ROI·DNA Privacy Policy

 

Last Updated: September 30, 2025

ROI·DNA, Inc. (“ROI·DNA,” “we,” “us,” or “our”), is a full-service digital marketing agency that delivers deep, functional solutions built on incisive expertise across the digital space. ROI·DNA respects and values your privacy. This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information, and to inform you how to exercise your privacy rights.

1. SCOPE AND UPDATES TO THIS PRIVACY POLICY

2. CONTACT US

4. GDPR

4. PERSONAL INFORMATION WE COLLECT

5. HOW WE USE YOUR PERSONAL INFORMATION

6. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

7. STORAGE OF YOUR INFORMATION

8. YOUR PRIVACY CHOICES AND RIGHTS

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

11. CHILDREN’S INFORMATION

12. OTHER PROVISIONS

13. HOW TO COMPLAIN

 

1. SCOPE AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including on our website (https://www.roidna.com/), and other online or offline offerings. To make this Privacy Policy easier to read, our website and other offerings are collectively called the “Services.”

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

An Important Note: This Privacy Policy does not apply to any of the personal information that we process on behalf of our customers through their use of our Services (“Customer Data”). Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

2. CONTACT INFORMATION

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us either:

ROI·DNA
655 Montgomery St.
Suite 850
San Francisco, CA
94111
Data Protection Officer
Level 2, 100 Harris St
Pyrmont, NSW
2009
Australia
gdpr@enero.com

Or, click below to submit a data request to ROI·DNA. You will be redirected to a form where you will be required to provide your details.

SUBMIT DATA REQUEST

3. GDPR

For the purpose of the General Data Protection Regulation in the United Kingdom and European Union (“GDPR) (collectively the “Data Protection Laws”) the Data Controller is ROI·DNA.

4. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

 

A. Personal Information You Provide to Us Directly

 

We may collect personal information that you provide to us in interactions you have with us, including but not limited to the following:

  • Use of Services. In order to provide our Services, we may collect personal information such as your full name, email address, physical address, or phone number. We may also collect additional information, such as your age, gender, preferences, and interests.
  • Your Communications with Us. We may collect personal information, such as your full name, email address, or phone number, when you request information about our Services, file any forms as part of a registration process, or otherwise communicate with us. This includes information provided at the time of registering to use this website, subscribing to a component of our Services, or requesting further information or using or accessing our Services. We may also ask you for information when you report a problem with this website. If you contact Us, We may keep a record of that correspondence.
  • Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
  • Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., forums, blogs, and social media pages). Any information you provide using our interactive features will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
  • Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
  • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
  • Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

 

B. Personal Information Collected Automatically

 

We may collect personal information automatically when you use our Services such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, traffic data, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.

 

Cookie Policy (and Other Technologies.) 

We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services. By using our Website and providing opt-in consent you agree to our use of cookies and other technologies as more specifically set out below.

  1. Cookies. Cookies are small text files placed in device browsers or the hard drive of your computer if you agree, that store preferences, facilitate and enhance your experience, and also improve the website. Cookies contain information that is transferred to your computer’s hard drive.
  2. Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

The provision of certain personal data may be required from you to enable Us to provide you use or access of our services. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.

Our uses of the  Technologies identified above fall into the following general categories:

  1. Operationally Necessary. This includes Technologies that are required for the operation of our website and allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
  2. Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
  3. Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality and personalisation when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed; and
  4. Advertising- or Targeting-Related. These Technologies record your visit to our website andthe pages you have visited. . We may use first party or third-party Technologies to process and provide us with information about you and us and our Services and deliver advertising content, including ads we reasonably believe you have legitimate interests in, on both our Services platforms or on third-party digital properties. See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Some of the advertising Technologies we use include:

  1. Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
  2. Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. They also count the number of visitors and to see how visitors move around the website when they are using it. Some of our analytics partners include:
  3. Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
  4. Social Media Platforms. Our Services may contain social media buttons, such as Facebook, LinkedIn, Twitter, and Instagram which might include widgets such as the “share this” button or other interactive mini programs). These features may collect personal information such as your IP address and which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

 

Essential (Strictly Necessary and Functional) 1st Party cookie(s).

