PRIVACY POLICY

Updated: January 10, 2022

Rosy Wellness, Inc. (“Rosy”) respects your privacy and the privacy of others. This PRIVACY POLICY (this “Privacy Policy”) is intended to explain Rosy’s privacy practices with respect to the www.meetrosy.com website (together with its pages, features, and functions, and any mobile versions of the foregoing, the “Site”) and the Rosy mobile application that links to this Privacy Policy (together with its sections, features, and functions, the “App”). This Privacy Policy is also intended to provide you (together with any person helping you visit, access, register with or use the Site and/or the App, “you” or “your”) with an overview of the following:

• the type of information about you Rosy collects through the Site and the App;
• how Rosy collects that information;
• how Rosy uses that information;
• who will have access to that information; and
• Rosy’s security measures for protecting that information.

This Privacy Policy applies to information collected through the Site and/or the App. Carefully read this Privacy Policy in its entirety.

You are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as Rosy’s Terms and Conditions, whenever you create, register with or log into an account on or through the Site and/or the App. Similarly, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as Rosy’s Terms and Conditions, whenever you visit, access, register with or use the Site, the App or any products or services provided by Rosy on or through the Site and/or the App; and your continuing visit, access, registration with or use of any of the foregoing reaffirms your acceptance and agreement in each instance.

As used herein, the term “personal information” means information (including personally identifiable information) that would allow someone to specifically identify you or contact you physically or online (e.g., your name, physical address, telephone number, email address, social security number); and the term “non-personal information” means any information other than personal information that Rosy may collect from you.

1. A Special Note About Minors.

The Site is a general audience website intended for use by adults. Neither the Site nor the App is designed or intended to attract, and is not directed to, children under eighteen (18) years of age, let alone children under thirteen (13) years of age. Rosy does not collect personal information through the Site or the App from any person it actually knows to be under thirteen (13) years of age. If Rosy obtains actual knowledge that it has collected personal information through the Site or the App from a person under thirteen (13) years of age, then it will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Furthermore, if you are under eighteen (18) years of age, then you (or your parent or legal guardian) may at any time request that Rosy remove content or information about you that is posted on the Site and/or the App. Please submit any such request (“Request for Removal of Minor Information”) to privacy@meetrosy.com, with a subject line of “Removal of Minor Information.”

For each Request for Removal of Minor Information, please state “Removal of Minor Information” in the email or letter subject line, and clearly state the following in the body:

a. the nature of your request;

b. the identity of the content or information to be removed;

c. whether such content or information is found on the Site or the App;

d. the location of content or information on the Site or the App (e.g., providing the URL for the specific web page the content or information is found on);

e. that the request is related to the “Removal of Minor Information;”

f. your name, street address, city, state, zip code and email address; and

g. whether you prefer to receive a response to your request by mail or email.

Rosy is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.

Please note that the aforementioned removal does not ensure complete or comprehensive removal of such content or information posted on the Site or the App.

Also, please note that Rosy is not required to erase or otherwise eliminate, or to enable erasure or elimination of, such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires Rosy to maintain the content or information; when the content or information is stored on or posted to the Site or the App by a third party other than you (including any content or information posted by you that was stored, republished or reposted by the third party); when Rosy anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of Rosy’s voluntary practices concerning the collection of personal information through the Site and/or the App from certain minors, and is not intended to be an admission that Rosy is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

2. Categories of Information Collected.

Rosy may collect personal and non-personal information about you through the Site and/or the App. The categories of such information might include, for example:

