This Privacy Policy was last updated on 29 MAY 2024.
Rosslare Enterprises Limited and its affiliates, subsidiaries, and/or related companies (Hereinafter: “We” “Us”, “Our” and/or “Rosslare Group”) are committed to reasonably secure and protect your personal information which We might collect, store, use and/or share (“Process”) in accordance with this Privacy Policy (Hereinafter: the “Policy” or “Privacy Policy”) , and in compliance with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”).
This Policy describes what, how and why personal information Rosslare Group might collect and/ or Process and/ or share about visitors and/or users of Rosslare Group’s websites, and/or about users of Rosslare Group’s products, applications, and other available services, (Hereinafter: “You”, “Your”, and/or “User”). This Policy also describes the rights You have with respect to Your personal information.
This Policy may not address all possible data collection and Processing scenarios. We may inform You of a product or a service-specific data collection through supplementary policies or notices provided before collection.
BY USING THE WEBSITE, YOU ACKNOWLEDGE AND AGREE TO BE BOUND BY THE POLICY.
Personal information We collect.
We collect personal information that You disclose to Us, depending on the context of Your interactions with Us.
You directly provide Rosslare Group with personal information when You visit or use Rosslare Group’s websites or any of its functions or service thereof, or use Rosslare Group’s products, software, applications, or services, or interact with Rosslare Group, or communicate with Rosslare Group (Hereinafter: “Service(s)”).
Any personal information provided to Rosslare Group shall be understood to have been provided to Rosslare Group with Your full consent. Refusal to provide information or the provision of incomplete or incorrect information may deny Your access to certain services and / or functions of the website or may render Rosslare Group unable to handle any enquiry You are making or may otherwise deter the objectives of Your visit to the website.
The personal information may include:
-Contact details such as: name, job title, company information, contact address, phone number(s), email address, language preference, or any other personal information.
-Information related to, or arise from any of the following, without limitation: Your ISP (Internet Service Provider); internet domain/protocol (IP) addresses; web browser type and version; referring links/pages; exit links/pages; pages and files viewed on Our websites; operating system; and date/time records of Your access to Our websites/applications; click path and/or clickstream data, and device identifiers, or any other technical information.
-Information You provide to Us such as the content of messages, query information, and any other questions or information You provide to Rosslare Group (for example in connection with customer service or support), or other content You choose to upload to the Services.
-Rosslare Group may also collect general demographic and profile data, from time to time, and publicly available information related to You and/or to the group, or organization, or entity, which You work for, or belong to as may be applicable.
-Rosslare Group may also obtain data from third parties, such as Rosslare Group’s partners and service providers, which may offer services or engage in joint marketing activities.
-We may collect information which is not specifically listed here but which We will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
-Other information collected by Cookies or automated means. We, Our service providers, and Our business partners may automatically log information about You, Your computer or mobile device, and activity occurring on or through the Services. The information that may be collected automatically includes Your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple IDFA for advertising), browser type, screen resolution, IP address, the website You visited before navigating to Our website, general location information such as city, state or geographic area; and information about Your use of and actions on the Service, such as pages or screens You viewed, how long You spent on a page or screen, navigation paths between pages or screens, information about Your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
On Our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies. Our emails may also contain web beacons. In Our mobile application, We may collect this information directly or through Our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from Our mobile application.
Some of the data Rosslare Group collects and/or Processes is non-personally identifiable information (Non-PII). Non-PII is information that cannot be used to identify a particular individual. For example, statistical data, such as the numbers of visits to Our website. We collect this data to understand how users use Our websites, products, software, applications or services, for website administration, and for improving Our communication and/or services. Rosslare Group may collect, use, Process, transfer, share or disclose Non-PII for other
purposes at its own discretion.
We will endeavour to isolate Your personal information from Non-PII and ensure that the two types of data are used separately. If personal information is combined with Non-PII, it will still be treated as personal information during Processing, and handled according to this Privacy Policy.
How We use Your Personal information.
We use Your personal information when We believe it is necessary and We have a valid legal basis to do so under applicable law.
As such, We may use Your personal information for the following purposes:
To provide the services or related data that You request, operate, and improve Our business.
To communicate with You about a Service, or events or programs, to understand Your needs and interests and to respond Your requests.
To verify Your identity.
We may use Your personal information such as demographics to analyse Your use of service in order to improve the service, or to develop new products or services ant to market and promote Our business.
We may use Your personal information and disclose it to governmental authorities, law enforcement, and private parties as We deem essential or appropriate to: (a) protect Our, Your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
In some cases, Rosslare Group will seek for Your consent to the collection , use or sharing of Your personal information, such as in order to contact You, to provide You with information about products and/or services, to assist You in evaluating and/or purchasing Our products and/or services; to send You marketing materials and/or information about upcoming webinars and events, product announcements, newsletters, promotions, technical notices; to send You questionnaires, surveys, requests for feedback; to send You any other business, marketing and/or informational materials; to share with third parties; to share with Rosslare Group service providers; and to share with Rosslare Group partners.
