Rosslare Enterprise Limited CCPA Privacy Notice

Rosslare Enterprise Limited (“REL”) CCPA Privacy Notice

This CCPA Privacy Notice was last updated on 02 March 2025.

This CCPA Notice applies solely to Californian residents’ Personal Information, which we collect directly or indirectly while You are using our website or through our Services, or business-to-business Personal Information.

The California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”), any other California privacy laws, and this CCPA Notice apply to visitors, employees, users, applicants for employment, and independent contractors, and others who are California residents as defined in those Acts (Hereinafter: “You”, “Your”, and/or “Consumers”). Any term defined in the CCPA and CPRA has the same meaning as in this CCPA Notice.

This CCPA Notice supplements the information contained in our Privacy Policy. and the definitions used herein shall have the same meaning as defined in our Privacy Policy .

  1. Categories of Personal Information We Collect.

We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device, all as detailed in the table below.

We have collected the following categories of personal information within the last twelve

(12) months from California Consumers, and intend to continue doing so subject to the requirements under the CCPA:

 

Category Description and Examples Collected
A.

Identifiers

 A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes: Online identifier, unique online identifier, IP address, real name, username, email address, as part of “Contact Us Form”, etc.
B.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

 A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport

number, driver’s license or

 Yes: address, telephone number, current employment, etc.
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.

Some personal information included in this category may overlap with other categories. Information collected under this Category may also include Sensitive Personal Information as defined in the CCPA.
C.

Protected classification characteristics under California or federal law.

 Age (40 years or older), race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, 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). No
D.

Commercial information.

 Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No.
E.

Biometric information.

 Genetic, physiological, behavioural, and biological characteristics, or activity No
patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F.

Internet or other similar network activity.

 Browsing history, search history, information on a consumer’s interaction with a website, application, or

advertisement.

 Yes: information on a consumer’s interaction with our website (e.g., through cookies).
G.

Geolocation data.

 Physical location, approximate location derived from IP address or movements. Yes: approximate location as part of our online marketing and analytics activity (through your IP address).
H.

Sensory data.

 Audio, electronic, visual, thermal, olfactory, or similar information. No
I.

Professional or employment-related information.

 Current or past job history or performance evaluations. Yes: Current Job title
J.

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. 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.

 No
K.

Inferences drawn from other personal information.

 Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes. No
L.

Sensitive personal information.

 Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or No
ethnicity, religious or philosophical beliefs, union membership, content of mail, email and text messages, biometric data, health data, and sexual orientation or sex life.

Personal Information does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern, information that is de-identified or aggregated with other consumer information, or information that falls outside the scope of the CCPA.

For more information about the types of information we collect, please see the “What Information We Collect” (Link) section in our Privacy Policy.

  1. Sources of Personal Information.

We collect most information directly or indirectly from You through your use of our website or through our services or products. For example, through forms You use to contact us, requesting support, etc. Or indirectly, we collect your usage data automatically from measurement tools. Additionally, we collect information Via third parties that have obtained your consent to provide such information. Or for example, from partners who assist us in performing services for Consumers, internet service providers, data analytics providers, and data brokers, etc.

  1. Use of Personal Information.

We may use the Personal Information collected as identified above, for Business Purposes and/or Commercial Purposes: To meet the reason You provided the Personal Information (support, address an inquiry, etc.); provide, maintain and improve our services; analyse Your interaction with our applications; to enrol You in our newsletter subscriptions members, and other commercial transactions that may take place from time to time; respond to law enforcement; or otherwise as detailed in our Privacy Policy. https://rosslare.com/privacy-policy/

We will not collect additional categories of Personal Information or use the Personal Information we collected for significantly different, unconnected, or conflicting purposes without updating this notice.

  1. Disclosures of Personal Information.

We may disclose Your Personal Information, including sensitive personal information, to a contractor, a sub-contractor, or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that Personal Information confidential and not use it for any other purpose except performing the contract. We may further restrict the contractor and service provider from selling or sharing Your Personal Information. In addition, we may share personal information with our affiliates and subsidiaries, vendors working on our behalf, or when required by law or in relation to legal process.

In the last twelve (12) months, we disclosed the following categories of Personal Information for a business purpose:

Category (corresponding with the table above) Category of Recipient Business Purpose
 

Category A
Category B
Category F

  

Cloud computing and storage vendors.

  

Storage, hosting.
Government Entities/ Law Enforcement. Subject to a law request, such as tax and social security authorities.
Operating systems. Operating the services
Category A
Category B
Category F
Category G		 Data analysis providers. Providing analytic data on the use of our website. We limit the providers ability to share such information, as detailed above.
Category A
Category B
Category F		 Various service providers. Improving the services, development, and optimization.
Category A
Category B		 Customer support providers. Affiliated companies. Customer and technical support
  1. Sale or Share of Personal Information.

REL is not a data broker and we do not trade with Your information.