• Your name (first, last and/or middle);
• Your unique identifiers (e.g., username, pseudonym, Twitter handle);
• Your login information for the Site and/or the App (e.g., username, password, security questions and answers);
• Your company name and/or title;
• Your home and/or business contact information (e.g., mailing address, email address, telephone number, facsimile number);
• Your profession;
• Your gender;
• Your electronic signature;
• Your transactional information (e.g., offers, orders, pricing, payments, purchases, purchaser, seller, item information, shipping terms, comments, ratings, feedback, and communications made on, through, or with respect to the Site or the App);
• Your business contact information (e.g., company, title, mailing address, email address, telephone number, facsimile number, tax identification number);
• Your computer, mobile device and/or browser information (e.g., IP address, mobile device ID information, operating system, connection speed, bandwidth, browser type, referring/exit web pages, web page requests, cookie information, hardware attributes, software attributes);
• Information about, and/or information found on, your pages and accounts with third-party websites, networks, platforms, servers and applications (e.g., Facebook, Google Plus, LinkedIn);
• Usage activity concerning your interactions with the Site, the App and/or third-party websites, networks, platforms, servers or applications accessed on or through the Site and/or the App (e.g., how you accessed the Site or the App, where you go when you leave the Site or the App, number of clicks on a page or feature, amount of time spent on the Site or the App or a page or feature, and identity of third-party websites, networks, platforms, servers and applications accessed through the Site or the App);
• Usage activity concerning videos, articles, and other content provided to or accessed by you on or through the Site or the App (e.g., viewing habits, viewing preferences, viewing history, title selections, favorites, streams, downloads, demographics and closed captioning selections);
• Information concerning the type of content that you access or might prefer to access on the Site and/or the App;
• Usage activity concerning communications with other users (e.g., interactions on online forums, chat rooms, and bulletin boards);
• Information about third parties that you refer to Rosy (e.g., name, contact information, relationship);
• Information set forth in the Site’s and/or the App’s online account registration, subscriber profile, and/or subscriber directory forms completed by you;
• Information set forth in your user account and profile with the Site and/or the App;
• Statements or content (e.g., comments, videos, photographs, images), and information about such statements or content, which you submit or publish on or through the Site and/or the App, or which are accessed via your public or linked social media pages (e.g., Facebook, Google Plus, LinkedIn);
• Your answers to questionnaires submitted on, through, or in relation to the Site and/or the App;
• Information relating to your mental health, medical, prescription medication, and alcohol history;
• Information relating to your sexual activities, history, or preferences (including, without limitation, your “Sexual Wellness Score”);
• Your geolocation;
• The name associated with your mobile device;
• The telephone number associated with your mobile device; and
• Your mobile device ID information.

3. How Information Is Collected.

Rosy might collect personal and non-personal information from you when you visit, access, register with, or use the Site and/or the App or any of its products or services; when you request, register for, order or purchase any products or services on, through or in relation to the Site; when you “sign in,” “log in” or the like to the Site and/or the App, even if through third-party online social media sites or accounts (e.g., Facebook, Google Plus, LinkedIn); when you allow the Site to access, upload, download, import or export content found on or through, or to otherwise interact with, your computer or mobile device (or any other device you may use to visit, access, register with or use the Site or the App) or online accounts with third-party websites, networks, platforms, servers or applications (e.g., your online social media accounts, your cloud drives and servers, your mobile device service provider); or whenever Rosy asks you for such information, such as, for example, when you answer an online survey or questionnaire.

In addition, if you or a third party sends Rosy a comment, message or other communication (such as, by way of example only, email, instant message, letter, fax, phone call, or voice message) about or referencing you or your activities in relation to the Site or the App, then Rosy may collect any personal or non-personal information provided therein or therewith.

Rosy might also use various tracking, data aggregation and/or data analysis technologies, including, for example, the following:

• Cookies, which are small data files (e.g., text files) stored on the browser or device you use to view a website or message. They may help store user preferences and activity, and may allow a website to recognize a particular browser or device. There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies. Cookies may record information you access on one page of a website to simplify subsequent interaction with that website, or to help streamline your transactions on related pages of that website. Most major browsers are set up so that they will initially accept cookies, but you might be able to adjust your browser’s or device’s preferences to issue you an alert when a cookie is downloaded, or to block, reject, disable, delete or manage the use of some or all cookies on your browser or device.
• Flash cookies, which are cookies written using Adobe Flash, and which may be permanently stored on your device. Like regular cookies, Flash cookies may help store user preferences and activity, and may allow a website to recognize a particular browser or device. Flash cookies are not managed by the same browser settings that are used for regular cookies.
• Web beacons, which are pieces of code embedded in a website or email to monitor your activity on the website or your opening of the email, and which can pass along information such as the IP address of the computer or device you use to view the website or open the email, the URL page on which the web beacon is located, the type of browser that was used to access the website, and previously set cookie values. Web beacons are sometimes used to collect advertising data, such as counting page views, promotion views or advertising responses. Disabling your computer’s, device’s or browser’s cookies may prevent some web beacons from tracking or recording certain information about your activities.
• Scripts, which are pieces of code embedded in a website to define how the website behaves in response to certain key or click requests sent by the user. Scripts are sometimes used to collect information about the user’s interactions with the website, such as the links the user clicks on. Scripts are often times temporarily downloaded to the user’s computer or device from the website server, active only while the user is connected to the Site and/or the App, and deactivated or deleted when the user disconnects from the Site and/or the App.
• Analytic tools and services, which are sometimes offered by third parties, and which track, measure and/or generate information about a website’s or program’s traffic, sales, audience and similar information, and which may be used for various reasons, such as, for example, statistical research, marketing research, and content ratings research, and conversion tracking. Google Analytics and Alexa are common examples of these types of technologies. Rosy may also use other third-party analytic tools and services.
• Other third-party data tracking or analytic technologies (e.g., deep linking, eTags, device fingerprinting or cross-device tracking).