You may indicate Your consent to the above by the following ways: 1) when providing Us with Your personal data through Our website or a form, ticking boxes indicating Your consent;2) when providing Us with Your personal data through the telephone or email.
When We will send marketing related materials it will be as permitted by law, and you would have the ability to opt-out of Our marketing and promotional communications.
We may make some of the personal information anonymous, aggregated, or de-identified. We may use this anonymous, aggregated, or de-identified data and share it with third parties for Our lawful business purposes, as to analyze and improve Our products and/ or Services.
How We share Your Personal information
Your personal information is not for sale, but We may share Your personal data with third parties, service providers, or partners. Sharing data is either with Your Consent or as instructed by You, or as required to complete any obligation, contract, transaction and/or for any other purpose described in this Policy. In every such case Rosslare Group will take reasonable steps to ensure that Your personal information is shared in accordance with this Privacy Policy and subject to applicable laws of data protection.
We may share Your personal information with Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
We may share Your personal information with third party entities and/ or individuals that provide services on Our behalf or assist Us operate Our business (such as customer support, hosting, analytics, email delivery, marketing, database management, as well as preparation and submission services.)
We may share or transfer Your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Our business to another company. Your personal information and any other information collected or received may be transferred to, and maintained on, computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those in Your jurisdiction.
As mentioned, third party companies and individuals may be retained by Us to provide certain services or products (“Service Providers “), to assist Us in analysing how a Rosslare Group website, product, software, or application is used. These third parties may have access to Your personal information only to perform agreed tasks on Our behalf and are obligated not to disclose or use Your personal information for any other purpose.
Service Providers and other third parties may use cookies and similar technologies to track Your browsing activity. for more details, see below paragraph about Cookies. You have the right to block or enable certain cookies and other similar tracking technologies using the third-party provided cookie management platform that may display the first time You visit each site and is available in the footer of Our sites.
Our categories of service providers may include:
Disclosure Required by Law. Rosslare Group will cooperate with legal or governmental authorities to identify Users who use Rosslare Group’s website, products, software, applications, or services for unlawful activities or to prevent or investigate possible wrongdoing in connection with Rosslare Group’s products or services.
Rosslare Group will respond to subpoenas, warrants, or other court orders regarding information concerning any user. Rosslare Group will disclose any of Your personal information or other information if Rosslare Group reasonably believes that Rosslare Group is required to do so by law. Rosslare Group will in addition disclose any of Your personal information or other information if such disclosure is necessary to protect or defend or save from harm the rights and/or property and/or wellbeing of any third party or individual, the rights and/or property and/or interests of Rosslare Group, or to protect Rosslare Group from legal liability; or to protect the integrity, without limitation, of Rosslare Group’s websites, applications, products, services or reputation. Such disclosure of Your personal information and/or information shall be at Rosslare Group’s sole and exclusive judgement and/or discretion. We may disclose Your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to Us.
Your Rights
All personal information that You provide to Us must be true, complete, and accurate, and You must notify Us of any changes to such personal information. Rosslare Group would like to make sure You are fully aware of all Your data protection rights. In this paragraph, We describe the rights available to all users.
Users who are California Residents please review Our CCPA PRIVACY NOTICE. https://rosslare.com/ccpa/
Users who are in the European Economic Area can find additional information about their rights further below.
If allowed by applicable laws, You have the right to withdraw Your consent at any time when Rosslare Group Processes Your personal information based on Your Consent. Such withdrawal, however, shall not affect or limit the validity of any prior Consent, and shall not apply to any of Your personal information collected or Processed prior to such withdrawal personal information; and shall not affect or limit the validity of any prior consent provided to Rosslare Group in any other way, method, or means.
The right to Opt-out of marketing communications.
As mentioned above, Rosslare Group may collect and/or Process information that You provide for the purpose of subscribing to Rosslare Group’s sales and marketing communications and emails. You have the right to opt-
out of receiving sales and marketing communications and stop Our marketing messages. Even if You opt-out of receiving marketing communications from Us, You may continue receiving service-related and other non-marketing communications.
To exercise Your rights, please send a message to [email protected], with Your current contact details.
If You desire only to update Your contact details, please send a message to [email protected] with Your current email and Your previous contact details.
Security
Rosslare Group is taking appropriate technical and organizational measures to reasonably ensure an adequate level of security to safeguard the personal information stored by Rosslare Group. Rosslare Group takes reasonable steps to protect Your personal data from loss, misuse and unauthorized access, disclosure, alteration and/or destruction. We employ several organizational, technical and physical safeguards designed to protect the personal information We collect.
