies

VIII. Storage and Retention 

IX. Changes to this Privacy Notice

X. California Privacy Addendum

______________________________________________________________ 

I. Personal Information We Collect

Collection of General Data and Information

You do not need to provide your personal information in order to access the Roqad website.  However, use of our special enterprise services via our website may require us to process your personal data.  

When you interact with Roqad website, we collect the following information: 

  • Internet or other electronic network activity information, including, but not limited to, browser types and versions used, the operating system used by your computer, mobile or other device (“Device”), the Internet service provider of the accessing system, your browsing history, search history, and information (such as time and date of access) regarding your interaction with an internet website, application, or advertisement, including the Roqad website.
  • Identifiers, such as your name, email address, digital identifiers like first and third party cookies, mobile advertising identifiers, connected television identifiers and IP address, including the identifiers assigned by a third-party that represent a specific web interaction, application usage, device, or pseudonymized information.
  • Any other similar data and information that may be used in the event of attacks on our information technology systems.
  • Demographic information, such as your age and gender (in the U.S. only)
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Geolocation data.
  • Professional or employment-related information.
  • Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 
This general data and information are stored in the server log files.

II. How We Collect Information

Cookies

The Internet pages of Roqad uses cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, Roqad can provide the users of this website with more user-friendly services and customized advertising that would not be possible without the cookie setting.

You may, at any time, delete or prevent the setting of cookies through our website by adjust the settings in your Internet browser. If you deactivate the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

Our cookies are set for 365 days. Internally we remove all data after 90 days. We stop using user’s data after 30 days.

Tracking mechanism and the data types used

Roqad technology may track users visiting websites with simple js script that allows it to save common HTTP request data including: a browser’s cookie ID, a browser’s user agent, an IP address of the browser, the visited URL, browser’s language, referrer URL.

For more information on our Identity Graph please see: https://roq.ad/identity-graph.

We may also use tracking technologies in our newsletter. For more information, please see here.

Website Forms

We collect your information when you submit it us on our website contact forms or when you email us.  

III. How We Use Information We Collect

We use the personal information we receive through our Services to generate cross-device graph, and to generate targeted advertising on behalf of our advertiser customers. The graph includes only IDs (including IP addresses) connected into clusters indicating our predictions for specific user identifiers that are representative of the same person.

Roqad also uses information we collect to: (1) deliver the content of our website and Services, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. 

Roqad participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Roqad’s identification number within the framework is 4.

 

IV. Who We Share Information With

Roqad shares information, including identifiers that represent individual users (including those with corresponding referring websites or applications where the Identifier was developed) with clients, which includes publishers, advertisers, other ad technology companies and advertising agencies, and prospects to its enterprise onboarding and identity graph services.

 

V. Your Rights and Choices

You may have the rights below, depending on the applicable laws in your jurisdiction. 


Right to Opt-Out

Right to Opt-Out (Cookie IDs)

Mobile applications, connected televisions, web browsers, and even specific applications and websites (“Publishers”) on those devices operate with different identifiers even though they may be on the same device. This is similar to how different websites might see you logged in as different versions of yourself (one may have a middle initial, one may have an older email, etc.). You have the right to opt out of Roqad’s use of your identifiers, including for data sharing and sales, targeted advertising and profiling in accordance with applicable laws. 

Note that you will need to contact each Publisher separately to exercise any right to opt out you may have with these Publishers. You can request a list of the identifiers we have connected to your, so that you may opt-out individually with other providers, including those who created the identifier. 

If you are interested in opting out on your computer or mobile web browser, please visit the “Web Browser Opt-out” section below. 

Web Browser Opt-out

Roqad’s opt-out information can be found in our Privacy page here. 


PLEASE NOTE:

The Roqad web browser opt-out works by replacing your unique cookie ID with a generic opted-out value or by flagging your cookie ID so that we know that you have opted-out of future processing. If you clear your cookies or delete your device’s content cache, we will no longer have the information needed to recognize your device as having opted-out.  

Right to Know

You have the right to know whether or not Roqad is processing your personal information and the right to know the specific pieces of personal information Roqad has about you. 

