ROLO - Privacy policy

(Last Updated: April 06, 2018)

ROLO (“Rolo App”, “Rolo-App”, “Rolo”, “ROLO”, “Service”) refers to the android application named ‘ROLO’ and the website https://www.getrolo.in developed by Netmine Mobile Innovations Private Limited ( “we”,  “our”, “us”,  “Netmine”, “Company”).

We respect the privacy of our users and are fully committed to protect personal information that users (‘users’, ‘you’ or ‘your’) share with us in connection with the use of Rolo.

This Privacy Policy (the “Privacy Policy”) is intended to describe our practices regarding the information we may collect from you when you use Rolo, the manners in which we may use such information, and the options and rights available to you. Capitalized terms which are not defined in this Privacy Policy, shall have the meaning ascribed to them in our Terms of Use (“Terms”) located at https://www.getrolo.in/termsandconditions.

This Privacy Policy does not apply to the practices of companies that we do not own or control or to individuals whom we do not employ or manage.

Table of Contents

  1. About the Service
  2. User Consent
  3. A Note about Children
  4. Changes to the Privacy Policy
  5. Information We Collect
    1. Information You Provide To Us
    2. Information We collect as You access and use Rolo
    3. Aggregate Information
    4. Information Third Parties collect about you
  6. How do We use the information We collect?
  7. How do We protect the information We collect?
  8. What Choices do You have regarding Your Personal Information?
  9. GDPR Requirements
  10. Questions

1. About the Service

Rolo is a contact manager that you can use to drive productive interactions  and relationships with your contacts. Rolo also helps you stay in touch with your contacts. In order to do so, You will ‘connect’ with contacts you choose and who also wish to connect with you. After you connect, Rolo will automatically update you of any changes your connections make to their contact information and vice-versa.

2. User Consent

By downloading, installing, accessing or using Rolo, you expressly consent to be bound by the terms and conditions set forth in this Privacy Policy, including but not limited to, the collection, processing, use and disclosure of your information. You represent and warrant that you have all rights necessary to submit such information. If you are using Rolo for an organisation, you consent to the terms of this Privacy Policy on behalf of that organisation. You represent that you have the legal authority to consent to the terms of this Privacy Policy on behalf of the organization and to be bound by its terms. If you are acting on behalf of a company or entity, you represent that you have the authority to bind such entity.

If you do not understand or you do not agree to be bound by any term hereof, you may not download, install, access or use Rolo, and must promptly and permanently remove Rolo completely from your systems and devices and cease any and all use thereof.

3. A Note about Children

Our Services are not directed toward minors. To use Rolo, you must be over the age of 13. We do not knowingly collect personal information from anyone under the age of 13.

4. Changes to the Privacy Policy

We reserve the right to update this Privacy Policy at any time. When we do, we will revise the updated date at the bottom of this page. Your continued use of Rolo after we have amended the Privacy Policy, will constitute acceptance of and agreement to be bound by those amendments.

We encourage users to frequently check this page for any changes to stay informed about how we are helping protect the Personal Information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

5. Information We Collect

We may collect Personal Information and Non-Personal Information, as defined below, from our Users

  • Personal Information
    Information that allows someone to identify you or contact you, either alone or in combination with other information, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to your Personal Information
  • Non-Personal Information (or) Anonymous InformationInformation that is not associated with or linked to your Personal Information. Information that, by itself, does not permit the identification of individual persons.

We may collect the following types of information from or concerning you or your mobile phone device, which may include Personal Information.

  1. Information You provide to us
    We receive and store any information you provide to us or permit us to access. You can choose not to provide us with certain information, but then you may not be able take advantage of some or all of Rolo’s features.