Please be advised that if you choose to block, reject, disable, delete or change the management settings for any or all of the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies, then certain areas of the Site and/or the App might not function properly.

By visiting, accessing, registering with or using the Site and/or the App, you acknowledge and agree in each instance that you are giving Rosy permission to monitor or otherwise track your activities on the Site and/or the App, and that Rosy may use the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies.

4. Use of Information Collected.

Rosy may use the personal and/or non-personal information it collects from you through the Site or the App in a variety of ways. Examples of those uses might include, for example:

• Place, fulfill, process and/or track your requests;
• Facilitate and maintain your access of, registration with and use of the Site, the App and/or their products and services;
• Facilitate and maintain your movement throughout the Site and/or the App;
• Facilitate and maintain your accounts and profiles with the Site and/or the App;
• Provide customer service;
• Operate the Site, the App, and their products and services;
• Send you communications like, for example, administrative emails, answers to your questions and updates about the Site and/or the App;
• Sending you “push notifications” via the App to your mobile device;
• Allow you to communicate with others through the Site or the App like, for example, through online messages, online forums, chat rooms, individual or group coaching sessions, and bulletin boards;
• Provide you with information about Rosy, its parents, its subsidiaries, its affiliates and/or their respective businesses, products and services;
• Provide you with information about third-party businesses, products and/or services;
• Provide you with customized content, services, and user experiences, including advertising and promotional information (e.g., targeted ads, retargeted ads), recommendations for content you might like, and cross-app or cross-site functionality across multiple third-party websites and mobile apps;
• Improve the Site, the App and/or their content, products, and services;
• Improve the products, services, marketing and/or promotional efforts of Rosy, its parents, its subsidiaries and/or its affiliates;
• Create new products, services, marketing and/or promotions for Rosy, its parents, its subsidiaries and/or its affiliates;
• Market the businesses, products and/or services of Rosy, its parents, its subsidiaries and/or its affiliates;
• Help personalize user experiences with the Site and/or its products and services;
• Analyze traffic to and through the Site and/or the App;
• Analyze user behavior and activity on or through the Site and/or the App;
• Conduct research and measurement activities for purposes of product and service research and development, advertising claim substantiation, market research and other activities related to Rosy, its parents, its subsidiaries, its affiliates, the Site, the App and/or their features, products and services;
• Monitor the activities of you and others on or through the Site and/or the App;
• Create device fingerprints and profiles about the possible relationships among different browsers and devices;
• Create consumer profiles, which may combine your personal or non-personal information from the Site and/or the App with your personal or non-personal information from another source or service;
• Protect or enforce Rosy’s rights and properties; and/or
• Protect or enforce the rights and properties of others (which may include you), assuming that Rosy believes it has an obligation to do so.

Rosy reserves the right to use your personal and non-personal information when:

• Required by applicable law, court order or other governmental authority (including, without limitation and by way of example only, in response to a subpoena or other legal process); and/or
• Rosy believes in good faith that such use is otherwise necessary or advisable (including, without limitation and by way of example only, to investigate, prevent, or take legal action against someone who may be causing injury to, interfering with, or threatening the rights, obligations or properties of Rosy, a user of the Site and/or the App (which may include you) or anyone else who may be harmed by such activities or to further Rosy’s legitimate business interests).