Right of Access

You have the right to access the personal information that Roqad processes about you, including: the purposes of the processing; the categories of personal information collected, the recipients or categories of recipients to whom the personal information have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the period for which the personal information will be stored, or, if not possible, the criteria used to determine that period.

Right to Correction

You have the right to request that we correct any inaccurate personal information we may have about you.  

Right to Erasure (Right to be Forgotten)

You have the right to request that we delete your personal information if that information is no longer necessary for the purposes for which they were collected or otherwise processed, where you have withdrawn consent or where there is no other legal ground for the processing. 

Right of Restriction of Processing

You have the right to request that we restrict the processing of your personal information in certain circumstances:

  • If you object to a processing based on our legitimate interest, we will restrict all processing of that information pending the verification of the legitimate interest.
  • If you have claim that your personal information is incorrect, we must restrict all processing of such data pending the verification of the accuracy of the personal data.
  • If the processing is unlawful, you can request the restriction of the use of your personal information. 
  • If the information is no longer needed for the purpose for which it was collected, but is required to comply with our legal obligations. 

Right to Data Portability

You have the right to request a copy of your personal information that is collected by automated means based on your consent or based on an agreement with us.  You may also request that this information be transferred to another controller, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

Right to Object to Processing Based on Legitimate Interests 

You have the right to object to processing of your personal information that is based on our legitimate interests. We will not continue to process your personal information unless we can demonstrate legitimate grounds for the process which overrides your interest and rights or due to legal claims. 

If Roqad processes personal data for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If you the Roqad to the processing for direct marketing purposes, Roqad will no longer process the personal data for these purposes.

Right to Withdraw Data Protection Consent

You have the right granted to withdraw your consent to processing of your personal data at any time.

Exercising Your Rights

If you want to exercise any of the rights above, please contact privacy@roq.ad.

Verifying Your Identity

In order to process your request, we may need to verify your identity to ensure you request is authentic by asking for reasonable data necessary for your response to your request. 

VI. Information for EU Users

Legal Basis for Processing

Consent 

We rely on consent for the processing of personal information collected for use in connection with our Identity Graph. 

Performance of a Contract
For our customers, we also process personal information when necessary to do so for the performance of a contract to which you are a party, for example, when processing operations are necessary for the supply of goods or to provide any other service. 

Compliance with Legal Obligations
We process personal information based on our need to comply with our legal obligations when necessary to do so for tax and other related purposes. 

Protection of Vital Interests
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. 

Legitimate Interests
We rely on our legitimate interests for processing personal information related to our collection and use of personal information in our enterprise sales and marketing efforts and in relation to the personal information of our employees, contractors, vendors, partners, prospective employees, and others with whom Roqad may endeavor to have a business relationship. 

Location of Information 

Roqad stores all EU data it collects in the EU. 

UK data is transferred to the EU and processed based on an ongoing equivalency agreement between the UK and EU member states. 

Roqad may transfer cookie IDs or MAIDs, hashed email addresses, IP Addresses, Connected TV IDs, and such other data that represents a user or household to its enterprise customers (advertisers, MarTech firms, brands, eCommerce providers, ad agencies, or publishers,.) as part of the generated cross-device graph and onboarding services.  Those customers may be located outside of the EU.  Whenever we share personal information with customers located outside of the EU, we do so pursuant to Standard Contractual Clauses.  


VII.   Additional Information

A. On Subscription to our Newsletters

On the website of Roqad, users are given the opportunity to subscribe to our company’s newsletter. You may be asked to provide your name, company name and email address when you sign-up.

You may only receive our newsletter if you:(1) have a valid email address and (2) register for the newsletter. 

During the registration for the newsletter, we also store the IP address of your device, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the email address of a data subject at a later date. 

The personal information collected as part of a registration for the newsletter will only be used in connection with your newsletter subscription.  You may terminate your subscription to our newsletter at any time by clicking the unsubscribe link in the newsletter or by unsubscribing on our website.

Newsletter Tracking

The newsletter of Roqad contains tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Roqad may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects.

Personal information collected in the tracking pixels contained in the newsletters are stored and analyzed in order to optimize the newsletter communication and design, as well as to adapt the content of future newsletters even better to your interests. This personal information will not be passed on to third parties. You are at any time entitled to revoke consent by [insert the opt-out procedure, e.g. “click unsubscribe in the email.”). After a revocation, this personal information will be deleted by us. Roqad automatically regards a withdrawal from the receipt of the newsletter as a revocation.