For example, when you use Rolo, we may collect the following information from you:

  • Personal Information
    • We may collect Personal Information from you, such as your full name, email and mailing address, professional title, company name, educational details, date of birth, phone number when you start using Rolo or when you update your profile on Rolo.
    • If you provide us feedback or contact us via email, we will collect your name and email-address, as well as any other content included in the email, in order to send you a reply.
    • If you provide us feedback from within the app, we (or our third party service provider) will collect the information you provide along with your name, email id and other Personal and Non-personal Information to help us process your feedback and respond.
  • Third Party Account Information
    • Rolo incorporates content from Third Party platforms, such as Facebook, Google and Twitter (“Third Party Services”). In order to connect your account on ROLO to your accounts and contacts on those services (“Third Party Accounts”), we may ask you for account information for those services. If you provide your third-party account credentials to us, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us if you authorize such transmissions, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy. This Privacy Policy does not apply to the practices of such Third Party Services. We are not responsible for the privacy policies and/or practices of these Third Party Services, and, to the extent you access them, you are responsible for reading and understanding the privacy policies of those Third Party Services. This Privacy Policy only governs information that is collected from those services. We don’t store your passwords for those Third Party Accounts.
  • Information about Others
    • When you use the Rolo Android App, we will collect Contact Information from your address books. “Contact Information” means information about your contacts that we collect from your address book(s), your email, your visiting cards or information that you provide about your contacts directly to Rolo, which includes but is not limited to, first name, last name, birth date, age, email address, gender, company, job title, photos, images of visiting cards, website urls, social network handles, instant messenger handles and physical address.
    • We make available a feature for certain email services whereby we will show you emails you have exchanged with a particular contact. This is a feature for which you must choose to give permission to access the appropriate account via the Rolo App. When this feature is activated, we copy an excerpt of your email with a link to the full email to our servers. We do not collect or store passwords to enable this feature.
    • When you link a Third Party Account to your ROLO account (by signing in using your Third Party Account information or otherwise), we may collect and store publicly available personal information about your contacts and friends, available from those Third Party Websites. This information may include their photo, name, email address,  groups, education history, company history, relationship summary, websites, special dates, status messages and other content you have access to when you access such profiles on those Third Party Websites. You may also be able to invite other users to the Service by providing us with their personal information.
    • If you choose to invite others to Rolo using our invite feature, you may be prompted to enter your friend’s email address or phone number. We collect and store this information to track the installation of the invitee and provide referral credits to you.
  • Other Information
    When you use Rolo we may collect other information from you as below
  • Call Logs and SMS Logs – If you grant us permissions, we collect a history of all your calls and SMS messages to restore when you install Rolo on a different device.
  • Notes about contacts – Rolo will allow you to make notes about your contacts. We store these notes as part of our backup to restore when you install Rolo on a different device.
  • Reminders about contacts – Rolo will allow you to create Reminders for contacts. We store these reminders as part of our backup to restore when you install Rolo on a different device.
  • Rolograms – Rolo will allow you to send free messages to other Rolo Users. These free messages, called Rolograms will appear in line with SMS messages but will be differentiated. We collect a history of Rolograms as part of our backup to restore when you install Rolo on a different device.
  • Information We collect as You access and use Rolo
    • Our web site (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol(IP) address, domain name, and/or a date/time stamp for your visit. This information may be used to help you when you request any help from us.
    • Our servers (which may be hosted by a third party service provider) collect information about mobile device identifier, mobile device brand and model, operating system type and version, screen resolution, network provider, language and information about your use of Rolo. This is used to help you when troubleshooting issues reported by you.
    • In addition to any Personal Information or other information that you choose to submit to us, we may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with Rolo (” Usage Information”). We use Analytics tools such as Firebase Analytics and Facebook Analytics to collect information about the way you use Rolo.  These analytics tools also receive this information, and their privacy policy governs their use of it.
    • We may also use technologies to collect information about your usage in context of errors and crashes in the app, in the form of logs. In the case of crashes, we use Crashlytics (part of Firebase) to collect detailed information about the software state that resulted in the crash. This information is used for debugging purposes only and does not include any personal information. Occassionally, our support personnel may request you to share diagnostic data for the purpose of troubleshooting. This diagnostic data snapshot includes additional details including contact data to help with troubleshooting. This snapshot is transmitted securely (over HTTPS) and stored securely for diagnosing the issue reported by you.
    • We also use cookies, tracking pixels and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following Internet browser help file directions. Additionally, we or a third party service provider we have engaged, may place or recognise a unique cookie or pixel on your browser or emails to enable you to receive customised or enhanced services.
  • Aggregate Information
    We collect statistical information about how both unregistered and registered Users, collectively, use the Service (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and is not tied back to you or your account.
  • Information Third Parties collect about You
    Third Party Websites that you choose to link your ROLO account to may also collect information that we are not aware of. You should consult their applicable terms of service and privacy policies for more information on their data collection practices.