In addition, Rosslare Group and its business partners enter into confidentiality agreements that require the parties to act subject to applicable data protection laws.
Security risk is inherent in all internet and information technologies. Due to those risks associated with information technology, We cannot guarantee absolute security of Your personal information. Despite Our safeguards and efforts to secure Your information, no electronic transmission over the Internet or information storage technology can be completely foolproof. Therefore, We cannot guarantee that hackers, cybercriminals, or other unauthorized third parties won’t be able to breach Our security measures and unlawfully access, collect, steal, or modify Your information. Even though We are committed to protecting Your personal information to the best of Our ability, the transmission of such data to and from Our Services inherently carries some level of risk. Therefore, it’s advisable that You access Our Services only within a secure environment and take appropriate precautions to safeguard Your information.
Duration of Storage
Rosslare Group will keep and use Your personal information on Rosslare Group’s information systems until such time as You communicate a request to Rosslare Group to delete or modify Your personal information, or for as long as needed in order to provide You with the most relevant offers, updates, or information and to comply with Our legal obligations, resolve disputes, and enforce Our agreements, and to enroll Our ongoing business effectively.
The data storage period may vary with the website, product, software, or application in question. The standards Rosslare Group uses to determine the retention period are as follows:
When We no longer require the personal information, We have collected about You, We will either delete or anonymize it or, if this is not possible (for example, because Your personal information has been stored in backup archives), then We will securely store Your personal information and isolate it from any further Processing until deletion is possible. If We anonymize Your personal information (so that it can no longer be associated with You), We may use this information indefinitely without further notice to You.
Children’s Privacy
This Website and Our Services do not address anyone under the age of 18 (“Children “).
We do not knowingly collect personal information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your Children has provided Us with personal data, please contact Us. If We become aware that We have collected Personal Data from children without verification of parental consent, We take steps to remove that information from Our servers.
Links to Third Parties’ services, sites, or applications
Our websites and Services may include links to other websites and applications, and other online services operated by third parties. Rosslare Group is not liable to secure Your personal information if You provide personal information to any of those third parties. Rosslare Group cannot control the privacy practices and data protection policies of third parties that are not subject to this Policy. When You submit personal information to such a third party, the operators of those third parties may collect information from You which will be used by them in accordance with their own privacy policy that may differ from this Privacy Policy. We encourage You to read and refer to the privacy protection policies of third parties You use.
Cookies and Similar Technologies
Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to Your browser from Our website and stored on Your device. For more information in relation to Our Cookies policy, please click here. https://rosslare.com/cookies-policy/.
Policy Changes
Rosslare Group reserves the right to change, modify and/or update this Privacy Policy at any time.
You are required to review the Privacy Policy and check for updates to the Privacy Policy, prior to each use of a Rosslare Group website, application, product, or service. In the event of a material change, Rosslare Group may present a notice on Our website and Rosslare Group may notify You through contact information. In all cases, Your continued use of the Service after the posting or effective date as stated in the notification of any modified Privacy Policy indicates Your acceptance of the terms of the modified Privacy Policy.
Contact Details
You may communicate with Us or unsubscribe from Our communications at any time.
You may address requests, questions, complaints, or suggestions in respect to this Privacy Policy via email address:
[email protected]
Additional Information for European residents
Personal information. References to “Personal Data” in this Privacy Policy are defined as “personal data” governed by European data protection legislation.
Legal bases for Processing. We use Your Personal Data only as permitted by law. If You are in the EU or UK, the followed specific regulation applies to You: The General Data Protection Regulation (GDPR) and UK GDPR require Us to explain the Legitimate Interests We rely on in order to Process Your personal information. As such, We may rely on the following legal bases to Process Your personal information:
(i)Your consent, (ii) for compliance with legal obligations, (iii) to protect vital interests.
Rosslare Group Processes personal data, in accordance with applicable laws, for Legitimate Interests in operating Our business, as stated in GDPR art. 6 (1) f, which also includes the following:
Note: If You provide Us with any personal information when You use the Service, You must consent to Our Processing and use of such Personal Data in accordance with this Privacy Policy. If You do not consent to Our Processing and use of such Personal Data, You must not submit such Personal Data through Our Service.
Regarding the GDPR, Rosslare Group may be a controller of Your personal information. A Controller means the body that determines the purposes and means of the Processing of personal information.
If You believe Rosslare Group is the data controller of Your personal information, You are entitled to request:
For Submitting Your inquiry or request in relation to Your rights regarding Your Personal information collected by Rosslare Group, please send an email to: [email protected], including the following
information:
The above personal information You provide is necessary to fulfill Your request, and for Rosslare Group to verify Your identity and personal information Rosslare Group have about You.
We will use Your personal information to respond Your inquiry.