B. On Job Applicants

We collect and process the personal information of job applicants in order to process your job application and to execute an employment agreement with you in the event you are hired. Once you are hired, the collection and use of your personal information shall be treated in accordance with our employee privacy notice.  If no employment contract is concluded, the application documents shall be automatically erased two months after notification of the refusal decision, unless we are required to retain that information to comply with our legal obligations (e.g. for compliance with the General Equal Treatment Act (AGG)).

C. On Third Party Technologies

We include third party digital tracking technologies on our website and receive this data through our enterprise services, this section provides you more information about these technologies. 

Data Protection Provisions about the Application and Use of Meta (formerly known as Facebook)

On this website, the controller has integrated technologies provided by Meta. Meta is a social network. For more information on Meta’s privacy practices see https://www.facebook.com/privacy/policy/. 

The operating company of Meta is Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, D04 X2K5 Ireland.

We use a Facebook plug-in on our website.  An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. When you interact with Facebook’s plug-in, and you are also logged-into Facebook, Facebook will receive information about your use of our site. 

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.

Data Protection Provisions about the Application and Use of Google Analytics (with anonymization function).  To understand more about Google’s privacy practices see https://policies.google.com/privacy.

On this website, Roqad has integrated Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of Google Analytics is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on your device. The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under https://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/. 

Data Protection Provisions about the Application and Use of Google Remarketing

On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.

The operating company of the Google Remarketing services is the Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.

Google Remarketing sets a cookie on your Device. With the setting of the cookie, Google can recognize you when you visit our site. Google receives personal information, such as the IP address or the surfing behaviour of the user, which Google uses, inter alia, for the insertion of interest relevant advertising.

The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

You may object to the interest-based advertising by Google by clicking here: https://www.google.de/settings/ads and updating your settings on each browser. 

Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/. 

Data Protection Provisions about the Application and Use of Google-AdWords

On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google.

If a data subject reaches our website via a Google ad, a conversion cookie is filed on your device. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages were called up on our website.

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.

The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link https://www.google.de/settings/ads and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/. 

Data Protection Provisions about the Application and Use of LinkedIn

We use the Linked-In plug-in on our website. For Linked In’s privacy notice see https://www.linkedin.com/legal/privacy-policy.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For privacy matters outside of the UNITED STATES LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

When you interact with LinkedIn’s plug-in, LinkedIn gains knowledge of what specific sub-page of our website you visited. If you are logged into LinkedIn when using our website, LinkedIn will receive information about your visit regardless of whether you click on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable, you can log out of LinkedIn before visiting our website.

LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from email messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy. The LinkedIn Cookie Policy is available under https://www.linkedin.com/legal/cookie-policy. 

Data Protection Provisions about the Application and Use of X (formerly known as Twitter)

On this website, the controller has integrated components of X.

The operating company of X, Corp. formerly known as Twitter, 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.  

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a X component was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding X component of X. Further information about the X components is available under https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, X gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the X component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on X, X detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the X component and associated with the respective X account of the data subject. If the data subject clicks on one of the X buttons integrated on our website, then X assigns this information to the personal X user account of the data subject and stores the personal data.

X receives information via the X component that the data subject has visited our website, provided that the data subject is logged in on X at the time of the call-up to our website. This occurs regardless of whether the person clicks on the X component or not. If such a transmission of information to X is not desirable for the data subject, then he or she may prevent this by logging off from their X account before a call-up to our website is made.

The applicable data protection provisions of X may be accessed under https://twitter.com/privacy?lang=en. 

VIII. Storage and Retention

Routine Erasure and Blocking of Personal Data

Roqad shall process and store the personal data of you only for the period necessary to achieve the purpose of storage, or otherwise in compliance with our legal obligations. 

Period for Which the Personal Data Will Be Stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

IX. Changes to this Privacy Notice

From time to time, we may update this Privacy Notice.  If we make changes that are material or if they could have an impact on the choices, you made or your marketing preferences, we will notify you. 

