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Privacy Policy

The following privacy policy (“Privacy Policy”) sets forth Turing Holdings LLC d/b/a Roll (“Roll” “we” or “us”) policy with respect to information, including personally identifiable and non-personally identifiable data (“Personal Data”) and other information, Roll collects from visitors to either the Roll website found at https://tryroll.com/ or the Roll mobile application (the “Roll App”) collectively (the “Roll Properties”).  The Roll Properties have been created to allow creators and followers to interact, for creators to create and send personalized loyalty points type tokens (“Social Money”) to followers that can be redeemed for experiences (the “Service”).  You may register for an account on the Roll Properties as either a creator (“Creator”) or a basic user (“Follower”).   

This Privacy Policy supplements and forms a part of Roll’s Terms of Service. Capitalized terms not defined here have the meaning given to them in the Roll Terms of Service.

When you use any part of the Service, you are consenting to the collection, transfer, storage, disclosure and other uses of your information as described in this Privacy Policy.

This Privacy Policy does not apply to the practices of third parties that Roll does not own or control, including third-party websites, services and applications that you elect to access in connection with the Roll Properties and the Service, or to individuals that Roll does not manage or employ. While we attempt to facilitate access only to those third-party services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those third-party services. We encourage you to carefully review the privacy policies of any third-party services that you access.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

Information We Collect

When you interact with us through the Roll Properties or the Service, we may collect Personal Data and other information from you, as further described below.

Personal Data That You Provide: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for access to the Roll Properties or Service or use the Roll Properties or Service.   

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us, you acknowledge and agree that such Personal Data may be transferred and stored from your current location to the offices and servers of Roll and the authorized third parties referenced below.

To sign up for the Roll Properties or the Service as a basic user, you will provide some or all of the following information:

  • full name
  • email address
  • photograph to be used as profile image

To sign up for the Roll Properties or the Service as a Creator, you will provide some or all of the following information:

  • full name or company name
  • email address
  • photograph to be used as profile image

In addition, you may be asked to create a password to access your account on the Roll Properties or through the Service. It is your responsibility to keep your password secure and not share it with anyone.

Public Profiles:  You may be given the opportunity to create a public user profile.  If you create a Creator account, the following information may appear to the public:

  • your full name
  • public information about your social money such as it’s name, symbol and image
  • other Creators you “follow” on Roll, via holding their social money

If you create a basic user account, the following information may appear to the public. 

  • your full name
  • Creators you “follow” on Roll, via holding their social money

Other Information We Collect

Non-Identifiable Data: When you interact with the Roll Properties, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Roll may store such information itself or such information may be included in databases owned and maintained by Roll affiliates, agents or service providers. The Services may use such information and pool it with other information. It is important to note that no Personal Data is available or used in this process.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Roll Properties and the Service, Roll may conduct research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Roll may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Roll may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Device Identifiers: The Roll Properties or the Service, through its third-party providers, may collect device-specific information when you access the Service using a mobile device. Device information may include unique device identifier, media access control address, network information, and hardware model, as well as non-personally identifiable usage and traffic data and information about how the device interacts with the Roll Properties or the Service. This type of data enables Roll and third parties authorized by Roll to figure out how often individuals use parts of the Roll Properties or the Service and learn more about our users’ demographics and Internet behaviors, so that we can analyze, operate and improve our products and services.

Location Information: The Roll Properties or the Service may collect and use your location information (for example, by using the GPS on your mobile device) to provide certain functionality of the Roll Properties or the Service. If you choose to enable our location features, your location information may be publicly displayed within the Roll Properties or the Service. Please keep in mind that other users can see this information about you, and they may use it or disclose it to other individuals or entities outside of our control and without your knowledge. Your location information may be subject to abuse, misuse, and monitoring by others, so please be careful if you choose to enable location functionality. We may also use your location information in an aggregate way, as described above in the “Aggregated Personal Data” section.