5. Sharing of Information Collected.

Rosy reserves the right, but not the obligation, to share your personal information with the following:

• Rosy’s employees, agents, and administrators;
• Rosy’s accountants, financial advisors, and legal advisors;
• Rosy’s parents, subsidiaries, and affiliates;
• Independent contractors or others providing individual or group coaching services;
• Service providers and other third parties who help Rosy provide, manage, administer, maintain, monitor, distribute, operate, or facilitate the Site and/or the App, who help Rosy develop, market or provide its products and services, or who help further Rosy’s business efforts, e.g., web hosting companies, website administrators, mobile app distribution platforms, support services companies, data analytics and analysis companies, advertising partners, and payment processing vendors (including, for example, through the Apple App Store), as needed in order for them to perform such services;
• Law enforcement or other governmental entities in response to what Rosy believes to be an allegation or suspicion of illegal activity, a request relating to a civil or criminal investigation, an allegation or suspicion of illegal activity, a subpoena, a court order, or any other activity that may expose Rosy to liability if it does not act or comply;
• Any third parties who Rosy believes are necessary to help or allow Rosy to protect and enforce its rights and properties, including, without limitation, to enforce its rights under Rosy’s Terms and Conditions or any other agreements it has with you, and to protect and enforce its intellectual property rights;
• Any third parties who Rosy believes are necessary to help or allow Rosy to protect the rights and properties of others (which may include you), assuming that Rosy believes it has an obligation to do so; and/or
• Other parties, with your express or implied consent, when Rosy has specifically requested your consent or when you understand that such sharing is necessary for the transaction.

Rosy also reserves the right to share your personal information with third parties in connection with or as a result of any potential or actual merger, acquisition or other event involving a change in ownership or control of Rosy or Rosy’s business (whether by sale of assets, merger, stock purchase or otherwise).

Rosy also reserves the right to use data collected on, through, or in relation to the Site and/or the App (including, without limitation, your personal information) for use in conducting medical research, studies, and publications (and any other research, studies, and publications) and to share the same with third parties; provided, however, that any such use of such data will be on an anonymized basis.

Rosy does not limit the ways in which it might use or share non-personal information – and Rosy reserves the unencumbered right, but not the obligation, to use or share non-personal information – because non-personal information does not identify you. For example, Rosy may freely share non-personal information with its parent, subsidiary and affiliated companies, its vendors, its suppliers, its representatives and its customers, as well as with other individuals, businesses and government entities.

You may choose to share certain information and/or follow other users on the Site and/or the App. You may choose to share your contact information with other users or provide it publicly.

6. Data Retention.

Rosy may retain your personal information and non-personal information for as long as it believes necessary. Rosy may dispose of or delete any such personal information or non-personal information at any time, except as set forth in any other agreement or document executed by both you and Rosy concerning the same or as required by law.

7. Transactions.

All credit card, debit card and other monetary transactions conducted with respect to the Site and/or the App, if any and as applicable, shall occur through an online payment processing application (including through the Apple App Store). Such online payment processing applications shall be provided by third-party online payment processing vendors. Rosy’s relationship with a vendor, if any, is merely contractual in nature, and that vendor is in no way subject to Rosy’s direction or control; thus, their relationship is not, and should not be construed as, one of fiduciaries, franchisors-franchisees, agents-principals, employers-employees, partners, joint venturers or the like. You should review the privacy policy for any third party payment processor for its terms.

8. Third Party Applications and Networks.

The Site, the App and/or any communications sent through or as a function of the Site and/or the App might contain links to third-party websites, networks, platforms, servers and/or applications. Third-party websites, networks, platforms, servers and/or applications might also contain links to the Site and/or the App.

In addition, you might have the opportunity to access the Site and/or the App using your online user accounts with certain third-party websites, networks, platforms, servers or applications, which might be subject to separate privacy policies pertaining to those third-party websites, networks, platforms, servers or applications. Rosy might also collect information from those third-party websites, networks, platforms, servers or applications (such as, for example, your name, gender, date of birth and personal interests, when you “like” or click links provided by or through those third-party websites, networks, platforms, servers, or applications and other information available through your online account or page with those third-party websites, networks, platforms, servers or applications).

