Privacy Policy and DPA

Privacy Policy

Welcome to Roclo ("Roclo," "our," or "we"). Our website at https://www.roclo.com (the "Site"), along with all related websites, downloadable software, mobile and tablet applications, and other services that we provide which feature a link to this privacy notice (“Privacy Notice”), are part of our offering. Additionally, any communication we have with individuals through written or verbal means, such as email or phone calls, is also considered part of our "Service".

Roclo is responsible for the Personal Data that you provide to us, as described in this Privacy Notice, unless otherwise specified. It's important to note that this Privacy Notice does not apply when we process Personal Data as a processor or service provider on behalf of our Clients. When we offer cloud products and services to our Clients, they are the owners and controllers of their own data. Roclo is largely unaware of the specific Client Data being stored or made available by a Client or User, and we do not directly access it except as authorized by the Client or as required to provide services.

We are not responsible for the privacy or data security practices of our Clients, which may differ from those set forth in this Privacy Notice. If you have any questions about privacy information related to situations where a Roclo Client is the controller of your data, please contact the respective Client directly. Roclo will not transfer or make available Client Data to third parties, except to our Subprocessors who may process such data on our behalf in connection with our Services to Clients. We are not responsible for the content of the Personal Data contained in the Client Data or other information stored on our servers, nor are we responsible for the manner in which the Client or User collects, handles, or processes such information.

Definitions

“Client(s)” means a customer of Roclo

“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.

“Sub-Processor” means any person or entity engaged by Roclo or its Affiliate to process Personal Data in the provision of the Services to the Company.

“Personal Data” means any information relating to an identified or identifiable natural person.

“User(s)” means a person(s) that has been given authorisation by the Client to access the Service.

“Visitor(s)” means an individual other than a User, who uses the public website area, but has no access to the restricted areas of the Site or Service.

Information We Collect

Information you provide

To access our services, you will need to sign up for an account by providing us with your name, contact number, email address, company name, and country. You may also choose to provide additional information, such as your photo, but this is not required. When you make a purchase, we ask for your name, contact information, and payment details, which we store in an encrypted format for future processing, with your consent. If you have any questions or concerns about how we handle your personal information, please contact us at privacy@roclo.com

Information Collected by Clients

The Service allows Clients and Users to store and upload Client Data, which may include Personal Data of individuals. Roclo does not have a direct relationship with these individuals whose Personal Data is hosted as part of the Client Data. It is the responsibility of each Client to provide notice to its customers and third parties about the purpose of collecting their Personal Data and how it is processed through the Service as part of the Client Data.

Automatically Collected Data

We collect information from various sources when you visit our websites, use our services or mobile applications. This information includes internet protocol addresses, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We use this information to gain insights about visitors and to enhance their user experience. In addition, we use cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track website navigation, gather demographic information, understand email campaign effectiveness and engage with visitors and users. We also collect usage data from our products, services, and mobile applications to analyse user behaviour and improve our offerings. This data includes information about the features accessed, access time and frequency, performance data, storage utilized, user settings, configurations, and devices used.

Sharing Your Information

Service Providers

As with many businesses, we may enlist the services of other companies and individuals to perform certain business-related tasks. We may share personal information with these third-party service providers only as necessary to enable them to provide the requested services. These services may include technical assistance, order fulfillment, customer service, and marketing assistance. We require that these third-party service providers sign contracts obligating them to maintain the same level of data protection as outlined in our privacy policy. In addition, we may share personal information with our affiliates to support the marketing, sale, and delivery of services.

Disclosure to public authorities

Under certain circumstances, we may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. Additionally, we may be compelled to disclose personal information to other third parties by government authorities or as required by law or regulation, which may include responding to court orders and subpoenas.

Change of Ownership

Personal Data and information about Users and Visitors may be transferred to an acquirer, successor, or assignee in the event of a merger, acquisition, sale of assets, debt financing, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership, where the information is transferred to one or more third parties as part of our business assets. This transfer will only take place if the recipient commits to a Privacy Policy that is consistent with this Privacy Notice. Similarly, Client Data may be transferred to an acquirer, successor, or assignee in the same circumstances, for the sole purpose of continuing the operation of the Service, and only if the recipient commits to a Privacy Policy that is substantially consistent with this Privacy Notice.

Direct Marketing / Email Management

If you wish to opt-out of the use of your personal information for direct marketing purposes, or the transfer of your personal information to third parties for direct marketing purposes, you may contact privacy@roclo.com. Please note that we will require a reasonable amount of time to process your request.