6. How do We use the information We collect?

  1. Use Of Non-Personal or Anonymous Information – We may use Non-Personal Information to analyse usage patterns so that we may enhance our Services. Netmine reserves the right to transfer and disclose to third parties or otherwise use Non-personal Information at its sole discretion. Non-Personal Information includes information collected directly from the Users or information extracted from Personal Information by excluding information that could identify you personally.
  2. Use Of Personal Information and Contact Information
    1. General Use – In general, we may use the Personal Information and Contact Information we collect from you to help us serve you better. For example, we may use your Personal Information and Contact Information to
      1. facilitate the creation of and secure your account on our system;
      2. identify you as a user in our system;
      3. provide improved administration and quality of experience of our Services;
      4. provide the Services you request; or respond to your requests in any other manner as appropriate;
      5. send you a welcome e-mail to verify ownership of the e-mail address provided when your account was created;
      6. call you or send you an SMS message to verify ownership of phone number provided when your account was created;
      7. send you administrative e-mail or SMS notifications, such as security,support and maintenance advisories;
      8. respond to your inquiries related to employment opportunities or other requests;
      9. We may use your information to personalise and improve Rolo and to analyse how Users utilise Rolo. Registered Users may have some of this information associated with their accounts. Unregistered Users will not have this association, but information concerning their use of Rolo may be gathered through the use of cookies and stored by us. We may also use Personal Information and non-Personal information for purposes including responding to your requests for information, product, and services; customizing or personalizing content or advertising in Rolo and elsewhere on the Internet; providing you offers and information we think may be of interest to you; operating and improving our Service; and for other purposes disclosed at the time of collection.
      10. send you email or SMS to obtain feedback about Rolo; and
      11. send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Rolo.
    2. To Provide Rolo’s Features – We may use the Personal Information and Contact Information we collect from you to provide the functionality delivered by Rolo. This usage includes but may not be limited to the following.
      1. We may use your Contact Information to combine multiple contact information of a friend from different sources to a single meaningful contact. For example, we may help you combine phone numbers from one source with email id and occupation from another source to create a complete view.
      2. Rolo provides a built in ability to display call logs and SMS logs. In addition, Rolo allows you to create a backup of all call logs and message logs. Call logs and SMS logs information will be used to either display them to you or provide you with insights about how frequently you interact with a contact.
      3. Rolo allows you to send free IP messages (Rolograms) to other Rolo users, if this feature is enabled. Rolo also lets you backup Rolograms.
      4. Rolo will backup your contacts and notes and reminders. These backups are stored on Our servers.
      5. Rolo helps you stay in touch by connecting with contacts you choose and who also wish to connect with you. Such contacts (your Connections) can view Your Contact Information and any information that is part of your profile on Rolo. Any updates you make to your Profile will also be available to your Connections. You can stop these updates by disconnecting with those contacts.
      6. Rolo uses a proprietary algorithm to surface emails that are very similar to the one you are reading. We use the Gmail API for this feature. When you are viewing a contact’s profile, we also show emails you exchanged with that contact.
      7. Rolo may retrieve and display information that your contacts provide on social networks that you connect to Rolo.
      8. Rolo may use information about your contacts to help you invite them to Rolo.
    3. Contacts Database – We may combine the Contact Information we collect to create databases and data sets which include enhanced Contact Information.
      1. We may use the Contacts Database to provide certain features to Users. For example we may suggest additional contact information for one of your contacts based on their phone number or email id that is available in your contacts.
      2. As part of our business offerings we may offer an API for purposes such as contact validation and enrichment, as well as for lead generation and other similar purposes. As part of the API, we may disclose information such as name, email, company name, position and related business and Contact Information to our business customers and trusted partners.
    4. Sharing Aggregate Information – We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of data so that our partners can understand how and how often people use our Service and their services or websites, which facilitates improving both their services and how our Services interface with them. They may also use this information for their advertising, marketing, and for their other business use. In addition, these third parties may share with us aggregated or otherwise non Personal Information about you that they have independently developed or acquired.
    5. Sharing with Affiliates or Subsidiaries – We may disclose Personal Information or Contact Information to our affiliates or subsidiaries; however, if we do so, their use and disclosure of the information will be subject to this Privacy Policy.
    6. Usage Information – As mentioned above, We use analytics and crash reporting tools which have access to Usage Information (as defined above). These tools include, without limitation,
      • Firebase Analytics
      • Facebook Analytics
      • Fabric
    7. Sharing with Agents – We may use certain third parties to perform provide you with the Services that we offer; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; to process feedback. We may need to share your Personal Information and Contact information and other information with these third parties. Third party services include without limitation,
      • Hotline.io
      • Freshchat
      • Freshdesk
      • Sinch
      • ABBYY
    8. IP Address Information – While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.
    9. Information You Elect To Share – You may access other Third Party Services through the Service, for example by clicking on links to those Third Party Services from within our website. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.
    10. Affiliates and Acquisitions – We may share some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.
    11. Sharing for Legal Purposes – We may share Personal Information or Contact Information we collect in the following cases:
      1. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
      2. to enforce this Privacy Policy and/or the Terms, including investigation of potential violations thereof;
      3. to detect, prevent, or otherwise address fraud, security or technical issues;
      4. to respond to claims that any use of the App violates the rights of third-parties;
      5. to protect the rights, property, or personal safety of Company, any of its Users, or the general public;
        pursuant to your explicit approval prior to the disclosure;