In the last twelve (12) months, we did not “sell” information as most people would commonly understand that term, However, for retargeting and analytic purposes, when we promote our Services, we use third-party tools that are able to market our Services online, assess these marketing efforts, identify individuals interested in our Services, etc. This involves placing cookies, pixel or other tracking technologies on our website and sharing online identifiers and online behaviour information with these vendors. The CCPA defines these actions as “sharing” or “selling”.

In the last twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:

CATEGORY (CORRESPONDING WITH THE TABLE ABOVE) CATEGORY RECIPIENT PURPOSE OF SALE OR SHARE
Category A Category B

Category F Category G

 marketing tools and vendors: third party service providers that provide us with services, while they retain certain rights to use Your data for their own business needs (e.g. Google Analytics, Cloudflare, Facebook, Network Box fraud detection services, our online marketing service

providers, etc.).

 Promoting the Services, applications, etc.
  1. Retention Periods.

The retention periods are determined depending on certain considerations:

    1. For as long as it remains necessary to achieve the purpose for which the personal Information was initially collected. For example: if You contacted us, we would keep Your information at least until we will fulfil Your inquiry.
    2. To comply with our regulatory obligations and legal duties.
    3. To resolve a claim, we might have or a dispute, including any legal proceeding between us, until such dispute will be concluded, and furthermore, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that unless required by applicable law, we will not be obligated to keep Your data for any specific period, and we may delete it for any reason and at any time, without providing You a prior notice. Online identifiers are usually kept for a short period. Other information usually will not be retained for more than 24-months unless You have further contact with the Company.

Information related to purchase of our Services and management of user account may be retained for longer periods and even without limitation as such information is part of our internal record keeping as a business as well, sometimes, contain information we obliged to keep (e.g., transactional data as part of our bookkeeping obligations).

When we remove Your Personal Information, we ensure that the information cannot be recovered or restored.

  1. Your California Consumer Rights.

As a California resident, You may exercise certain privacy rights in relation to Your Personal Information. You may be granted with these rights free of charge, unless otherwise permitted under applicable law. We may limit our response to Your exercise of these privacy rights as permitted under applicable law, all as detailed in the Data Subject Request Form (Link) and as follows:

  1. The right to Know. The right to know what Personal Information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer.
  2. The right to correct or delete. The right to correct inaccurate Personal Information that a business maintains about a consumer. The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions.
  3. The right to Opt- Out. You have the right to opt-out of the “sharing” of Your Personal Information for “cross-contextual behavioural advertising,” often referred to as “interest- based advertising” or “targeted advertising”. The right to opt-out of the sale or sharing of Personal Information by the business. In certain circumstances, You have the right to opt-out of the use of automated decision making in relation to Your Personal Information.
  4. The right Limit the Use or Disclosure of SPI. Under certain circumstances, If the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business.
  5. The right not to receive discriminatory treatment. The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing You a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by Your Personal Information.
  6. The right to access. You may request to receive a copy of Your Personal Information we have collected in the last 12 months, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information You provided to us in a portable format. You may make this request up to two times in a 12-month period.
  7. Exercise Your Rights.

You may exercise Your rights by using the Data Subject Request Form available in Data Subject Request Form. The instructions for submission, the process, and verification requirements, when applicable, including any information the inquirer must provide are all detailed in the Data Subject Request Form. OR- You can do so by submitting a respective request to:[email protected]

You may elect to exercise Your rights by an “Authorized Agent”, as detailed herein:

  1. “Authorized agents” may submit opt out requests on a consumer’s behalf. If an authorized agent sends a request on Your behalf, we will require a proof for the authorization, prior to acceptance of any requests by an authorized agent on behalf of a California consumer. thus, You are required to: You should provide the authorized agent a signed power of attorney, or a written signed permission.
  2. You should have a verification of their own identity directly with the business.
  3. You should have a confirmation with the business that they provided the authorized agent permission to submit the request.

We may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

  1. Children Under Age 16

We do not knowingly collect information from children under the age of 16.

  1. Notice of Financial Incentive.

REL do not offer financial incentives to Consumers for providing Personal Information.

  1. Miscellaneous.

Direct Marketing Requests. California Civil Code Section 1798.83 permits You, a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the Data Subject Request Form. (Link)

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If You are a California resident and would like to make such a request, please submit Your request in writing to us using the contact information provided below.

Do Not Track Settings. Cal. Bus. And Prof. Code Section 22575 also requires us to notify You how we deal with the “Do Not Track” settings in Your browser. Currently, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. Do Not Track is a privacy preference You can set in Your web browser to indicate that You do not want certain information about Your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit www.donottrack.us.

  1. Adjustments.

As required under the CCPA, we will update the CCPA Notice every 12 months. The last revision date will be reflected at the top of this CCPA Notice.

  1. Our Contact Details:

Address:

Rosslare Enterprises Limited

Suit 905 Wing Fat Ind. Bldg.

12 Wang Tai Road Kowloon Bay

Kowloon Hong Kong

[email protected]