The following cookies may be witnessed:

 

Name Provider Purpose Expires
OptanonConsent OneTrust Consent status of a visitor 365 days
visitor_idXXXXXX Salesforce/Pardot Unique, anonymous identifier for a person interacting with the site before they are converted into a “prospect” record 3,650 days (10 years)
_GRECAPTCHA Google  Spam Protection 180 days
_gtm Google Tag Manager Script Loader  End of session

Third Party Cookies.

By clicking “Allow” you will see the following 3rd Party Cookies:

Analytical Cookie(s)

Name Provider Purpose Expires
_ga

_ga_<container-id>

Google Analytics Site Analytics 730 days (2 years)
_hjSessionUser_XX Hotjar  Sets when a user first lands on a page; used to ensure data from subsequent visits are tied to the same user ID 365 days
_htHasCachedUserAttributes Enables team to know whether data set in _hjUserAttributes Local Storage item is up to date or not End of session
_ hjUserAttributesHash Enables team to know when any User Attribute has changed and needs updating 2 minute duration, extended every 30 seconds
_hjUserAttributes Stores User Attributes sent through the Hotjar Identify API No explicit expiration
_hjSession_XXXXXX Holds current session data; ensures subsequent results in the session window are attributed to the same session 30 minute duration, extended on user activity
_hjDonePolls Set when a user completes an on-site survey to ensure the same survey is not shown to the same user 365 days
_hp2_id.APP_ID Heap User cookie that stores user_id, identity, other IDs 13 months minus 1 day
_hp2_ses_props.APP_ID Session properties cookie 30 minutes
_hp2_props_APP_ID Event properties cookie 13 months minus 1 day
_hp5_meta.APP_ID User + session cookie for heap.js v5 13 months minus 1 day
_hp5_event_props_APP_ID Event properties cookie for heap.js v5 (stores properties set by the addEventProperties API) 13 months minus 1 day
_hp5_let.ENV_ID Contains last event time in Heap v5.2.7+ 13 months minus 1 day
6suuid 6sense Intent Tracking 730 days
tuuid

tuuid_lu

Demandbase Account Based Tracking 13 months
liap LinkedIn Denotes the logged in status of a LinkedIn member 1 year
Bcookie Brower identifier cookie to uniquely identify devices accessing LinkedIn 1 year
__cf_bm Bot management After 30 minutes of continuous inactivity
li_sugr Makes a probabilistic match of a user’s identity 90 days
_guid Used to identify a LinkedIn Member for advertising through Google Ads 90 days
__cf_bm Qualified ChatBot Bot management After 30 minutes of continuous inactivity

 

Please note that third parties’ affiliates may also use cookies, over which We have no control.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our website.

 

D. Personal Information Collected from Other Sources

 

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services when we reasonably believe you have a legitimate interest in our Services (e.g., trade show attendee listings or directories, LinkedIn or other directory listings, external websites, etc.) and organizations. These third-party services and organizations may provide us with your name, physical address, and phone number while using our Services.

 

5. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

We rely on the following lawful basis for processing:

  1. your consent as provided when you sign up to using our services on our website. to fulfil our contractual obligations to you.
  2. to fulfil our legal obligations.
  3. certain legitimate business purposes which may include some or all of the following:
    • for direct marketing purposes;
    • where it is necessary to protect your vital interests;
    • we are transferring between different parts of the organizational group for internal administrative purposes;
    • where there is a direct appropriate relationship, such as where you or your employer is a client;
    • we have a reasonable expectation that you consent to your data being processed; or
  4. processing for the purposes of ensuring network and information security, including preventing unauthorized access to electronic communications networks and stopping damage to computer and electronic communication systems.

 

A. Provide Our Services

We use your information to fulfil our contract with you and provide you with our Services, including but not limited to:

  1. Carrying out our obligations arising from any contracts entered into between you and Us;
  2. Allowing you to participate in interactive features of our service, when you choose to do so;
  3. Notifying you about changes to our service;
  4. Providing you with information that will help you select us as a possible partner for your future integrated communications needs;
  5. Processing applications if you apply for a job we post on our Services;
  6. Allowing you to register for events; and
  7. Providing you with information and offers that you request from Us or which We feel may interest you.

