Effective date: 21 May 2018
choices you have with respect to the information.
- organising it into the sections listed in the Table of Contents below,
- providing a series of examples that help illustrate how the policies may be implemented by Rotaready and
- defining and capitalising a few terms that are used more than once for simplicity and brevity.
When we refer to "Rotaready", we mean the Rotaready entity that acts as the processor of your
information, as explained in more detail in the "Identifying the Data Controller and Processor"
Table of Contents
the associated Rotaready mobile and tablet applications (collectively, the "Services"),
Rotaready.com and other Rotaready websites (collectively, the "Websites") and other interactions
(e.g., customer service inquiries, user conferences, etc.) you may have with Rotaready. If you do
not agree with the terms, do not access or use the Services, Websites or any other aspect of
the Services through the Rotaready platform ("Third Party Services"), or any other third party
products, services or businesses. In addition, a separate agreement governs delivery, access and use
of the Services (the "Subscription Agreement"), including the processing of any personal data
submitted through Services accounts (collectively, "Customer Data"). The organisation (e.g., your
employer or another entity or person) that entered into the Subscription Agreement ("Customer")
controls their instance of the Services (their "Realm") and any associated Customer Data. If you
have any questions about specific Realm settings and privacy practices, please contact the Customer
whose Realm you use.
Information We Collect And Receive
Rotaready may collect and receive Customer Data and other information and data ("Other
Information") in a variety of ways:
- Customer Data. Customers or individuals granted access to a Realm by a Customer ("Authorised
Users") routinely submit Customer Data to Rotaready when using the Services.
- Other Information. Rotaready also collects, generates and/or receives Other Information:
- Realm and Account Information. To create or update a Realm account, you or your Customer
(e.g., your employer) supply Rotaready with an email address, phone number, password,
domain and/or similar account details. In addition, Customers that purchase a paid
version of the Services provide Rotaready (or its payment processors) with billing
details such as credit card information, banking information and/or a billing address.
- Usage Information.
- Services Metadata. When an Authorised User interacts with the Services, metadata
is generated that provides additional context about the way Authorised Users
work. For example, Rotaready logs the people, features, content and links you
interact with and what Third Party Services are used (if any).
- Log data. As with most websites and technology services delivered over the
Internet, our servers automatically collect information when you access or use
our Websites or Services and record it in log files. This log data may include
the Internet Protocol (IP) address, the address of the web page visited before
using the Website or Services, browser type and settings, the date and time the
Services were used, information about browser configuration and plugins,
language preferences and cookie data.
- Device information. Rotaready collects information about devices accessing the
Services, including type of device, what operating system is used, device
settings, application IDs, unique device identifiers and crash data. Whether we
collect some or all of this Other Information often depends on the type of
device used and its settings.
- Location information. We receive information from you, your Customer and other
third-parties that helps us approximate your location. We may, for example, use
a business address submitted by your employer, or an IP address received from
your browser or device to determine approximate location. Rotaready may also
collect location information from devices in accordance with the consent process
provided by your device.
Services that help us collect Other Information. The Websites and Services may also
include cookies and similar tracking technologies of third parties, which may collect
Other Information about you via the Websites and Services and across other websites and
- Third Party Services. Customer can choose to permit or restrict Third Party Services for
their Realm. Typically, Third Party Services are software that integrate with our
Services, and Customer can permit its Authorised Users to enable and disable these
integrations for their Realm. Once enabled, the provider of a Third Party Service may
share certain information with Rotaready. For example, if an HR application is enabled
to permit absence records to be imported to a Realm, we may receive names and time off
data of Authorised Users, along with additional information that the application has
elected to make available to Rotaready to facilitate the integration. Authorised Users
should check the privacy settings and notices in these Third Party Services to
understand what data may be disclosed to Rotaready. When a Third Party Service is
enabled, Rotaready is authorised to connect and access Other Information made available
to Rotaready in accordance with our agreement with the Third Party Provider. We do not,
however, receive or store passwords for any of these Third Party Services when
connecting them to the Services.
- Contact Information. In accordance with the consent process provided by your device, any
contact information that an Authorised User chooses to import (such as an address book
from a device) is collected when using the Services.
