Rosecut Website and Application Privacy Notice

Who are we?

We are Rosecut Technologies Limited, (in this Notice, we refer to ourselves as Rosecut, "we", "us", and "our").

This Privacy Notice explains what information about you we collect, what we do with it, and how you can control it. This notice applies to this website (our Site) and our mobile application (our App).

How can you contact us?

If you have any questions about how we handle your personal information, please contact us at contact@rosecut.com.

What information do we collect and why do we use it?

We'll collect technical, contact, financial, income, account, communication and other information about you. We do this if you:

● use our Site or App, contact us or give us feedback;
● register for an account, subscribe to our services or publications;
● sign up to receive news, updates or other marketing;
● enter a competition, prize draw or promotion; or.
● attend one of our events.

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When we collect
Use our Site or App

What we collect
• phone number
• Internet Protocol (IP) address
• login information (social log-in ID/email address)
• browser type and version (and browser plug-in types and versions)
• device IDs
• operating system
• hardware version
• device settings (e.g. language and time zone)
• time zone setting
• file & software names and types (associated with your device and/or the Site)
• information relating to your mobile operator or Internet Service Provider (ISP).

Information about your visit
• full Uniform Resource Locators (URL)
• clickstream to, through and from our Site (including date and time)
• pages and services you viewed or searched for
• demographic information (including age and gender)
• page response times
• download errors
• length of visits to certain pages
• page interaction information (like scrolling, clicks, and mouse-overs)
• traceable campaign links (e.g. in emails or via tracking URLs)
• methods used to browse away from the page
• phone number or social media handle used to connect with us.

Location data (if you opt-in)
We may ask for your location via cookies or your device settings. Your location might mean us checking what country or region you are in using any of the following:

• the coordinates (latitude/longitude) of your location,
• your full or partial IP address,
• your device ID (If you use Apple: your Identifier for Advertisers (IFA) code, or if you use Android your Android ID, or a similar device identifier).

If you agree to share your location with us, we'll use this to deliver location-specific content, advertising or other services, like checking for fraudulent transactions.

We may combine your location information with your device ID, so we can recognise your browser or device when you return to our Site.

What it is used for
To ensure content from our Site/ App is presented in the most effective manner for you and for your device.

To understand how people use our Site and our services, and how we can improve our Site and our services.

To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences.

Why we do this
It is important for us to continually learn and improve (and we balance this with your own rights).

For any cookies which aren't necessary for our Site or App to operate, with your consent.

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When we collect
If you contact us or give us feedback

What we collect
Contact Information
● first and last name,
● email address,
● billing and delivery address,
● phone number(s),
● social media handle

Communications Information
● emails,
● texts, in-app messaging & other digital messaging,
● calls,
● letters,
● survey responses,
● any in-person conversations you have with us.

What it is used for
To reply to you, including answering any questions and troubleshooting any issues you may have with our Site or our services.

To administer any forms or surveys you complete.

Why we do this
It is important for us to help you use our Site and our services, and to understand how we can improve.

It is part of a contract we've agreed to with you.

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When we collect
If you register for an account with us, subscribe to our services or publications or chose to invest with us

What we collect
Contact Information

Income/ Financial Information
● annual salary
● financial goals
● asset worth
● sources of income
● how much money you have saved

Account Information
● log-in information (username or similar identifier, passcode)
● marital status,
● title,
● age,
● gender (optional).
● interests, preferences and feedback.

What it is used for
Register you as new customer.

Manage our relationship with you.

Manage and collect payments/ investments.

Make personalised suggestions and recommendations to you.

Update you about technical changes or other service updates (for example, if we update our terms).

Ask you for feedback.

Use data analytics to develop insights, and to improve our Site, App and services, marketing, customer relationships and experiences, including combining and anonymising individuals' information.

Why we do this
It is part of a contract we've agreed to with you.

It is important for us to manage our business and our Site.

It is important for us to help you use our Site and our services, and to understand how we can improve.

We have to comply with the law.

