This Privacy Policy explains how we collect, use, and disclose your information when you use our Service. It also informs you about your privacy rights and legal protections.
We collect and use your personal data to improve and provide the Service. By using the Service, you consent to the collection and use of information as described in this Privacy Policy.
Interpretation
Capitalized terms used in this Privacy Policy have specific meanings as outlined below. These definitions apply whether the terms are used in the singular or plural form.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for you to access our Service or certain features of the Service.
Affiliate refers to an entity that controls, is controlled by, or is under common control with another entity. “Control” means owning 50% or more of the shares, equity interests, or other voting securities.
Application refers to Well AI, the software provided by the Company.
CCPA/CPRA refers to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA) of 2020.
Company (referred to as "the Company," "We," "Us," or "Our") refers to Rocksburg Technologies Limited.
For the purposes of the GDPR, the Company is the Data Controller.
Consumer (under CCPA/CPRA) refers to a natural person who is a California resident. A resident includes individuals who are present in the U.S. for non-temporary purposes or individuals domiciled in the U.S. but temporarily outside the country.
Data Controller (under GDPR) refers to the Company as the entity that determines the purposes and means of processing Personal Data.
Device means any device capable of accessing the Service, such as a smartphone or tablet.
GDPR refers to the General Data Protection Regulation of the EU.
Personal Data refers to any information that relates to an identified or identifiable individual.
For GDPR, Personal Data includes any information related to you, such as your name, ID number, location data, online identifier, or other factors relevant to your physical, genetic, mental, economic, or social identity.
For CCPA/CPRA, Personal Data refers to information that identifies, relates to, describes, or is capable of being associated with you.
Service refers to the Application.
Service Provider refers to a natural or legal person who processes data on behalf of the Company, including third-party contractors or companies assisting in the Service's operations or analyzing how it is used. Under the GDPR, Service Providers are Data Processors.
Usage Data refers to data collected automatically, either generated by the Service or from its infrastructure (for example, duration of page visits).
You refers to the individual using or accessing the Service, or the company or legal entity on whose behalf the individual is accessing the Service.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. This may include, but is not limited to:
Email address
Usage Data
Usage Data
Usage Data is collected automatically when you use the Service. This may include information such as your device's IP address, browser type, browser version, pages visited, time and date of your visit, duration spent on those pages, device identifiers, and other diagnostic data.
If you access the Service through a mobile device, we may collect information such as the type of device, its unique ID, IP address, operating system, mobile browser type, and other diagnostic data.
Additionally, we may collect information sent by your browser when you visit our Service or use it on a mobile device.
Information Collected While Using the Application
When you use our Application, we may collect images and other data captured by your device’s camera or stored in your photo library.
This data is used to enhance and personalize your experience within the Service and may be uploaded to our servers or stored locally on your device.
You can enable or disable this feature at any time via your device settings.
The Company may use your personal data for the following purposes:
To provide and maintain our Service, including monitoring its usage.
To perform a contract: Develop, comply with, and fulfill any contracts with you through the Service.
To contact you: We may contact you via email or other electronic communication methods such as push notifications, regarding updates, new features, products, or services related to the Service, including security updates as necessary.
To manage your requests: Handle and respond to your inquiries.
For business transfers: Evaluate or engage in business transactions such as mergers, acquisitions, or sales involving all or part of our assets, including Personal Data.
For other purposes: Analyze data, identify usage trends, and improve our Service, products, and user experience.
We may share your personal information in the following cases:
For business transfers: Sharing or transferring your personal information during the course of any mergers, asset sales, financing, or acquisitions.
With affiliates: Sharing your data with our affiliates, subject to the same privacy policy. Affiliates include our parent company, subsidiaries, and joint venture partners.
With business partners: Sharing your data with our partners to offer specific products or services.
With other users: If you share personal data or interact with other users in public areas, this information may be publicly available.
With your consent: Sharing your personal information for any purpose where you have granted consent.
We will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. We may also retain your data as needed to comply with legal obligations, resolve disputes, and enforce our legal agreements.
Additionally, Usage Data may be kept for internal analysis purposes. This data is typically retained for a shorter period unless it is used for security purposes, to enhance the Service, or required to be kept longer by law.
Your data, including Personal Data, is processed at the Company’s operating offices and other locations where our data processors are located. This means that your information may be transferred to and stored on servers outside of your country or jurisdiction. These regions may have different data protection laws.
By agreeing to this Privacy Policy and submitting your information, you consent to this transfer.
We will take all reasonable steps to ensure that your data is securely handled in accordance with this Privacy Policy. No transfer of your personal data will take place unless we ensure that adequate protections are in place to secure your information.
You have the right to request the deletion of your personal data. We will assist you in deleting this information.
Our Service may also allow you to delete certain data directly within the Service.
You may update, amend, or delete your information at any time by accessing your account settings. Alternatively, you can contact us to request access, correction, or deletion of your personal information.
Please note that we may retain certain information where required by law or for other legitimate purposes.
