Rocko Privacy Policy
Effective: August 15, 2024
This Privacy Policy (“Policy”) describes how Rocko Inc. (“Rocko,” “we,” “our,” “us”) collects, uses, and discloses certain personal information obtained through our website (“Site”), which is located at https://rocko.co/, as well as information that we process as part of offering you our services (collectively with the Site, the “Services”). By using our Services, you are agreeing to the terms of this Policy.
What Information We Collect and Maintain About You
We collect personal and other information from you directly when you provide it to us through the Services. We also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Services. We may also collect information from third parties in relation to providing you our Services.
Personal information collected from accountholders. If you make an account with us in relation to our Services, we will collect information from you related to establishing and maintaining your account (specifically, your name, IP address and the corresponding country, and email address). You may also elect to provide us with your phone number to receive SMS alerts. Finally, we collect information about transactions that you conduct through our Services, including the wallet addresses involved.
We may also collect information about you from third parties in relation to our Services. For example, when you sign in to your Coinbase account through our Services, we may collect your name, email address, and contact information. You may also elect to provide us with permissions that allow us to access additional information (e.g., your cryptocurrency wallet addresses, linked accounts, payment methods, transaction history, and/or wallet balances).
Other personal information collected through the Site. You can visit the Site without submitting any information that we can use to identify you personally. However, to use certain features on the Site, such as the “Contact” feature, you will be required to provide personal information. Such information could include, for example, your name and email address.
Web log data. When you use the Site, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
Cookies. We use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before visiting the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.
Web beacons. The Site or the emails that you receive from Rocko may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it can allow an email sender to determine whether a user has opened a particular email.
Third-party online tracking and behavioral advertising. We may partner with certain third parties to collect, analyze, and use the personal and other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from us. This information may be used for a variety of purposes, including online interest-based advertising, as discussed below (see “With Whom and Why We Share Your Information”).
How We Use and Process Your Information
We use the information that we collect (described in “What Information We Collect and Maintain About You,” above) for a variety of purposes. Our legal bases for processing your personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3) your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.
The purposes for which we use your information include to:
- Provide you with our Services;
- Enable you to process the transactions you initiate;
- Respond to your questions or requests concerning the Services;
- Fulfill the terms of any agreement you have with us;
- Fulfill your requests for our Services or otherwise enable you to complete a transaction that you initiate;
- Send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails;
- Deliver confirmations, account information, notifications, and similar operational communications;
- Improve your user experience and the quality of our products and Services;
- Comply with legal and/or regulatory requirements;
- Aggregate and deidentify information;
- Benchmark results for our customers;
- Serve advertisements;
- Analyze how visitors use the Services and various Services features, including to count and recognize visitors to the Services;
- Create new products and Services; and
- Manage our business.
With Whom and Why We Share Your Information
We may share any of the information described in “What Information We Collect and Maintain About You,” above, with other parties for a variety of purposes, as described below.
Third-party service providers. Rocko uses third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.
Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.
Interest-based advertising. The Services enable third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties may use the fact that you used our Services to target online ads to you. In addition, our third-party advertising networks might use information about your use of our Services to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.
The use of online tracking mechanisms by third parties is subject to those third parties’ privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Our Services do not currently respond to “do not track” browser headers.
Blockchain. Information about transactions that you conduct through our Services is stored on a publicly accessible blockchain. By using our Services, you acknowledge that this transaction information is stored on a public blockchain and is outside the scope of our Privacy Policy. We cannot modify or delete this information once it is publicly shared and stored on the blockchain.
However, please note that, in addition to storing this transaction history information on a public blockchain, we also store this information on our own servers. This information remains subject to this Privacy Policy.
Corporate partners. We may share information about you or your transactions conducted through our Services with our corporate partners (e.g., cryptocurrency companies that refer their customers to us and/or offer our Services to their customers). This may include your personal information and transaction history information, as well as aggregated data about our customers’ loan volumes and types of transactions executed.
Legal purposes. We may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:
- To comply with applicable law or a court order, subpoena, or other legal process;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- To establish, protect, or exercise our legal rights or defend against legal claims; or
- To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
Aggregated and de-identified information. From time to time, Rocko may share aggregated or de-identified information about users, such as by publishing a report on trends in the usage of the Services. Such aggregated information will not identify you personally.
Other third parties. We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Your Privacy Rights
If you want to learn more about the personal information that Rocko has about you, or you would like to update, change, or delete that information, please contact us by email at privacy@rocko.co.
You may opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at privacy@rocko.co.
If you are a resident of a jurisdiction with an applicable data privacy law, you may have certain rights available to you in relation to your personal information. These rights may include:
- The right to access your personal information (including a data portability request);
- The right to correct or amend any personal information we have on file about you;
- The right to delete your personal information;
- The right to limit the use of your “sensitive” personal information;
- The right to opt-out of the sale or “sharing” of your personal information;
- The right to opt-out of the use of your personal information for targeted advertising purposes;
- The right to restrict or object to the processing of your personal information (such as for direct marketing purposes);
- The right to restrict or opt-out of the use of your personal information for certain automated decision-making (including profiling in furtherance of decisions that produce legal or similarly significant effects);
- The right to revoke your consent (to the extent applicable);
- The right to confirm whether personal information about you is being processed;
- The right to obtain a list of specific third parties (or categories of third parties) to which we have disclosed your personal information or any personal information.
We will respond to your request as soon as reasonably possible and within the timeframe required under applicable law. We will allow you to appeal any decision we make in response to such request in accordance with applicable law. Appeals may be submitted to privacy@rocko.co with the subject line “Appeal of Decision Related to Privacy Rights Request.”
Prior to complying with your request, we will first verify your identity by comparing the information you provide with the information we have on file for you.
You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.
External Links
The Services may contain links to third-party websites. If you use these links, you may leave the Services. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their contents, or their privacy policies. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our Services, you do so at your own risk.
Data Security
We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no website is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk.
Data Retention
We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed. This section does not apply to transaction information that is stored on a public blockchain.
International Users
The information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. Rocko may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any personal or other information to us, you expressly consent to such transfer and processing.
Children
Content on our Services is directed at individuals of ages 18 and older and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.
Changes to this Policy
We may make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Site, so you should review this page periodically. If we make a material change to the Policy, you will be provided with appropriate notice.
How to Contact Us
Should you have any questions or concerns about this Policy, you can contact us at privacy@rocko.co.