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What we collect
If you sign up to receive news, updates or other marketing from us

Contact Information

Marketing preferences
● if you have opted-in to marketing or out of marketing,
● any specific marketing preferences.

What it is used for
Send you direct marketing, includes news, updates, or asking you to complete a survey

Why we do this
If you are a consumer, we do this with your consent.

If you are or work for a business or other organisation, we do this because it is important to us to grow or manage our business, or with your consent.

We also do this to comply with the law.

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When we collect
If you enter a competition, prize draw or promotion

Contact Information
Entry Information
● any information you provide as part of your entry – for example, your answers on an entry form or to a survey.

What it is used for
Administer our competitions, prize draws, promotions or surveys

Why do we do this
It is part of a contract we've agreed to with you, for example specific competition terms.

It is important for us to manage competitions, prize draws and promotions which we manage.

To comply with the law.

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When we collect
If you attend one of our events

Contact Information
Attendance Information
● any information you provide as part of your attendance – for example, any dietary requirements.
● Event surveys and feedback.

What is it used for
Manage and improve our events, including managing attendance, speakers, suppliers and getting feedback.

Why we do this
It is important for us to manage and improve our events.

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What are the legal reasons we can use your information?

If you are in the UK or the EU, we must have a relevant legal reason for each way we use your personal information.

Legal reasons include consent, a contract with you, complying with our legal obligations and things that are important to us.

Consent: We'll use your personal information to send you marketing if you have consented (where required by law).

You can opt-out of marketing at any time by clicking the “unsubscribe” link in any marketing we send.

We also use consent for some of the cookies we use (see our Cookie Notice for more detail).

Contract: We use your personal information to carry out an agreement you have with us (for example, our Terms), or if you ask us to do something so you can make an agreement with us.

We may send you service updates based on your agreement with us (for example, updates about books you have ordered).

Other things that are important to us: We may use your personal information if we need it for things that are important to us or another organisation, as long we balance this with your rights and interests.

Things that are important to us include:

o Administering, improving and expanding:

− Getting your feedback and reviews
− Providing and improving our Site, products and services
− Implementing and improving our security measures
− Growing our business and informing our marketing strategy.

o Marketing & advertising:

− Marketing and promoting Rosecut to an organisation you work for or provide services to.
− Measuring or understanding the effectiveness of our advertising, and showing you relevant advertising (including when you visit other websites).

o Fulfilling agreements with other organisations:

− Complying with any agreement we may have with an educational or other institution you attend, are part of, work for or provide services to.
− Enforcing or applying our terms or other agreements with you or with an organisation you work for or provide services to.

If you would like more information about how we balance our interests and your rights, please contact us at support@rosecut.com.

Legal compliance: We may need to use your personal information to comply with our legal obligations and/or any court orders.


Who do we share your information with?

We may share your personal information with our group companies, our service providers and professional advisors, our business partners, and if we are legally required to.

We may share your personal information with:

● any member of our group, which means our group companies, including our ultimate holding company, and its subsidiaries and/or our subsidiaries who may support our processing of personal information under this Notice. If any of these group companies use your information for direct marketing, we will only transfer information to them for that purpose with your prior consent.
● our service providers, organisations who support the services we offer through the Site and only process your personal information on our behalf, following our instructions and data protection law.

Service providers help us with things like:

o website and data hosting,
o website and application analytics and search engine providers,
o managing marketing lists,
o sending emails and other correspondence,
o customer service and feedback,
o invoicing and payment processing,
o credit reference agencies (only if we need your credit score for our due diligence checks)
o IT support.

Our service providers will only use your information to provide their services to us.