Law Enforcement
In certain situations, the Company may be obligated to disclose your Personal Data, either as required by law or in response to legitimate requests from public authorities (such as courts or government agencies).
Other Legal Requirements
The Company may also disclose your Personal Data if we believe in good faith that such disclosure is necessary to:
Comply with a legal obligation.
Safeguard and protect the rights or property of the Company.
Prevent or investigate potential misconduct related to the Service.
Ensure the personal safety of Service Users or the public.
Protect against legal liability.
We take the security of your Personal Data seriously. However, please keep in mind that no method of transmission over the Internet or electronic storage is entirely secure. While we strive to employ reasonable measures to protect your data, we cannot guarantee its absolute security.
The Service Providers we engage may have access to your Personal Data. These third-party vendors collect, store, use, process, and transfer information about your activity on our Service, in accordance with their respective Privacy Policies.
Analytics
We may use third-party service providers to monitor and analyze the use of our Service:
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the collected data to monitor and analyze the use of our Service. This data may be shared with other Google services.
You can opt out of certain Google Analytics features through your mobile device settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy
For more information on Google's privacy practices, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Firebase
Firebase is an analytics service provided by Google Inc.
You can opt out of certain Firebase features via your mobile device settings or by following the instructionsin their Privacy Policy: https://policies.google.com/privacy
We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245
For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners' sites or apps webpage: https://policies.google.com/technologies/partner-sites
Legal Basis for Processing Personal Data under GDPR
We may process your Personal Data under the following conditions:
Consent: You have provided your consent for processing your Personal Data for one or more specific purposes.
Performance of a contract: Providing your Personal Data is necessary to fulfill an agreement with you and/or for pre-contractual obligations.
Legal obligations: Processing your Personal Data is required to comply with a legal obligation to which the Company is subject.
Vital interests: Processing your Personal Data is necessary to protect your vital interests or those of another individual.
Public interests: Processing your Personal Data is related to a task carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing your Personal Data is necessary for the legitimate interests pursued by the Company.
If you need clarification on the specific legal basis for our processing of your Personal Data, particularly whether the provision of Personal Data is a statutory or contractual requirement or necessary to enter into a contract, we will be happy to provide that information.
Your Rights under the GDPR
The Company is committed to respecting the confidentiality of your Personal Data and ensuring you can exercise your rights.
If you are within the EU, you have the right under this Privacy Policy, and by law, to:
Request access to your Personal Data: The right to access, update, or delete the information we hold about you. You can update or request deletion of your Personal Data directly from your account settings, if possible. If you cannot perform these actions, please contact us, and we will assist you. This also allows you to receive a copy of your Personal Data.
Request correction of your Personal Data: You have the right to correct any inaccurate or incomplete information we hold about you.
Object to the processing of your Personal Data: You can object to the processing of your Personal Data if we are relying on a legitimate interest as the legal basis for processing, and you have a particular situation that justifies your objection.
Request the erasure of your Personal Data: You have the right to request the deletion or removal of your Personal Data when there is no valid reason for us to continue processing it.
Request the transfer of your Personal Data: We will provide your Personal Data, or transfer it to a third party of your choice, in a structured, commonly used, and machine-readable format. Note that this right only applies to automated information that you initially consented to us using, or where we used the information to perform a contract with you.
Withdraw your consent: You have the right to withdraw your consent to the use of your Personal Data. Please note that if you withdraw consent, we may not be able to provide certain functionalities of the Service.
Exercising Your GDPR Data Protection Rights
To exercise your rights regarding access, correction, deletion, and objection, please contact us. We may ask you to verify your identity before responding to your requests. We will make every effort to respond to your request as soon as possible.
You also have the right to file a complaint with a Data Protection Authority regarding our collection and use of your Personal Data. If you are in the European Economic Area (EEA), please contact your local data protection authority.
This section of the privacy notice is specifically for residents of California and serves as an addition to the information provided in our Privacy Policy. It applies exclusively to all visitors, users, and others who reside in the State of California.
We collect information that identifies, relates to, describes, references, or can be reasonably linked, directly or indirectly, to a specific Consumer or Device. Below are the categories of personal information that we may collect from California residents over the past twelve (12) months.
Please note that the categories and examples listed below are in line with the definitions set forth in the CCPA/CPRA. This does not mean that all examples of each category were collected, but reflects our best understanding that some information from each category may have been collected. For example, certain categories of information may only be collected if you voluntarily provide them.
Category A: Identifiers
Examples: Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, driver’s license number, passport number, or similar identifiers.
Collected: Yes.
Category B: Personal Information under the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Examples: Name, signature, Social Security number, physical description, address, phone number, passport number, driver’s license or state ID, insurance policy number, education, employment history, bank account, credit card or debit card number, and other financial, medical, or health insurance information.
Collected: Yes.
Category C: Protected Classification Characteristics under California or Federal Law
Examples: Age (40 years or older), race, ethnicity, ancestry, national origin, citizenship, religion, marital status, medical conditions, disability, sex, gender identity or expression, sexual orientation, military status, genetic information.