- Third Party Data. Rotaready may receive data about organisations, industries, Website
visitors, marketing campaigns and other matters related to our business from parent
corporation(s), affiliates and subsidiaries, our partners or others that we use to make
our own information better or more useful. This data may be combined with Other
Information we collect and might include aggregate level data, such as which IP
addresses correspond to postal codes or countries. Or it might be more specific: for
example, how well an online marketing or email campaign performed.
- Additional Information Provided to Rotaready. We receive Other Information when
submitted to our Websites or if you participate in a focus group, contest, activity or
event, apply for a job, request support, interact with our social media accounts or
otherwise communicate with Rotaready.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or
Other Information (collectively, "Information"). However, certain Information is collected
automatically and, if some Information, such as Realm setup details, is not provided, we may be
unable to provide the Services.
How We Use Information
Customer Data will be used by Rotaready in accordance with Customer's instructions, including any
applicable terms in the Subscription Agreement and Customer's use of Services functionality, and as
required by applicable law. Rotaready is a processor of Customer Data and Customer is the
controller. Customer may, for example, use the Services to grant and remove access to a Realm,
assign roles and configure settings, access, modify, export, share and remove Customer Data and
otherwise apply its policies to the Services.
Rotaready uses Other Information in furtherance of our legitimate interests in operating our
Services, Websites and business. More specifically, Rotaready uses Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This
includes use of Other Information to support delivery of the Services under a Subscription
Agreement, prevent or address service errors, security or technical issues, analyse and monitor
usage, trends and other activities or at an Authorised User's request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you
contact us, we may use your Other Information to respond.
- To develop and provide search, learning and productivity tools and additional features.
Rotaready tries to make the Services as useful as possible for specific Realms and Authorised
Users. For example, we may improve search functionality by using Other Information to help
determine and rank the relevance of content, channels or expertise to an Authorised User, make
Services suggestions based on historical use and predictive models, identify organisational
trends and insights, to customise a Services experience or create new productivity features and
- To send emails and other communications. We may send you service, technical and other
administrative emails, messages and other types of communications. We may also contact you to
inform you about changes in our Services, our Services offerings, and important Services-related
notices, such as security and fraud notices. These communications are considered part of the
Services and you may not opt out of them. In addition, we sometimes send emails about new
product features, promotional communications or other news about Rotaready. These are marketing
messages so you can control whether you receive them.
- For billing, account management and other administrative matters. Rotaready may need to
contact you for invoicing, account management and similar reasons and we use account data to
administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
If Information is aggregated or de-identified so it is no longer reasonably associated with an
identified or identifiable natural person, Rotaready may use it for any business purpose. To the
extent Information is associated with an identified or identifiable natural person and is protected
Rotaready will retain Customer Data in accordance with a Customer's instructions, including any
applicable terms in the Subscription Agreement and Customer's use of Services functionality, and as
required by applicable law. Depending on the Services plan, Customer may be able to customise its
retention settings and apply those customised settings at the Realm level. The deletion of Customer
Data and other use of the Services by Customer may result in the deletion and/or de-identification
of certain associated Other Information. Rotaready may retain Other Information pertaining to you
your Other Information after you have deactivated your account for the period of time needed for
Rotaready to pursue legitimate business interests, conduct audits, comply with (and demonstrate
compliance with) legal obligations, resolve disputes and enforce our agreements.
How We Share And Disclose Information
This section describes how Rotaready may share and disclose Information. Customers determine their
own policies and practices for the sharing and disclosure of Information, and Rotaready does not
control how they or any other third parties choose to share or disclose Information.
- Customer's Instructions. Rotaready will solely share and disclose Customer Data in
accordance with a Customer's instructions, including any applicable terms in the Subscription
Agreement and Customer's use of Services functionality, and in compliance with applicable law
and legal process.
- Displaying the Services. When an Authorised User submits Other Information, it may be
displayed to other Authorised Users in the same Realm. For example, an Authorised User's email
address may be displayed with their Realm profile.
- Customer Access. Owners, administrators, Authorised Users and other Customer
representatives and personnel may be able to access, modify or restrict access to Other
Information. This may include, for example, your employer using Service features to export logs
of Realm activity, or accessing or modifying your profile details.