Cookie Policy

We use, and allow certain other companies to use, Cookies on the Roll Properties and our Services to analyze our traffic, and to recognize your device.  This section explains what cookies are, how we use Cookies and similar technologies on the Roll Properties and our Service and what you can do to manage how Cookies are used.

WHAT ARE COOKIES?

A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Roll Properties and Service.  The Cookie will collect information relating to your use of the Roll Properties or the Service, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Roll Properties via a link from third party site, the URL of the linking page. 

In addition to Cookies, the Roll Properties or the Service may use web beacons.  Web beacons allow us to count the number of users who have visited or accessed the Roll Properties or the Service and to recognize users by accessing our cookies. We may employ web beacons to facilitate administration and navigation of the Roll Properties or the Service, to track the actions of users of the Roll Properties or the Service, to compile aggregate statistics about usage and response rates on the Roll Properties or the Service, and to provide an enhanced online experience for visitors to the Roll Properties or the Service. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color.  A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF. 

WHAT ARE THE DIFFERENT TYPES OF COOKIES AND HOW DO WE USE THEM?

Essential – These are Cookies which are essential for the running of the Roll Properties and Services. Without these Cookies, parts of the Roll Properties and Service would not function.  These Cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

Examples of how we may use essential Cookies include:

  • Setting unique identifiers for each unique visitor, so that website numbers can be analyzed.

Functional – These Cookies are used to remember your preferences on the Roll Properties and Services and to provide enhanced, more personal features. The information collected by these Cookies is usually anonymized, so we cannot identify you personally.  Functional Cookies do not track your internet usage or gather information which could be used for selling advertising.

Examples of how we may use functional Cookies include:

  • Gathering data about visits to the Roll Properties and Services, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from
  • Eliminating the need for returning users to re-enter their login details.

Analytical Performance – Analytical performance Cookies are used to monitor the performance of the Roll Properties, for example, to determine the number of page views and the number of unique users on the Roll Properties and Services. We use this information to improve user experience or identify areas of the Roll Properties and Services which may require maintenance.  The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.

Examples of how we may use analytical Cookies include:

  • Measuring users’ behavior 
  • Analyze which pages are viewed and how long for and which links are followed to better develop the Roll Properties and Services

Third Party Cookies – You may notice on some pages of the Roll Properties and Services that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own Cookies on your device. We do not control the use of these third party Cookies and cannot access them due to the way that Cookies work, as Cookies can only be accessed by the party who originally set them. Please check the third party websites for more information about these Cookies.

HOW CAN YOU MANAGE OR OPT OUT OF COOKIES?

Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control Cookies. In some cases, you can choose to accept Cookies from the primary site, but block them from third parties. In others, you can block Cookies from specific advertisers, or clear out all Cookies. Deleting or blocking Cookies may reduce functionality of the Roll Properties and the Services. 

To learn more about how to reject Cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.

Opting out of Analytical Performance Cookies

If you would like to opt out of Analytics Cookies, please do so by clicking on the links below:

Google Analytics: https://tools.google.com/dlpage/gaoptout

FURTHER INFORMATION AND CONTACT DETAILS

If you have any questions about or if you would like more information on the Cookies that we use and their purposes, please contact us at the email address set forth below.

Our Use of Your Personal Data and Other Information

The Roll Properties may use the information collected in the following ways: 

  • To operate and maintain the Roll Properties; 
  • To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings; 
  • To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts; 
  • To respond to your comments or inquiries; 
  • To provide you with user support; 
  • To track and measure advertising on the Roll Properties; or,
  • To protect, investigate, and deter against unauthorized or illegal activity.

Roll uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such Services and to monitor your use of such Services. Roll and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. Roll and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as at [email protected].

You acknowledge that this information may be personal to you, and by creating an account and providing such information, you allow others, including Roll, to identify you and therefore you may not be anonymous. Roll Properties user profiles are available for view by Roll and other Roll Properties’ users, and other users can discover and follow creators through the Service. Content that you post on, through, or in connection with the Service, including on third party services, such as your social media accounts, may also be public.

