We Are Rosie, LLC (the “Company” or “we”) maintains a network of consultants and/or employees (the “Rosies”) who provide marketing and related services (the “Services”) to the Company’s customers (each a “Customer”).
This Policy is also a notice to California residents, to comply with the California Consumer Privacy Act of 2020 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. Under such regulation, the Company is at all times acting in its capacity as a Service Provider – processing information on behalf of its Customers, Rosies and Website visitors in a business-to-business setting.
Please read this Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. When you visit the Website or endeavor to become a Rosie, you consent to our collection and use of information about individuals as described below.
If you do not agree with our policies and practices, your choice is not to visit the Website or provide us with any Personal Information. This Policy may change from time to time. Your continued use of the Website, service as a Rosie, or purchaser of Services, in each case after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.
If you have any questions about this Policy or how we manage the information that you provide to us, please email us at email@example.com, or write to us at We Are Rosie, LLC, 1372 Peachtree Street NE, Atlanta, Georgia 30309.
This Policy applies to personal information we collect where such collected information identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device (collectively, “Personal Information”).
Personal Information does not include:
- Publicly available information from government records;
- Information received from the business relationship which has been de-identified or aggregated, such that it cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular person.
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and any comparable state regulation (as applicable); or
- Personal information covered by the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the Driver’s Privacy Protection Acts of 1994, or any comparable state regulations (as applicable)).
In particular, the Company has collected and processed the following categories of Personal Information from its Website users, Rosies and prospective Rosies through the methods described above within the last twelve (12) months (not intended to be exhaustive):
- Real name; postal address; email address; telephone number; website; device identifiers; employment, including current and historical; education and degrees earned; social media handles and other social media information; and LinkedIn profile and information contained thereon.
The Company obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you – Personal Information that you input into the Website, provide to us or any of our vendors via email or over the telephone, or provided to us or any of our vendors on written forms.
- Records and copies of your correspondence (including email addresses), if you contact us through email correspondence.
- Third-party sources – Personal Information from sources such as LinkedIn, recruiting websites, social media websites used by you, and our vendors.
- From background checks and/or education verification checks, in each case as required by our vendors.
The technologies we use for data collection may include
- Clear GIFs: We employ a software technology called clear gifs (aka web beacons/web bugs), that helps us better manage the content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of a sentence. We do not currently tie the information gathered by clear gifs to your Personal Information, although you agree that we may do so in the future. We use clear gifts in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see “Personal Information Rights and Choices” below.
- Log Files: As is true of most websites, we gather information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.
When you use our Websites, we may receive “do not track” requests from you, whether via signals from Web browsers or other mechanisms. At this time, we do not respond to such “do not track” requests, although we may choose to do so in the future.
use of your personal information
How We Use Your Personal Information
We use your Personal Information to hire and onboard Rosies (and prospective Rosies), to match Rosies to projects for our Customers. We may use your Personal Information in marketing materials that we provide to our Customers.
We also use your Personal Information on an anonymous, aggregate basis for data analysis regarding the community of Rosies in reports that will be used internally by the Company and provided externally to our Customers and to the press.
We also use your Personal Information for the purpose of sending e-mails to the entire Rosie community in order to provide information about the Company to the Rosies.
The Company does not generally disclose, share or sell your Personal Information to third-party businesses, although we may do so in the future. However, we share your Personal Information as follows:
- with our vendors for purposes of potentially hiring and onboarding Rosies as an employee of our vendors;
- with our Customers to match Rosies to projects for such Customers, to provide Services to Customers, to provide materials to a Rosie who may provide Services to Customers, and to give Rosies access to our Customers’ systems for the purposes of providing Services;
- to provide, sell, or transfer such Persona Information to a company that acquires, is acquired by, or is merged with or into us;
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request; and
- to enforce or apply any agreements, including for billing and collection purposes.
Such third parties to whom we provide Personal Information will have their own privacy policies. If you would like copies of any such third party privacy policies, please email us at firstname.lastname@example.org.
The website has industry standard security measures in place to protect the loss, misuse, and alteration of the information under our control. We have implemented measures designed to secure Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to, through, or by the Company over the Internet. Any transmission of Personal Information is at your own risk.
The Company is operated from the United States. If you are visiting the Website from outside of the United States, you agree to any processing of any personal information you provide us according to this Policy.
Minors and children should not use the Website.
personal information rights and choices
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of such residents’ personal information to third parties for such third parties’ direct marketing purposes. To make such a request, please e-mail us at: email@example.com.
Certain regulations (including the CCPA) provide individuals with specific rights regarding their Personal Information. The Company is at all times a Service Provider (as defined in CCPA) or Controller (as defined in the European General Data Protection Regulation) of the Personal Information. This section describes your rights and explains how to exercise those rights.
(1) Access to Specific Personal Information and Data Portability Rights
You may access, update, correct or extract any and all Personal Information from the Company.
For both Personal Information relating to users and the third parties about which you inputted Personal Information, you have the right to request that the Company disclose certain Personal Information to you about our collection and use of the Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable individual request we will disclose to you:
- The categories of Personal Information we collected about you or an individual about which you inputted Personal Information.
- The sources for the Personal Information we collected about you or an individual about which you inputted Personal Information.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you or an individual about which you inputted Personal Information (also called a data portability request).
(2) Deletion Request Rights
You may request to delete any and all Personal Information you have inputted.
You have the right to request that the Company delete any Personal Information about you or that you have inputted that was collected and retained, subject to certain exceptions including regulatory data retention requirements. Once we receive and confirm your verifiable individual request, we will delete (and direct our service providers to delete) the Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the Personal Information is necessary for us or our third party service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, 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.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation, including, but not limited to, compliance with applicable state and federal regulations that govern retention of Personal Information.
- Make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.
(3) Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to us.
Only you may make a verifiable request related to Personal Information that we collected from you or your users. You may make a verifiable request as the individual that the Personal Information is about (the user) or on behalf of an individual whose Personal Information you have provided to us, in such a case you must provide the verification of that individual.
You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:
- Provide sufficient information that allows us to reasonably verify you are either (i) the person about whom we collected Personal Information or (ii) an authorized representative which inputted the Personal Information
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you or an individual about which you inputted Personal Information.
We will only use Personal Information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
(4) Response Timing and Format
We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option and direction.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the Personal Information from one entity to another entity without hindrance.
We will not discriminate against you for exercising any of your Personal Information rights. Unless permitted by applicable regulations, and unless use of your Personal Information is required for use to maintain a business relationship with you or with any of our Customers, we will not:
- deny you goods or services;
- charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- provide you a different level or quality of goods or services; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
If you have any questions or suggestions regarding this Policy or your rights hereunder, please contact us as follows:
By email: firstname.lastname@example.org
By mail: We Are Rosie LLC, 1372 Peachtree Street NE, Atlanta, Georgia 30309
changes to our privacy statement
The Company reserves the right to amend this Policy at our discretion and at any time.
Last Updated and Effective: March 8, 2020.