Moreover, Rosy might permit third parties to use their own tracking, data aggregation and/or data analysis technologies like the ones described above (e.g., third-party cookies).

To the fullest extent permitted by law, Rosy is not responsible for, and you hereby release Rosy from any and all liability which may arise from, such third-party websites, networks, platforms, servers and applications (including, without limitation, the privacy policies and practices of such third-party websites, networks, platforms, servers and applications). It is your responsibility, and your responsibility alone, to carefully read, accept and comply with any and all relevant terms of use, waivers, and privacy policies associated with those third-party websites, networks, platforms, servers and applications.

9. Security.

Rosy implements security measures to help protect the personal information it collects through the Site and/or the App. For example, Rosy may encrypt the transmission of information through the Site and/or the App by using secure socket layer (SSL) technology.

Regardless of the foregoing, please observe that “perfect” or “100%” security does not exist on the Internet. Therefore, your access and use of the Site or the App, and your opening of any communications sent through or as a function of the Site or the App, are done at your own risk.

To help maintain the security of your personal information, Rosy asks that you please notify it immediately of any unauthorized visit, access or use of the Site and/or the App, or the loss or unauthorized use of your user access information for the Site and/or the App (e.g., username or password).

10. Retention, Review, and Change of Information Collected.

You may request at any time that Rosy provide you with an opportunity to review and change your personal information collected through the Site and/or the App, if any, or to no longer use your personal information to provide you with any products or services. Please submit any such request (“Request Concerning Personal Information”) to privacy@meetrosy.com, with a subject line of “Your Personal Information.”

For each Request Concerning Personal Information, please state “Your Personal Information” in the email or letter subject line, and clearly state the following in the body:

a. the nature of your request;

b. that the request is related to “Your Personal Information;”

c. your name, street address, city, state, zip code and email address; and

d. whether you prefer to receive a response to your request by mail or email.

Rosy is not responsible for any Request Concerning Personal Information that is incomplete, incorrectly labeled or incorrectly sent. You are solely responsible for the accuracy and content of your personal information, and for keeping your personal information current and correct.

11. Your California Privacy Rights.

The following section applies if you are a legal resident of California. As described above, Rosy collects certain types of personal information about your during your relationship with Rosy. The California Consumer Privacy Act (CCPA) provides California residents with certain rights relating to their personal information, including the right to request that we disclose the following information to you about our collection and use of your personal information over the past 12 months. You may submit a verifiable consumer request to us at privacy@meetrosy.com to request the following information:

• The categories of personal information we collected about you (paragraph 2 above).
• The categories of sources for the personal information we collected about you (paragraph 3 above).
• Our business or commercial purpose for collecting or selling that personal information (paragraph 4 above).
• The categories of third parties with whom we share that personal information (paragraph 5 above).
• The specific pieces of personal information we collected about you.
• If we sold or disclosed your personal information for a business purpose, the categories of personal information sold or disclosed about you, and the categories of third parties to whom the personal information was sold or disclosed, or a statement that we have not sold or disclosed such personal information about you.

We provide the following chart of the categories of personal information (as defined in the CCPA, with examples for each category) that we have collected within the last twelve months:

Category	Examples in this Category (some categories may overlap)	Collected Y/N
A. Identifiers	Real name, postal address, unique personal identifier, online identifier, Internal Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Y
B. Personal information described in California Customer Records statute [Cal. Civ. Code § 1798.80(e)]	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Y
C. Characteristics of protected classifications under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or credit, marital status, medical condition (AIDS/HIV status, cancer), 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), political activities or affiliations, familial status, source of income status, status as a victim of domestic violence, assault, or stalking.	Y
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Y
E. Biometric information	An individual’s genetic, physiological, biological or behavioral characteristics, or activity patterns that can be used to establish individual identity, including images of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which 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.	N
F. Internet or other electronic network activity information	Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.	Y
G. Geolocation data	Physical location and/or movements.	Y
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	N
I. Professional or employment related information	Current or past job history or performance evaluations	N
J. Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	N
K. Inferences drawn from other personal information	Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Y

Note that the CCPA’s definition of Personal Information does not include:

