Privacy Policy

Rouge Mocap, Inc., a California corporation (“Rouge”), respects the privacy of anyone who visits its website located at (www.rougemocap.com) (the “Website”), and shares your concerns regarding the security of data that your, or other users, may submit on the Website. Rouge’s Privacy Policy (the “Policy”) explains the information Rouge collects, how Rouge uses and protects such information, how users may access and update their own information, and how users may manage their privacy settings when using the Website.

Data Privacy - GENERAL

This privacy notice is to let you know how Rouge looks after your personal information. This notice explains how Rouge does this, and tells you about your privacy rights and how the law protects you. Rouge’s policy is to keep your data safe and private, not to sell your data, and to give you ways to manage your existing data at any time.

Data protection law says that Rouge is allowed to use personally identifiable information (“PII”) only if Rouge has a proper reason to do so. Rouge’s main scope of collecting and processing any provided PII is to ensure an optimal experience on the Website. It is Rouge’s legal duty to respect local or EU laws and only use PII when it is in your legitimate interest or, of course, when you consent to it. The types of PII that Rouge collects are set forth below.

TYPES OF DATA COLLEGED

The types of PII this Website may collect, by itself or through third parties, include: (i) Cookies; (ii) Usage Data; (iii) Contact Information (first name, last name, phone number and email address); (iv) Data communicated while using the Website; and/or (v) unique device identifiers for advertising (Google Advertiser ID or IDFA, for example). PII may be freely provided by you, or, in the case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all data requested by this Website is mandatory and failure to provide such data may make it impossible for this Website to function properly. In cases where this Website specifically states that certain data is not mandatory, users are free not to communicate such data without consequences to the availability or the functioning of the Website. Users who are uncertain about which PII is mandatory (if any) are welcome to contact Rouge.

Any use of Cookies (or other tracking tools) by this Website, or by the owners of third-party services used by this Website, serves the purpose of providing the Website, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party PII obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the data to Rouge.

METHODS OF PROCESSING DATA

Rouge takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of all data. Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In some cases, data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors. The updated list of these parties may be requested from Rouge at any time.

Rouge may process PII relating to you if one of the following applies:

You have given consent for one or more specific purposes. Note: Under some legislations Rouge may be allowed to process PII until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of PII is subject to European data protection law;

The provision of PII is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;

Processing is necessary for compliance with a legal obligation to which you are subject;

Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Rouge; and/or

Processing is necessary for the purposes of the legitimate interests pursued by Rouge, or by a third party.

In any case, Rouge will gladly help to clarify the specific legal basis that applies to any such processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

PII is processed at Rouge’s operating offices, as well as in any other places where the parties involved in the processing are located. Depending on your location, data transfers may involve transferring PII to a country other than your own. To find out more about the place of processing of such transferred data, you can check the section containing details about the processing of PII. You are also entitled to learn about the legal basis of data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by Rouge to safeguard your data. If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with Rouge using the information provided in the contact section.

RETENTION TIME

PII shall be processed and stored for as long as required by the purpose for which such PII has been collected. Therefore:

PII collected for purposes related to the performance of a contract between Rouge and you shall be retained until such contract has been fully performed; and

PII collected for the purposes of Rouge’s legitimate interests shall be retained as long as needed to fulfill such purposes. You may find specific information regarding the legitimate interests pursued by Rouge within the relevant sections of this document or by contacting Rouge.

Rouge may be allowed to retain PII for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, Rouge may be obliged to retain PII for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, PII shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.

PUPROSE OF PROCESSING DATA

PII is collected to allow Rouge to provide the Website, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as, without limitation, the following: remarketing and behavioral targeting, backup saving and management, traffic optimization and distribution, contacting you, advertising, analytics, displaying content from external platforms, tag management, content performance and features testing (A/B testing), hosting and backend infrastructure, registration and authentication, interaction with data collection platforms and other third parties, handling payments, interaction with external social networks and platforms, platform services and hosting, and infrastructure monitoring. For specific information about the PII used for each purpose, you may contact Rouge.

INFORMATION ON OPTING OUT OF INTERNET-BASED ADVERTISING

In addition to any opt-out feature provided by any of the services listed herein, you may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC(Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. Rouge thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps. You may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

YOUR RIGHT TO CONTROL AND ACCESS YOUR INFORMATION

You may exercise certain rights regarding your PII processed by Rouge. In particular, you have the right to do the following:

Withdraw your consent at any time. You have the right to withdraw consent where you have previously given consent to the processing of your PII.