 

B. Administrative Purposes

We use your information for various administrative purposes, such as:

  1. Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  2. To ensure that content on the website is presented in the most effective manner for you and for the device(s) you use to access and view the website;
  3. Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  4. Measuring interest and engagement in our Services;
  5. Short-term, transient use, such as contextual customization of ads; Improving, upgrading, or enhancing our Services;
  6. Developing new products and services;
  7. Ensuring internal quality control and safety;
  8. Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy; Debugging to identify and repair errors with our Services;
  9. Auditing relating to interactions, transactions, and other compliance activities;
  10. Sharing personal information with third parties as needed to provide the Services;
  11. Enforcing our agreements and policies; and
  12. Carrying out activities that are required to comply with our legal obligations.

 

C. Marketing and Advertising our Products and Services

In addition to the above uses, We may use personal information (and, where you have consented, permit selected third parties to use your information) to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we may market to you include email campaigns and text messages  (if you have consented to such communications), custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, please either:

  1. tick the relevant box situated on the form on which We collect your data (for example, the registration form);
  2. unsubscribe from our electronic communications using the method indicated in the relevant communication; or
  3. contact us at any time as set forth in “Contact Us” below.

 

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

 

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create.

 

6. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

  1. Service Providers and Subcontractors. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
  2. Business Partners and Agents. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
  3. Affiliates. We may share your personal information with our company affiliates for example: for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
  4. Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
  5. APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us”

For example, the personal information we may send contains your email address, phone number, company name and full name to a publication or media outlet as it applies to our services.

These third-party service providers are required not to use your personal information other than to provide the services requested by us.

We may disclose your personal information to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

 

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, our affiliated entities, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

 

7. STORAGE OF YOUR INFORMATION

A. Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website or any website we host, you are responsible for keeping this password confidential.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.

B. Keeping your personal data up to date

If your personal details change you may update them by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.

We will endeavor to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.

C. How long we keep your personal data

The time periods for which we retain your personal data is dependent upon the purposes for which we use it. We will retain it for as long as you are a registered subscriber or user of our services or for as long as we have another business purpose to do so. Thereafter, for no longer than is required or permitted by law, by our Retention Policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request.

D. Where we store your personal data

All information We hold about you is stored on our secure servers within the UK, EEA and US.

The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), or the United Kingdom. It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.

Such countries do not have the same data protection laws as the United Kingdom, and the EEA . Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to EU-U.S. Data Privacy Framework or under a European Commission approved contract or through a series of intercompany agreements based on the Standard Contractual Clauses authorized under the EU Data Protection Directive 95/46/EC and (as permitted under Article 46(5) of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If you would like further information please contact Us OR our Data Protection Officer (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

 

8. YOUR PRIVACY CHOICES AND RIGHTS

A. Your Privacy Choices.

The privacy choices you may have about your personal information are determined by applicable law and are described below.

  1. Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
  2. “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
  3. Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital

Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.

B. Your Privacy Rights.

In accordance with applicable law, you may have the right to:

  1. Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your
  2. personal information; (ii) obtaining access to or a copy of your personal information and certain other supplementary information that this policy is already designed to address; and (iii) receiving an electronic
  3. copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format in certain situations (also known as the “right of data portability”);
  4. Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
  5. Request Deletion of your personal information in certain situations;
  6. Request Restriction of or Object to our processing of your personal information where the processing of your personal information is based on our legitimate interest or for direct marketing purposes ;
  7. Request Restriction of or Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
  8. Request Restriction of or Object in certain other situations to our continued processing of your personal data otherwise restrict our processing of your personal data in certain circumstances;
  9. Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal; and
  10. Claim compensation for damages caused by our breach of any data protection laws.

If you would like to exercise any of these rights, please:

  • contact us through the channels set out above;
  • let Us have enough information to identify you, for example your name, employer, or registration details;
  • let Us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill); and
  • let Us know the information to which your request relates, including any client account or reference numbers, if you have them.

We will process such requests in accordance with applicable laws.

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

his Supplemental Notice for California Residents, under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations, only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”).