Personal Information: Access, Retention, and Security

Personal Information

If you believe that your personal information is inaccurate or has been processed in violation of this policy, you have the right to request correction, amendment, or deletion of such information. To exercise this right, you can send a notice to us at privacy@roclo.com with “Privacy Policy” in the subject line. We will respond to your request within a reasonable time frame.

Retention of personal information

We will keep your personal information in an identifiable form only for the duration required to fulfil the purpose(s) for which it was originally collected, as stated in this policy, subsequently authorized, or as permitted by the applicable law. Once the applicable retention periods have lapsed, we may either erase your personal information or retain it in a form that does not personally identify you.

Protection of personal information

At Roclo the security and privacy of your personal information are of utmost importance to us. We are committed to implementing reasonable and appropriate security measures to safeguard your personal information from unauthorized access, loss, disclosure, alteration, and destruction, in accordance with applicable laws and regulations. These measures take into account the risks associated with processing your data and the nature of such data.

Minors and Children’s Privacy

Safeguarding the privacy of minors is a matter of utmost importance to us. Our Service is not intended for use by individuals under the age of 18, and we do not knowingly collect Personal Data from minors. If you are under 18 years of age, please do not use or access our Service. If we become aware of the collection of Personal Data from minors under 18 years of age without verifiable parental consent, we will take appropriate measures to delete such information.

Changes and Updates to this Privacy Notice

Please make sure to check this page regularly to stay informed about any updates or changes to this Notice, as we may update it periodically. If we make any modifications to this Notice, we will provide it through the Service and indicate the date of the most recent update, and comply with all relevant laws. By continuing to use the Service after the revised Notice becomes effective, you acknowledge that you have read, understood and agreed to the current version of the Notice.

How to Contact Us

If you have questions about this Privacy Policy, please contact us via e-mail at privacy@roclo.com with “Privacy Policy” in the subject line.

Roclo Privacy Policy, 10th January 2023

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Data Processing Agreement (DPA)

This DPA is entered into between the Client and Roclo Limited and is incorporated into and governed by the terms of the Roclo Service Agreement.

1. DEFINITIONS

Any capitalised term not defined in this DPA shall have the meaning given to it in the Agreement.

“Affiliates” means any entity that directly or indirectly controls, is controlled by, or is under common control of a party.

“Control,” for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of a party;

“Agreement” means the agreement between the Client and Roclo Limited for the provision of the Services;

“Controller” means the Client;

“Data Protection Law” means the GDPR and/or any subsequent amendment or replacement or supplementary legislation;

“Data Subject” shall have the same meaning as in Data Protection Law;

“DPA” means this data processing agreement together with Exhibits A and B;

“GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016;

“Personal Data” shall have the same meaning as in Data Protection Law;

“Processor” means Roclo;

“Services” means provision of a web based management system for the purpose of managing M&A and other similar transactions as well as providing and sales enablement and CRM tool

“Standard Contractual Clauses” means the EU model clauses for personal data transfer from controllers to processors c2010-593 - Decision 2010/87EU;

“Sub-Processor” means any person or entity engaged by Roclo or its Affiliate to process Personal Data in the provision of the Services to the Company.

2. PURPOSE

2.1The Processor has agreed to provide the Services to the Controller in accordance with the terms of the Agreement. In providing the Services, the Processor shall process Customer Data on behalf of the Controller. Customer Data may include Personal Data. The Processor will process and protect such Personal Data in accordance with the terms of this DPA.

3. SCOPE

3.1In providing the Services to the Controller pursuant to the terms of the Agreement, the Processor shall process Personal Data only to the extent necessary to provide the Services in accordance with both the terms of the Agreement and the Controller’s instructions documented in the Agreement and this DPA.

4. PROCESSOR OBLIGATIONS

4.1The Processor may collect, process or use Personal Data only within the scope of this DPA.

4.2The Processor confirms that it shall process Personal Data on behalf of the Controller and shall take steps to ensure that any natural person acting under the authority of the Processor who has access to Personal Data shall only process the Personal Data on the documented instructions of the Controller.

4.3The Processor shall promptly inform the Controller, if in the Processor’s opinion, any of the instructions regarding the processing of Personal Data provided by the Controller, breach any Data Protection Law.

4.4The Processor shall ensure that all employees, agents, officers and contractors involved in the handling of Personal Data: (i) are aware of the confidential nature of the Personal Data and are contractually bound to keep the Personal Data confidential; (ii) have received appropriate training on their responsibilities as a data processor; and (iii) are bound by the terms of this DPA.