7. How do We protect the information We collect?

We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your Personal Information from unauthorized access and disclosure. However, no system can be completely secure. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Therefore, although we take steps to help secure your information, we do not promise, and you should not expect, that your Personal Information will always remain secure.

8. What choices do You have regarding Your Personal Information?

  1. You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.
  2. You can request that we cancel your account by writing to us at privacy@getrolo.in.
  3. You can request that we delete your Personal Information from the Contacts Database by writing to us at privacy@getrolo.in.
    1. Before we can process your request for deletion of your Personal Information Contacts Database, you need to cancel your account with Rolo.
    2. If you request that we delete your Personal Information from the Contacts Database, we will not do so. If we do so, another user may later upload your contact information which will override your request for deletion. So in order to ensure that your Contact Information never gets used,  we will instead mark your Contact Information as ‘not to be used’.

9. GDPR Requirements

Breach Notification

Data processors will be required to notify their customers, the controllers, “without undue delay” after first becoming aware of a data breach.

Rolo Clarification

All breach related monitoring and notifications handled by senior management and guaranteed to be done within 72 hours.

Right to Access

GDPR emphasizes the right for data subjects to obtain from the data controller confirmation as to whether or not personal data concerning them is being processed, where and for what purpose. Further, the controller shall provide a copy of the personal data, free of charge, in an electronic format. This change is a dramatic shift to data transparency and empowerment of data subjects.

Rolo Clarification

Rolo is a contact management app which acts as a personal CRM and handles the following user data.

  • Contact data is processed and presented to the user along with a history of interaction with a given contact. Contact data is also backed up so that it can be restored on a new device of the user’s choice
  • Text messages (SMS) are processed and displayed to the user through the app. For non-premium users, text messages are NOT stored anywhere. For premium users, text messages are backed up so that they can be restored on a new device later.
  • Call logs: Call information is processed and displayed to the user through the app. For non-premium users, text messages are NOT stored anywhere. For premium users, text messages are backed up so that they can be restored on a new device later.
  • Other data: Other data created by the user on Rolo (notes, reminders and rolograms) are automatically backed up so that they can be restored on a new device of the user’s choice.