- Third Party Service Providers and Partners. We may engage third party companies or
individuals as service providers or business partners to process Other Information and support
our business. These third parties may, for example, provide virtual computing and storage
services. Additional information about the sub-processors we use to support delivery of our
Services is set forth in at Subprocessors.
- Third Party Services. Customer may enable or permit Authorised Users to enable Third
Party Services. When enabled, Rotaready may share Other Information with Third Party Services.
Third Party Services are not owned or controlled by Rotaready and third parties that have been
granted access to Other Information may have their own policies and practices for its collection
and use. Please check the privacy settings and notices in these Third Party Services or contact
the provider for any questions.
- Corporate Affiliates. Rotaready may share Other Information with its corporate
affiliates, parents and/or subsidiaries.
- During a Change to Rotaready's Business. If Rotaready engages in a merger, acquisition,
bankruptcy, dissolution, reorganisation, sale of some or all of Rotaready's assets or stock,
financing, public offering of securities, acquisition of all or a portion of our business, a
similar transaction or proceeding, or steps in contemplation of such activities (e.g. due
diligence), some or all Other Information may be shared or transferred, subject to standard
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified
Other Information for any purpose. For example, we may share aggregated or de-identified Other
Information with prospects or partners for business or research purposes, such as telling a
prospective Rotaready customer the average amount of time spent within a typical Realm.
- To Comply with Laws. If we receive a request for information, we may disclose Other
Information if we reasonably believe disclosure is in accordance with or required by any
applicable law, regulation or legal process.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights,
property or safety of Rotaready or third parties, including enforcing contracts or policies, or
in connection with investigating and preventing fraud or security issues.
- With Consent. Rotaready may share Other Information with third parties when we have
consent to do so.
Rotaready takes security of data very seriously. Rotaready works hard to protect Personal Data and
Other Information you provide from loss, misuse, and unauthorised access or disclosure. These steps
take into account the sensitivity of the Personal Data and Other Information we collect, process and
store, and the current state of technology. We employ industry-grade encryption during transmission
and while data is at rest. Given the nature of communications and information processing technology,
Rotaready cannot guarantee that Information, during transmission through the Internet or while
stored on our systems or otherwise in our care, will be absolutely safe from intrusion by
To the extent prohibited by applicable law, Rotaready does not allow use of our Services and Websites
by anyone younger than 13 years old. If you learn that anyone younger than this age has unlawfully
provided us with Personal Data, please contact us and we will takes steps to delete such
evolve, which may make those changes necessary, or we may make changes to our business. We will post
changes that materially alter your privacy rights, Rotaready will provide additional notice, such as
should deactivate your Services account. Contact us and the Customer if you wish to request the
removal of Personal Data under their control.
Data Protection Officer
To communicate with our Data Protection Officer, please email email@example.com.
Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the "controller" and "processor"
of information. In general, Customer is the controller of Customer Data. In general, Rotaready is
the processor of Customer Data and the controller of Other Information.
Individuals located in certain countries, including the European Economic Area, have certain
statutory rights in relation to their Personal Data. Subject to any exemptions provided by law, you
may have the right to request access to Information, as well as to seek to update, delete or correct
this Information. You can sometimes do this using the settings and tools provided in your Services
account. If you cannot use the settings and tools, contact Customer for additional access and
To the extent that Rotaready's processing of your Personal Data is subject to the General Data
Protection Regulation, Rotaready relies on its legitimate interests, described above, to process
your data. Rotaready may also process Other Information that constitutes your Personal Data for
direct marketing purposes and you have a right to object to Rotaready's use of your Personal Data
for this purpose at any time.
Data Protection Authority
Subject to applicable law, you also have the right to (i) restrict Rotaready's use of Other
Information that constitutes your Personal Data and (ii) lodge a complaint with your local data
protection authority or the Information Commissioner's Office (ICO), which is Rotaready's lead
supervisory authority in the European Union. If you are a resident of the European Economic Area and
believe we maintain your Personal Data within the scope of the General Data Protection Regulation
(GDPR), you may direct questions or complaints to our lead supervisory authority:
Information Commissioner's Office
Tel: +44 (0) 1625 545745
Rotaready's ICO Registration Number: ZA297859
Rotaready's practices, or if you are seeking to exercise any of your statutory rights. You may
contact us at firstname.lastname@example.org or at our mailing address below:
56 Leman Street