4.5The Processor shall implement appropriate technical and organisational procedures to protect Personal Data, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.

4.6The Processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (i) the pseudonymisation and encryption of Personal Data; (ii) the ability to ensure the on-going confidentiality, integrity, availability and resilience of processing systems and services; (iii) the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; (iv) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing. In accessing the appropriate level of security, account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data transmitted, stored or otherwise processed.

4.7The technical and organisational measures detailed in Exhibit B shall be at all times adhered to as a minimum security standard. The Controller accepts and agrees that the technical and organisational measures are subject to development and review and that the Processor may use alternative suitable measures to those detailed in the attachments to this DPA.

4.8The Controller acknowledges and agrees that, in the course of providing the Services to the Controller, it may be necessary for the Processor to access the Personal Data to respond to any technical problems or Controller queries and to ensure the proper working of the Services. All such access by the Processor will be limited to those purposes.

4.9Where Personal Data relating to an EU Data Subject is transferred outside of the EEA it shall be processed in accordance with the provisions of the Standard Contractual Clauses, unless the processing takes place: (i) in a third country or territory recognised by the EU Commission to have an adequate level of protection; or (ii) by an organisation located in a country which has other legally recognised appropriate safeguards in place, such as the EU-US Privacy Shield or Binding Corporate Rules.

4.10Taking into account the nature of the processing and the information available to the Processor, the Processor shall assist the Controller by having in place appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of the Controller’s obligation to respond to requests for exercising the Data Subject’s rights and the Controller’s compliance with the Controller’s data protection obligations in respect of the processing of Personal Data.

5. CONTROLLER OBLIGATIONS

5.1The Controller represents and warrants that it shall comply with the terms of the Agreement, this DPA and Data Protection Law.

5.2The Controller represents and warrants that it has obtained any and all necessary permissions and authorisations necessary to permit the Processor, its Affiliates and Sub-Processors, to execute their rights or perform their obligations under this DPA, and that it shall provide proof of such authority to the Processor immediately upon request.

5.3The Controller is responsible for compliance with Data Protection Law, including requirements with regards to the transfer of Personal Data under this DPA and the Agreement.

5.4All Affiliates of the Controller who use the Services shall comply with the obligations of the Controller set out in this DPA.

5.5The Controller shall implement appropriate technical and organisational procedures to protect Personal Data, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons. The Controller shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (i) the pseudonymisation and encryption of Personal Data; (ii) the ability to ensure the on-going confidentiality, integrity, availability and resilience of processing systems and services; (iii) the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; (iv) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing. In accessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data transmitted, stored or otherwise processed.

5.6The Controller shall take steps to ensure that any natural person acting under the authority of the Controller who has access to Personal Data only processes the Personal Data on the documented instructions of the Controller.

5.7The Controller may require correction, deletion, blocking and/or making available the Personal Data during or after termination of the Agreement. The Processor will process the request to the extent it is lawful and will reasonably fulfil such request in accordance with its standard operational procedures to the extent possible.

5.8The Controller acknowledges and agrees that some instructions from the Controller, including destruction or return of data, assisting with audits, inspections or DPIAs by the Processor, may result in additional fees. In such case, the Processor will notify the Controller of its fees for providing such assistance in advance, unless otherwise agreed.

6. SUB-PROCESSORS

6.1The Controller acknowledges and agrees that: (i) Affiliates of the Processor may be used as Sub-processors; and (ii) the Processor and its Affiliates respectively may engage Sub-processors in connection with the provision of the Services.

6.2All Sub-processors who process Personal Data in the provision of the Services to the Controller shall comply with the obligations of the Processor set out in this DPA.

6.3Where Sub-processors are located outside of the EEA, the Processor confirms that such Sub-processors: (i) are located in a third country or territory recognised by the EU Commission to have an adequate level of protection; or (ii) have entered into Standard Contractual Clauses with the Processor; or (iii) have other legally recognised appropriate safeguards in place, such as the EU-US Privacy Shield or Binding Corporate Rules.

6.4The Processor shall make available on request to the Controller a current list of Sub-processors at which shall include the identities of Sub-processors and their country of location. During the term of this DPA, the Processor shall provide the Controller, with prior notification via email, with any changes to the list of Sub-processor(s) who may process Personal Data before authorising any new or replacement Sub-processor(s) to process Personal Data in connection with the provision of the Services.