A copy of personal data related to a user can be obtained by sending an email request to privacy@getrolo.in with the subject line: Request for my data. The user just needs to mention the email id that was used to register with Rolo. The requested data will be sent in electronic format in response to this email.

 

Right to be Forgotten

Also known as Data Erasure, the right to be forgotten entitles the data subject to have the data controller erase his/her personal data, cease further dissemination of the data, and potentially have third parties halt processing of the data. T

Rolo Clarification

Rolo provides a process and a mechanism inside the app by which a user can request erasure of data related to him.

  • A user can send an email to privacy@getrolo.in with the subject line: Request to delete my data. The user just needs to mention the email id that was used to register with Rolo. A confirmation email will be sent to the user in response, confirming deletion of the user’s data. Once the deletion is confirmed, the user needs to uninstall the app.
  • A user can also use an option inside the app settings to get the data deleted. Once the deletion is confirmed, the user needs to uninstall the app.

Data Portability

GDPR introduces data portability – the right for a data subject to receive the personal data concerning them, which they have previously provided in a ‘commonly use and machine readable format‘ and have the right to transmit that data to another controller.

Rolo Clarification

  • Personal data related to a user can be obtained by sending an email request to privacy@getrolo.in with the subject line: Request for my data. The user just needs to mention the email id that was used to register with Rolo. The user will get a copy of the data tables (in CSV format) in the response.

Privacy by Design

Privacy by design is a part of a legal requirement with the GDPR. This calls for the inclusion of data protection from the onset of the designing of systems, rather than an addition. More specifically – ‘The controller shall..implement appropriate technical and organisational measures..in an effective way.. in order to meet the requirements of this Regulation and protect the rights of data subjects’. Controllers should hold and process only the data absolutely necessary for the completion of its duties (data minimisation), as well as limiting the access to personal data to those needing to act out the processing.

Rolo Clarification

Rolo is designed with user data privacy in mind, and incorporates the following measures

  • Data minimisation: Access limited to user data needed for the app features
  • Technology safeguard to limit access: User data stored for back-up protected using encryption
  • Access to user data limited to senior personnel
  • All personal data masked/anonimized when diagnostic data is sent by the user to the customer support team for troubleshooting

10. Questions

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at privacy@getrolo.in, and we will make an effort to reply within a reasonable timeframe.
By contacting us, you represent that you are free to do so and that you will not knowingly provide Company with information that infringes upon third parties’ rights, including any intellectual property rights. You further acknowledge that notwithstanding anything herein to the contrary, any and all rights, including intellectual property rights in such information provided, shall belong exclusively to the Company, and Company may use or refrain from using any such information at its sole discretion.


Changes to the Policy

April 06, 2018

  • Added Section 9 on GDPR requirements and how they are handled in Rolo.
  • Moved Questions to Section 10

October 19, 2017

  • Capitalised terms, like Users, You and Your appropriately throughout the document.
  • Removed overly general disclaimer about how this Policy does not apply to Third Parties that we may disclose information to. Individual disclaimers have been added in specific contexts.
  • Updated Table of Contents to reflect changes in the document.
  • Under Section 1 – About The Service – Added a Note about the new ‘Connect’ feature. Removed parts of App description that can be found elsewhere.
  • Changed Title of Section 3 to align with Table of Contents. Also modified age requirement clause to state that you must be over 13 to use Rolo.
  • Added details on what kind of personal information is collected (education details, date of birth etc) and when it is collected (when you start using Rolo or when you update your profile on Rolo)
  • Removed a statement about registering for updates on a link provided in our Site since we do not have any such link.
  • Changes in Section 5 – Information We Collect
    • Added a note about Rologram under ‘Section 5 – Information We Collect’
    • Removed Section5 – Information You Provide About A Third Party because it is covered under Section1 – Information about others
  • Section 6 – Re-organised content to separate headings. Added information on how Contact Information can be shared with business customers via our business offerings like an API. Also added a section to explain how we can help users merge contacts by sharing information about linkages in contacts.
  • Section 8 – What Choices do you have regarding your Personal Information
    • Added more information about how to delete account and how we handle deletion requests from global contacts database.