• Publicly available information lawfully made available to the general public from federal, state, or local government records (publicly available does not mean biometric information collected by a business about a consumer without the consumer’s knowledge) (information is not publicly available if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained);
• De-identified or aggregated consumer information;
• Information excluded from the CCPA’s scope, like:
  • Health or medical information covered by the Health Insurance Portability and Accessibility Act of 1966 (HIPAA), the California Medical Information Act (CMIA) or clinical trial data.
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We do not sell your personal information. During the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose (to our affiliates, service providers or third-party partners in connection with products or services we provide to you, including payment card processors, customer care, fraud preventions, analytics, messaging services (such as email and newsletters), and/or cloud service providers):

Category A: Identifiers

Category B: California Customer Records information

Category C: Characteristics of Protected Classifications

Category D: Commercial Information

Category F: Internet or other similar network activity

Category G: Geolocation data

Category K: Inferences

As set forth in paragraph 10 above, we also will process any requests to review and change your personal information or request that we no longer use your personal information and/or request the discontinuation (or opt-out) of Rosy’s sharing of your personal information with third parties.

For each California Privacy Rights Request, please submit a written request to privacy@meetrosy.com, with “Your California Privacy Rights” in the email or letter subject line, and clearly state the following in the body of the message:

a. the nature of your request under the CCPA;

b. that the request is related to “Your California Privacy Rights;”

c. your name, street address, city, state, zip code and email address; and

d. whether you prefer to receive a response to your request by mail or email.

Rosy is not responsible for a California Privacy Rights Request that is incomplete, incorrectly labeled or incorrectly sent. You are solely responsible for the accuracy and content of your personal information, and for keeping your personal information current and correct.

Please note that we may decline your request if we are unable to verify your identity or your authorization to make the request for another under applicable law. In addition, there may be reasons why we are unable to process a deletion request, including if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities;
• Debug products to identity and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records. If we decline your deletion request, we will provide a response stating why we were unable to comply with the request.

You may only make a verifiable consumer request under the CCPA twice within a 12-month period. We will not discriminate against your for exercising any of your CCPA rights.

Further, as required under applicable law, Rosy states that it currently does not respond to “do not track” (DNT) signals.

Finally, as explained further above, Rosy does not authorize third parties to collect your personal information when you use the Site and/or the App, except as expressly stated in this Privacy Policy. To the fullest extent permitted by law, Rosy is not responsible for, and you hereby release Rosy from any and all liability which may arise from, such third parties’ unauthorized collection of your personal information.

12. Modifications of this Privacy Policy.

Rosy may supplement, amend, or otherwise modify this Privacy Policy at any time without notice to you. Such supplements, amendments and other modifications will be posted on this or a similar page of the Site and/or the App, and shall be deemed effective as of their stated effective or modification dates. It is your responsibility to carefully review this Privacy Policy each time you visit, access, register with or use the Site and/or the App.

Again, by visiting, accessing, registering with or using the Site or the App, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as the most-recent version of Rosy’s Terms and Conditions, and your continuing visit, access, registration with or use of the Site or the App reaffirms your acceptance and agreement in each instance.

13. Severability.

If any term or condition of this Privacy Policy is deemed invalid or unenforceable by a court of law with binding authority, then the remaining terms and conditions shall not be affected, and the court shall reform the invalidated or unenforceable term or condition to the maximum extent permitted under the law and consistent with the intent of this Privacy Policy.

14. Contact Us.

Please direct any questions you may have about this Privacy Policy to privacy@meetrosy.com, with a subject line of “Privacy Policy.” The foregoing contact information may change from time-to-time by supplementation, amendment, or modification of this Privacy Policy.

15. International Users.

Our services are currently intended for users in the United States only. However, for any of the above purposes and in view of the ability to access the meetrosy.com website from other locations in the world, you agree that Rosy may transfer some or all of your personal information, your non-personal information and/or other data to countries outside your resident jurisdiction, and may process and/or store such information in the United States of America. You agree and recognize that countries outside of your jurisdiction may not have as comprehensive data protection laws as those existing in your resident jurisdiction. For more information please contact Rosy in the manner described in Section 14 above.

16. Modification Date.

This Privacy Policy was last modified on, and is dated effective as of, January 10, 2022.