6.5The Controller may object to the use of a new or replacement Sub-processor, by notifying the Processor promptly in writing within ten (10) Business Days after receipt of the Processor’s notice. If the Controller objects to a new or replacement Sub-processor, and that objection is not unreasonable, the Controller may terminate the Agreement or applicable Order Form with respect to those Services which cannot be provided by the Processor without the use of the new or replacement Sub-processor. The Processor will refund the Controller any unused prepaid fees covering the remainder of the Term of the Agreement (or applicable Order Form) following the effective date of termination with respect to such terminated Services.

7. LIABILITY

7.1The limitations on liability set out in the Agreement apply to all claims made pursuant to any breach of the terms of this DPA.

7.2The parties agree that the Processor shall be liable for any breaches of this DPA caused by the acts and omissions or negligence of its Sub-processors to the same extent the Processor would be liable if performing the services of each Sub-processor directly under the terms of the DPA, subject to any limitations on liability set out in the terms of the Agreement.

7.3The parties agree that the Controller shall be liable for any breaches of this DPA caused by the acts and omissions or negligence of its Affiliates as if such acts, omissions or negligence had been committed by the Controller itself.

7.4The Controller shall not be entitled to recover more than once in respect of the same claim.

8. AUDIT

8.1The Processor shall make available to the Controller and at the Controller’s expense all information reasonably necessary to demonstrate compliance with its processing obligations and allow for and contribute to audits and inspections.

8.2Any audit conducted under this DPA shall consist of examination of the most recent reports, certificates and/or extracts prepared by an independent auditor bound by confidentiality provisions similar to those set out in the Agreement. In the event that provision of the same is not deemed sufficient in the reasonable opinion of the Controller, the Controller may conduct a more extensive audit which will be: (i) at the Controller’s expense; (ii) limited in scope to matters specific to the Controller and agreed in advance; (iii) carried out during UK business hours and upon reasonable notice which shall be not less than 4 weeks unless an identifiable material issue has arisen; and (iv) conducted in a way which does not interfere with the Processor’s day-to-day business.

8.3This clause shall not modify or limit the rights of audit of the Controller, instead it is intended to clarify the procedures in respect of any audit undertaken pursuant thereto.

9. DATA BREACH

9.1The Processor shall notify the Controller without undue delay after becoming aware of (and in any event within 72 hours of discovering) any accidental or unlawful destruction, loss, alteration or unauthorised disclosure or access to any Personal Data (“Data Breach”).

9.2The Processor will take all commercially reasonable measures to secure the Personal Data, to limit the effects of any Data Breach, and to assist the Controller in meeting the Controller’s obligations under applicable law.

10. COMPLIANCE, COOPERATION AND RESPONSE

10.1In the event that the Processor receives a request from a Data Subject in relation to Personal Data, the Processor will refer the Data Subject to the Controller unless otherwise prohibited by law. The Controller shall reimburse the Processor for all costs incurred resulting from providing reasonable assistance in dealing with a Data Subject request. In the event that the Processor is legally required to respond to the Data Subject, the Controller will fully cooperate with the Processor as applicable.

10.2The Processor will notify the Controller promptly of any request or complaint regarding the processing of Personal Data, which adversely impacts the Controller, unless such notification is not permitted under applicable law or a relevant court order.

10.3The Processor may make copies of and/or retain Personal Data in compliance with any legal or regulatory requirement including, but not limited to, retention requirements.

10.4The Processor shall reasonably assist the Controller in meeting its obligation to carry out data protection impact assessments (DPIAs), taking into account the nature of processing and the information available to the Processor.

10.5The parties acknowledge that it is the duty of the Controller to notify the Processor within a reasonable time, of any changes to applicable data protection laws, codes or regulations which may affect the contractual duties of the Processor. The Processor shall respond within a reasonable timeframe in respect of any changes that need to be made to the terms of this DPA or to the technical and organisational measures to maintain compliance. If the parties agree that amendments are required, but the Processor is unable to accommodate the necessary changes, the Controller may terminate the part or parts of the Services which give rise to the non-compliance. To the extent that other parts of the Services provided are not affected by such changes, the provision of those Services shall remain unaffected.

10.6The Controller and the Processor and, where applicable, their representatives, shall cooperate, on request, with a supervisory data protection authority in the performance of their respective obligations under this DPA.

11. TERM AND TERMINATION

11.1The Processor will only process Personal Data for the term of the DPA. The term of this DPA shall coincide with the commencement of the Agreement and this DPA shall terminate automatically together with termination or expiry of the Agreement.