● if we run surveys, competitions, promotional campaigns, offers or other activities and you opt-in with a partner (for example, if you chose to enter a prize draw we manage with a partner organisation). We will provide more detailed privacy information at the time.
● potential investors, or if we sell or buy any business or assets then a potential seller or buyer.
● should you choose to create an investment account with us, we will share your personal information with our custodian partners including WealthKernel Limited, Credo Wealth and LGT Group.
● our auditors, legal advisers and other professional advisers.
● anyone that we must disclose information to in order to protect our rights, property, or safety, our customers, or other third parties, and to enforce our rights under this Notice or under any agreement (for example, our terms) with you. This includes exchanging information with other companies and organisations for the purposes of detecting and preventing fraud, credit risk and cyber-crime.
● if required to do so under a court order or if we are (or believe we are) under a duty to comply with any legal obligation. This includes exchanging information with law enforcement agencies, regulators, or other similar government bodies.


Where do we store your information?

We are based in the United Kingdom at the following address:

Rosecut Technologies
Warnford Court
29 Throgmorton Street
London EC2N 2AT
United Kingdom

We may transfer your personal information outside the UK (or, if you are in the European Union ("EU") or European Economic Area ("EEA"), outside of the EU/EEA):

● to store it, and so we can provide our Site, App and services to you.
● where we are legally required to do so.

We may also store your information with third parties who work with us to help us to provide our services to you.

If we transfer your information internationally, we will take steps to ensure your information is legally protected.


How do we protect your information?

You're in safe hands. We protect your information in various technical, organisational and contractual ways:

● we use technical security measures (for example, end-to-end encryption or multi-factor authentication), and
● we take steps to make sure that only people who need to use your data have access to it, and that our staff understand how use personal data responsibly and keep it safe.
● we require our service providers to contractually promise to take steps to protect the data we give them (including limiting the data we share, and requiring confidentiality commitments).
● we work to avoid personal data breaches, but we are prepared if a breach does happen. We will notify you, and any applicable regulator, of a breach if we are legally required to (if it's higher risk breach, we might need to notify, but if it's a lower risk breach, we may not need to tell you).


What if we link to other websites?

We may link to other websites (including apps). The websites will have their own privacy information, which you should read before using or sharing personal information with the site.

We are not responsible or liable for these websites, any content on them, or their policies and notices. A link does not mean we endorse the views of the linked website. We have no control over the availability of any of these websites.


How long do we keep your information for?

We usually don’t keep your information for any longer than we need to, but we might keep it for longer if we need to fix an issue or keep records.

We will usually keep personal information:

● for as long as necessary for the original reasons we collected it (for example, for as long as you have an account with us), and
● for up to six years after that to identify any issues and resolve any legal proceedings.

We may keep your personal information for longer:

● if you complain (so we keep our complaint records for long enough),
● if we know about pending or current legal proceedings, or reasonably believe there is a chance of legal proceedings,
● in some circumstances, if applicable law says we are required to.

If you opt-in to marketing from us and later change your mind (or object to any other use of your personal information), we may keep a record of your opt-out or objection for longer so we can demonstrate we respect your preferences.

We may combine and anonymise individuals' information, and we may keep anonymised information indefinitely.


How can you control your personal information?

If you are in the UK or the EU, you have rights over your personal information (just so you know, these aren't absolute). Please ask us and we would be happy to help.

If you are in the UK or the EU, you may have the right to:

● find out what information we hold about you.
● ask us to provide you with a copy of your information.
● ask us to make changes to your information.
● ask us to correct, delete, limit or stop using your information.
● ask us to move your information to a third party.
● change your mind about us holding your information (or sending you marketing).

These rights are not absolute – if a right doesn't apply, or only applies to some of your information or some of the things we do with it, we'll let you know as part of our reply to you.

If you would like to exercise any of these rights over your information, you can contact us at contact@rosecut.com.

Our Data Protection Officer is Daniel Greenhough. You can email them at: daniel.greenhough@rosecut.com.

If you have any concerns, you have the right to make a complaint to a data protection supervisory authority.

● If you are in the UK, the supervisory authority is the Information Commissioner's Office (ICO). You can visit their website at www.ico.org.uk.

● If you are in the EU, you can find your local data protection authority here.


What have we last changed in this Privacy Notice?

We last updated this Notice on 24 August 2021.