If Roll intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

Below are the types of lawful basis that we will rely on to process your Personal Data:

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected].
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
  • Consent means where you have consented to a certain use of your Personal Data.

Our Disclosure of Your Personal Data and Other Information

Roll will not sell, distribute, or reveal users’ email addresses or other personal information, except when required by law, without their consent. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties: Roll, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Roll may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Roll, (iii) act in urgent circumstances to protect the personal safety of users of the Service or the public, or (iv) protect against legal liability.

The Roll Properties may share your information with third parties when you explicitly authorize us to share your information. Additionally, the Roll Properties may use third-party service providers to service various aspects of the Roll Properties. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. The Roll Properties currently uses the following third-party service providers: 

  • Google Analytics – this service tracks usage and provides information such as referring websites and user actions on the Roll Properties. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics. 
  • MailChimp – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications.

At this time, your personal information is not shared with any other third-party applications. This list may be amended from time to time in Roll’s sole discretion. 

How We Protect Your Personal Information: We strive to take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of sensitive personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to personal information. Your account is also protected by a password for your privacy and security and you must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately, limiting access to your devices, and by signing off after you have finished accessing your account. Please keep in mind, however, that no method of storage or transmission over the Internet is completely secure, so your use of the Roll Properties and the Service and provision of information to us is at your own risk.

Your Choices

You may request deletion of your personal information by sending an email to [email protected], but in some cases, we may be required to keep your information by law. In such a case, it would no longer be active and would be kept separately in an archive.

Under laws in certain countries in which we operate, customers and other visitors to the Roll Properties from those countries have a right to access Personal Data about themselves, and to amend, correct or delete Personal Data that is inaccurate, incomplete or outdated.  We will, upon request, provide you with confirmation regarding whether we are processing Personal Data about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct, amend, or delete your Personal Data that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise consistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Information that you request. 

Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, that if we have already disclosed some of your Personal Data to third parties, we cannot access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Roll other than Personal Data collected through the Roll Properties or the Service. This Privacy Policy shall not apply to any unsolicited information you provide to Roll through the Roll Properties or the Service or through any other means. This includes, but is not limited to, information posted to any public areas of the Roll Properties or the Service, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Roll shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children

Roll does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Roll Properties or the Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Roll Properties or the Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Roll through the Roll Properties or the Service, please contact us immediately at [email protected], and we will use our best efforts to promptly remove that information from our databases.

Links to Other Web Sites

This Privacy Policy applies only to the Roll Properties and the Service. The Roll Properties may contain links to other web sites not operated or controlled by Roll (the “Third Party Sites”). The policies and procedures described here do not apply to the Third Party Sites. The links from the Roll Properties do not imply that Roll endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Visiting The Roll Properties from Outside the United States

This Privacy Policy is intended to cover collection of information from residents of the United States. If you are accessing the Roll App or the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located. The data protection and other laws of the United States might not be as comprehensive as those in your country.

Email Communications

If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.

Other Terms and Conditions

Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, the Roll App, or other users; or (d) protect, in an emergency, the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations in connection with credit risk reduction and fraud protection.

ARBITRATION

This Privacy Policy will be governed and construed in accordance with the laws of the State of New York. Any controversy or claim arising out of or relating to the Privacy Policy, or the breach thereof, shall be settled by arbitration administered by the American Arbitration Association (“AAA”) under its Commercial Arbitration Rules, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. The place of any such arbitration shall be in or near Manhattan County, New York. The parties also agree that the AAA Optional Rules for Emergency Measures of Protection shall apply to the proceedings.

Changes to Roll’s Privacy Policy

The Roll Properties and the Service may change from time to time. As a result, at times it may be necessary for Roll to make changes to this Privacy Policy. Roll reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated below. Your continued use of the Service after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting Roll

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.  To unsubscribe from any communications, please contact us at the email address below.

Please also feel free to contact us if you have any questions about Roll’s Privacy Policy or the information practices of the Services.

You may contact us as follows:  [email protected].

Last updated:  July 22, 2019