11.2The Processor shall at the choice of the Controller, upon receipt of a written request received within 30 days the end of the provision of the Services relating to processing, delete or return Personal Data to the Controller. The Processor shall in any event delete all copies of Personal Data in its systems within 60 days of the effective date of termination of the Agreement unless: (i) applicable law or regulations require storage of the Personal Data after termination; or (ii) partial personal data of the Company is stored in backups, then such personal data shall be deleted from backups up to 1 year after the effective date of termination of the Agreement.

12. GENERAL

12.1This DPA sets out the entire understanding of the parties with regards to the subject matter herein.

12.2Should a provision of this DPA be invalid or become invalid then the legal effect of the other provisions shall be unaffected. A valid provision is deemed to have been agreed which comes closest to what the parties intended commercially and shall replace the invalid provision. The same shall apply to any omissions.

12.3This DPA shall be governed by the laws of England and Wales. The courts of England shall have exclusive jurisdiction for the settlement of all disputes arising under this DPA.

The parties agree that this DPA is incorporated into and governed by the terms of the Agreement.

Exhibit A

Overview of data processing activities to be performed by the Processor

1. CONTROLLER

The Controller transfers Personal Data identified in sections 3, 4 and 5 below, as it relates to the processing operations identified in section 6 below.

2. PROCESSOR

The Processor received data identified in sections 3, 4 and 5 below, as it relates to the processing operations identified in section 6 below.

3. DATA SUBJECTS

The Personal Data transferred includes but is not limited to the following categories of Data Subjects:

  • Employees, freelancers and contractors of the Controller and other users added by the Controller from time to time.
  • Users, Affiliates and other participants from time to time to whom the Controller has granted the right to access the Services in accordance with the terms of the Agreement.
  • Clients of the Controller and individuals with whom those end users communicate with by email and/or instant messaging.
  • Service providers of the Controller.
  • People who are at least 16 years old.
  • Other individuals to the extent identifiable in the content of emails or their attachments or in archiving content.
4. CATEGORIES OF DATA

The Personal Data transferred includes but is not limited to the following categories of data:

  • Personal details, names, user names, passwords, email addresses, job titles, phone numbers and the Company names and addresses of Users.
  • Personal Data derived from the Users use of the Services such as records and business intelligence information.
  • Personal Data within email and messaging content which identifies or may reasonably be used to identify, data subjects.
  • Meta data including sent, to, from, date, time, subject, which may include Personal Data.
  • Data concerning education and profession.
  • Data revealing political opinions, image and sound recordings.
  • Survey, feedback and assessment messages.
  • Information offered by users as part of support enquiries.
  • Other data added by the Controller from time to time.
5. SPECIAL CATEGORIES OF DATA

No sensitive data or special categories of data are permitted to be transferred and shall not be contained in the content of or attachments to, emails.

6. PROCESSING OPERATIONS

The Personal Data transferred will be subject to the following basic processing activities:

  • Personal Data will be processed to the extent necessary to provide the Services in accordance with both the Agreement and the Controller’s instructions. The Processor processes Personal Data only on behalf of the Controller.
  • Processing operations include but are not limited to: M&A deal management and CRM management systems. This operation relates to all aspects of Personal Data processed.
  • Technical support, issue diagnosis and error correction to ensure the efficient and proper running of the systems and to identify, analyse and resolve technical issues both generally in the provision of the Services and specifically in answer to a Controller query. This operation may relate to all aspects of Personal Data processed but will be limited to metadata where possible.
  • Virus, anti-spam and Malware checking in accordance with the Services provided. This operation relates to all aspects of Personal Data processed.
Exhibit B
Technical and Organisational Security Measures

Processor utilises Amazon Web Services (“AWS”) cloud data centres / cloud security that maintain current ISO 9001, ISO 27001, ISO27017, ISO 27018, SOC1, SOC2, SOC3, PCI DSS Level 1, SSAE 16, ISAE 3402 certifications. The Processor will not utilise third party data centres that do not maintain the aforementioned certifications and/or attestations, or other substantially similar or equivalent certifications and/or attestations.

Upon the Controller’s written request (no more than once in any 12-month period), the Processor shall provide within a reasonable time, a copy of the most recently completed 3rd-party certification and/or attestation reports (to the extent that to do so does not prejudice the overall security of the Services). Any audit report submitted to the Controller shall be treated as Confidential Information and subject to the confidentiality provisions of the Agreement between the parties.

Full details relating to AWS data centre controls can be found here https://aws.amazon.com/compliance/data-center/controls/

Roclo Data Processing Agreement, 10th January 2023