Collected: No.
Category D: Biometric Information
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns for identification purposes (e.g., fingerprints, faceprints, voiceprints, retina scans, gait patterns, sleep or exercise data).
Collected: No.
Category E: Internet or Other Network Activity
Examples: Interaction with our Service or ads.
Collected: Yes.
Category F: Geolocation Data
Examples: Approximate physical location.
Collected: No.
Category G: Sensory Data
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
Category H: Professional or Employment Information
Examples: Job history or performance evaluations.
Collected: No.
Category I: Non-Public Education Information (per FERPA)
Examples: Student records such as grades, transcripts, schedules, student IDs, and disciplinary records.
Collected: No.
Category J: Inferences Drawn from Personal Information
Examples: A profile reflecting preferences, psychological trends, behavior, and other characteristics.
Collected: No.
Category K: Sensitive Personal Information
Examples: Login credentials, geolocation data.
Collected: Yes.
Under the CCPA/CPRA, "personal information" does not include:
Publicly available information from government records
De-identified or aggregated consumer information
Data excluded from the CCPA/CPRA's scope, including medical data governed by HIPAA, clinical trial data, or financial data regulated by sector-specific laws such as FCRA, GLBA, and FIPA.
We gather personal information from the following sources:
Directly from You: For example, when you fill out forms on our Service or provide preferences through the Service.
Indirectly from You: For example, by observing your interactions with the Service.
Automatically from You: For example, through cookies set on your device while you use our Service.
We may use or disclose the personal information we collect for business purposes as defined under the CCPA/CPRA. Examples include:
Operating our Service and providing it to you.
Offering support and responding to your inquiries, including investigating concerns and improving our Service.
Complying with law enforcement requests and legal obligations.
Internal administrative tasks such as auditing and data analysis.
Detecting security incidents and protecting against fraud or other malicious activities.
One-time uses as necessary.
These examples are not exhaustive. For more details on how we use your data, refer to the "Use of Your Personal Data" section. If we decide to collect new categories of information or use the information for unrelated purposes, we will update this Privacy Policy accordingly.
The CCPA/CPRA grants California residents specific rights concerning their personal information. If you are a California resident, you are entitled to the following rights:
Right to Notice: You have the right to be informed about the categories of personal data being collected and the purposes for which this data is being used.
Right to Know/Access: Under the CCPA/CPRA, you have the right to request that we disclose information regarding our collection and use of your personal data. Upon receiving and confirming your request, we will provide the following:
The categories of personal data we have collected about you
The sources of personal data we have collected about you
The business purposes for collecting or selling your personal data
The categories of third parties with whom we share your personal data
The specific pieces of personal data we have collected about you
Right to Correct Personal Data: You have the right to correct or rectify any inaccurate personal information we hold about you. Upon receiving and confirming your request, we will make reasonable efforts to correct (and direct our service providers to correct) your personal data, unless an exception applies.
Right to Limit the Use and Disclosure of Sensitive Personal Data: You have the right to request that we limit the use or disclosure of certain sensitive personal data we have collected about you, except where an exception applies. For submission, please refer to the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact us.
Right to Delete Personal Data: You have the right to request the deletion of your personal data under specific circumstances, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal data, provide goods or services you requested, take actions reasonably anticipated within the context of our ongoing business relationship, 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 identify and repair errors impairing intended functionality.
Exercise free speech, protect another consumer’s right to free speech, or exercise another right provided by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in scientific, historical, or statistical research in the public interest that adheres to applicable ethics and privacy laws, when deleting the information would likely impair the achievement of the research.
Enable internal uses reasonably aligned with consumer expectations based on your relationship with us.
Comply with legal obligations.
Make other lawful uses of the information consistent with the context in which it was provided.
Right Not to Be Discriminated Against: You have the right not to face discrimination for exercising any of your consumer rights, including:
Denying goods or services to you
Charging different prices or rates, including using discounts, benefits, or penalties
Providing a different level or quality of goods or services
Suggesting that you will receive a different price, rate, or level of service
If you are a California resident, you have the right to limit the use and disclosure of your sensitive personal information to only those uses necessary to perform services or provide goods that are reasonably expected by an average consumer. We collect, use, and disclose sensitive personal information only as required to provide our services. For further information on how we use your personal information, please refer to the "Use of Your Personal Data" section or contact us.
Our service may contain links to external websites not operated by us. If you click on a third-party link, you will be redirected to that party’s site. We strongly encourage you to review the privacy policy of each site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
We may periodically update our privacy policy. When this happens, we will notify you by posting the updated policy on this page. We will also notify you via email and/or a prominent notice on our service before the changes take effect and will update the "Last Updated" date at the top of this policy. We encourage you to review this privacy policy periodically for any changes. Updates to the policy are effective once they are posted on this page.
If you have any questions about this privacy policy, you can contact us:
By email: feedback@rocksburglimited.com
By visiting this page on our website: https://www.rocksburglimited.com