Last updated: July 11th 2018
The Data we collect depends on how our Services are used. Sometimes we receive Data directly, such as when a Roger account is created, test transactions are submitted through our website, or we receive an email. Other times, we get Data by recording interactions with our Services by, for example, using technologies like cookies and web beacons. We also get Data from third parties, like our financial partners or identity verification services.
The collection and use of data from a variety of sources is essential to our ability to provide our Services – and to help keep the Services safe. Data is critical in helping us to increase the safety of Your online payments, and reduce the risk of fraud, money laundering and other harmful activity.
a. Personal Data. We call Data that identifies, or that could reasonably be used to identify, You as an individual as "Personal Data". We collect Personal Data in different ways. For example, we collect Personal Data when a business registers for a Roger account, a Customer makes payments or conducts transactions through a User's website or application, a person responds to Roger emails or surveys, or when a Customer uses the "Remember Me" feature. We also receive Personal Data from other sources, such as our partners, financial service providers, identity verification services, and publicly available sources. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that we may collect includes:
We do not collect or store personal data in the form of credit or debit card numbers. This information is collected through our partner Stripe. When using our Dwolla integration to connect your bank account to Roger and route ACH payments, Roger may store and transmit routing and account information.
b. Other Data. We call Data other than Personal Data "Other Data". We collect Other Data through a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our websites, websites that implement our Services, and the use of our Services generally. Other Data that we may collect include:
a. Personal Data. We and our service providers use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate financial loss or other harm to Users, Customers, and Roger; and (iv) promote, analyze and improve our products, systems, and tools. Examples of how we may use Personal Data include:
Roger does not sell or rent Personal Data to marketers or unaffiliated third parties. We share Your Personal Data with trusted third parties, including:
a. To Roger Affiliates. We share Data with entities worldwide that we control, are controlled by us, or are under our common control, to provide our Services. Roger.ai, Inc. is the party responsible for overall management and use of the Data by these affiliated parties;
b. To Roger Service Providers and Payment Service Providers. We share Data with service providers and payment service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, credit bureaus, payment method providers), website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing;
d. To Third Parties. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
e. Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.
We use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your account has been compromised), please contact us immediately.
You have choices regarding our use and disclosure of Your Personal Data:
a. Opting out of receiving electronic communications from us. If You no longer want to receive marketing-related emails from us on a going-forward basis, You may opt-out via the unsubscribe link included in such emails. We will try to comply with Your request(s) as soon as reasonably practicable. Please note that if You opt-out of receiving marketing-related emails from us, we may still send You important administrative messages that are required to provide You with our Services.
b. How You can access or change Your Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to Your Roger account or by contacting us.
If emailing us Your request, please make clear in the email what Personal Data You would like to have changed. For Your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that You use to send us Your request, and we may need to verify Your identity before implementing Your request. We will try to comply with Your request as soon as reasonably practicable.
The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.
You have the right to know which Personal Data we collect about you. You may object to any Personal Data being used at any time. You can also retract your permission to use your Personal Data at ny time. If the Data we retain about you is wrongful, you have a right to request it to be corrected or deleted. You can request this via email@example.com.
1460 Mission St.
San Francisco, CA 94103
Attention: Roger Legal
For EU individuals: The entity that provides Services in Europe is Roger.ai ApS, Sølvgade 38, 1103 København K.
Sensitive Information. Because email communications are not always secure, please do not include credit card or other sensitive Data (such as racial or ethnic origin, political opinions, religion, health, or the like) in your emails to us.