Object to processing of your PII. You have the right to object to the processing of your PII if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

Accessing your Data. You have the right to learn if your PII is being processed by Rouge, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your PII undergoing processing.

Verify and seek rectification. You have the right to verify the accuracy of your PII and ask for it to be updated or corrected.

Restrict the processing of your PII. You have the right, under certain circumstances, to restrict the processing of your PII. In this case, Rouge will not process your PII for any purpose other than storing it.

Have your PII deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your PII from Rouge.

Receive your PII and have it transferred to another controller. You have the right to receive your PII in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your PII is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.

Lodge a complaint. You have the right to bring a claim before any competent data protection authority.

Where PII is processed for a public interest, in the exercise of an official authority vested in Rouge, or for the purposes of the legitimate interests pursued by Rouge, you may object to such processing by providing any grounds related to the particular situation to justify the objection. You must, however, know that, should your PII Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether Rouge is processing PII for direct marketing purposes, you may refer to the relevant sections of this document or contact Rouge.

Any requests to exercise your rights set forth herein or otherwise granted by law can be directed to Rouge through the contact details provided herein. These requests can be exercised free of charge and will be addressed by Rouge as early as possible and always within one month.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

Your PII may be used for legal purposes by Rouge in Court, or in the stages leading to possible legal action arising from improper use of this Website or the related services. You therefore declare that you are aware that Rouge may be required to reveal personal data upon request of public authorities.

In addition to the information contained in this privacy policy, this Website may provide you with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other PII (such as the IP Address) for this purpose.

More details concerning the collection or processing of PII may be requested from Rouge at any time. Please see the contact information set forth herein.

This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

YOU ALSO HAVE THE RIGHT TO COMPLAIN

Please let Rouge know if you are unhappy with how it has used your PII. The Website complies with applicable privacy laws, and Rouge is making efforts to adjust for the specific requirements of other markets. For any specific question related to regulatory aspects, please contact Rouge. This Policy shall be governed by and construed in accordance with United States law. Disputes arising in connection with this Policy shall be subject to the exclusive jurisdiction of Los Angeles, California courts. Rouge is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about Rouge’s compliance with the principles of Privacy Shield. Rouge asks that you first submit any such complaints directly to us via privacy@rougemocap.com. If you aren’t satisfied with Rouge’s response, please contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield or EU Data Protection Agency. Find out on their website how to report a concern.

OTHER INFORMATION

Visiting Rouge’s Websites from outside the United States.

If you are accessing the Website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where Rouge’s servers are located and its central database is operated. This Policy and the storage, use and disclosure of your information under this Policy, is governed by the laws on the United States. The Website is controlled and operated by Rouge from the United States and you expressly waive the application of any laws of any territory other than the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By accessing and/or using the Website, you understand and agree that your information may be transferred to Rouge’s facilities and/or those third parties with whom Rouge shares as described in this Policy, and the laws of the United States apply to the use, storage and disclosure of your information.

Security

Rouge takes reasonable security measures (including physical, electronic and procedural measures) intended to help safeguard your PII from unauthorized access and disclosure. For example, only authorized employees, contractors, and service providers are permitted to access PII, and they may do so only for permitted business functions. In addition, Rouge uses firewalls to help prevent unauthorized persons from gaining access to your PII.

Rouge wants you to feel confident using the Website. However, no system can be completely secure. Therefore, although Rouge takes steps to secure your information, Rouge does not promise, and you should not expect, that your PII, or searches, or other information will always remain secure. Please be advised that whenever you voluntarily disclose PII on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. Rouge cannot control what other third parties may do with the information you voluntarily post, so Rouge encourages you to exercise discretion and caution with respect to your personal information. Once you have posted information, you may not be able to edit or delete such information.

Anti-spam policy

Rouge is totally against spam, and only wants to be of service to its customers and those interested in the company. If you aren’t interested, please change your email preferences or let Rouge know.

Children's Privacy

The Website is for a general audience and is not directed to or intended for children under the age of 16. Accordingly, Rouge does not knowingly collect personal information from children under the age of 16, and if Rouge becomes aware that it has, Rouge will promptly delete any such information from its servers.

Changes

If Rouge is involved in a reorganization, merger, acquisition, or sale of all or any portion of Rouge’s assets, your PII may be transferred as part of that deal. Rouge will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event. Rouge may also revise this Policy from time to time, and will post the most current version on its website. If a revision meaningfully reduces your rights, Rouge will notify you.

How to contact Rouge

If you have any questions about this Policy or Rouge’s information-handling practices, please contact Rouge by email as follows: privacy@rougemocap.com, Attn: Privacy Officer.

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