For the purpose of the CCPA, the business is ROI·DNA, Inc.

We are complying with the CCPA and considering its underlying principles in how we think about customer trust and data privacy as a core pillar of our business. We are providing this CCPA-specific privacy notice to supplement the information and disclosures already contained above.

A. Your Rights.

Under the CCPA you have a number of important rights. In summary, those include rights to:

  1. Right to Know and Access. You may submit a request up to two times in a 12 month period for information regarding the:
    1. categories of Personal Information collected or disclosed by us;
    2. purposes for which categories of Personal Information are collected by us; categories of sources from which we collect Personal Information; and
    3. specific pieces of Personal Information we have collected about you during the past twelve months.
  2. Right to Delete. Subject to certain exceptions, you have the option to delete Personal Information about you that we have collected from you.
  3. Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.
  4. Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. Shine the Light. We do not rent, sell, or share your Personal Information with non-affiliated companies for their direct marketing purposes, unless we have your permission.

For further information on each of those rights, see the CCPA Fact Sheet from the Office of the Attorney General

California: https://oag.ca.gov/system/files/attachments/press_releases/CCPA%20Fact%20S heet%20%2800000002%29.pdf

If you would like to exercise any of these rights, please:

  • contact us as set forth in “Contact Us” below OR Catherine Hoyle our Data Protection Officer via gdpr@enero.com;
  • let Us have enough information to identify you, for example your name, employer, or registration details;
  • let Us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill); and
  • let Us know the information to which your request relates, including any client account or reference numbers, if you have them.

We will process such requests in accordance with applicable laws.

B. Personal Information Collected in the previous 12 months.

The CCPA provides California residents with the right to know what categories of personal information ROI·DNA has collected about them, and whether ROI·DNA disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. The examples of Personal Information provided for each category are taken from the CCPA and are included to help you understand what the categories mean.

California residents can find this information below:

Category of Personal Information Collected by ROI·DNA We collect Category of Third Parties Personal Information is Disclosed to for a Business Purpose We Sell
Identifiers.

A real name, alias, telephone number, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

YES Service providers Business partners Affiliates

Other third parties you interact with

Advertising networks (online identifiers and/or hashed email addresses)

Data analytics providers

Social networks

NO
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, address, telephone number,

YES Advertising networks Data analytics provider Service providers NO
Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender,gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO N/A NO
Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES Advertising networks Data analytics provider Service providers NO
Biometric Information

Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

NO N/A NO
Internet or other electronic network activity

Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.

YES Advertising networks Data analytics provider Service providers NO
Geolocation data

Physical location or movements.

YES Advertising networks Data analytics provider Service providers NO
Professional or employment-related information

Current or past job history or performance evaluations.

YES N/A NO
Inferences drawn from other personal information to create a profile about a consumer

Profile reflecting a consumer’s preferences, characteristics, predispositions, behavior, and attitudes.

YES Advertising networks Data analytics provider Service providers NO

The categories of sources from which we collect personal information, our business and commercial purposes for using personal information, and the disclosure of personal information are set forth in “Personal Information We Collect”, “How We Use Your Personal Information” and “How We Disclose Your Personal Information” above, respectively.

C. “Sales” of Personal Information and use of cross-context behavioral advertising under the CCPA/CPRA

the CCPA, ROI·DNA does not “sell” personal information, nor do we sell the personal information of minors under 16 years of age, without affirmative authorisation. That said, we may share information with third-party advertising partners for the purpose of promoting our Services as described above, such as for

cross-context behavioral advertising. To the extent that such sharing is considered a “sale” under California law, you may limit such sharing by following the instructions found above in the section titled, Your Privacy Choices, or by contacting us as set forth in “Contact Us” below.

D. Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.

California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and

obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to

those parties.

10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at contact@roidna.com OR Catherine Hoyle our Data Protection Officer via gdpr@enero.com, with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

11. CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.

12. OTHER PROVISIONS

A. Third-Party Websites/Applications.

The Services may contain links to other websites/applications and other

websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

B. Supervisory Authority.

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, the United Kingdom, or Virginia, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.

13. HOW TO COMPLAIN

We hope that We or our Data Protection Officer can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.