X. CALIFORNIA PRIVACY ADDENDUM

If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with certain rights regarding your personal information, including the right to know about personal information collected, disclosed, collected, shared or sold; the right to request that we delete personal information that we have collected from you; the right to correct your inaccurate personal information, the right to opt-out of the sale or sharing of your personal information; and the right not to be discriminated against for exercising your rights. These rights are subject to certain exceptions. You may also review our general privacy policy  to learn more about how we protect your information.

Collection of Personal Information

Through direct connections to consumers, a network of publisher partners, and via data brokers and aggregators, we may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We have collected the following categories of personal information about you over the past 12 months:

  • Internet or other electronic network activity information, including, but not limited to, browser types and versions used, the operating system used by your computer, mobile or other device (“Device”), the Internet service provider of the accessing system, you browse history, search history, and information (such as time and date of access) regarding your interaction with an internet website, application, or advertisement, including the Roqad website.
  • Identifiers, such as your name, email address, digital identifiers like first and third party cookies, mobile advertising identifiers, connected television identifiers and IP address, including the identifiers assigned by a third-party that represent a specific web interaction, application usage, device, or pseudonymized information.
  • Any other similar data and information that may be used in the event of attacks on our information technology systems.
  • Demographic information, such as your age and gender (in the U.S. only)
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Geolocation data.
  • Professional or employment-related information.
  • Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We collect the personal information listed above from the following sources:

  • From you directly.
  • Service providers and contractors who collect information on our behalf.
  • Your operating device (such as your computer or mobile device) and your web browser.
  • Analytics providers.
  • Third-party advertising networks.
  • Data brokers and aggregators. 


Disclosure, Sharing or Sale of Personal Information

In the last 12 months, we have disclosed, shared or sold the following categories of personal information subject to the CCPA:

  • Identifiers, such as your name, email address, digital identifiers like cookies, mobile advertising identifiers, connected television identifiers and IP address.
  • Characteristics of protected classifications under California or federal law, such as your age and gender.
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
  • Geolocation data.
  • Professional or employment-related information.
  • Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may have shared or sold any of the information listed above with:

  • Advertising and analytics providers.
  • eCommerce Providers.
  • Digital Publishers.

We disclose your personal information to the entities listed above for the following purposes:

  • To provide our customers with our services.
  • To improve our services.
  • Compliance with our legal obligations.
  • Any other purpose described in our privacy policy.

Your Rights

If we maintain personal information about you that is subject to CCPA, you may exercise certain rights in connection with this data if you are a California resident. In addition to the rights described above, you may also have the right to:

Right to Know

California residents have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months (“Right to Know”).  Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • The categories of personal information that we have disclosed for a business or commercial purpose.
  • Our business or commercial purposes for collecting or selling personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (i.e., a data portability request).

Right to Opt-Out of Sale

The CCPA provides California residents with the right to opt-out of the sale of their personal information. You may opt-out of the right to sale by clicking here.

Right to Delete

California residents have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and verify your request, we will delete (and direct our service providers/vendors to delete) your personal information from our records, unless an exception applies.

Right of Correction 

The CCPA provides California residents with the right to correct your inaccurate personal information that we have. 

Right to Nondiscrimination

The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights.

Shine the Light

California’s Shine the Light law permits you to request what personal information is shared with third parties by us and our affiliates, if that personal information is shared for direct marketing purposes.   

Exercising Your Rights

If you are a California resident and wish exercise your privacy rights, you may submit a request by us by email at privacy@roq.ad.

When you submit a request, we will verify your identity by asking you to provide reasonable information that could include your name, the email address, and applicable digital identifiers. We will verify your identity by matching the information you provide with what we have on file for you. We may ask you for additional information to verify your identity or to comply with your request.

Authorized Agent

You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.

Contact for More Information

ePrivacy GmbH represented by Prof. Dr. Christoph Bauer

Burchardstrasse 14, 20095 Hamburg, Germany

If you wish to contact us regarding this California Privacy Notice, you may do so through the following methods:

  • By email at privacy@roq.ad
  • By calling us at +49 172 589 7954

Privacy Notice Date Updated: 7th of June, 2024.

 

Definitions

The data protection declaration of Roqad is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use the following terms:

Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Personal Data/Personal Information

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.