Privacy Policy

This Privacy Policy describes the personal information that Pluto News Inc., d/b/a RocaNews (“RocaNews” or “we”) collects from or about you online, whether in connection with https://www.rocanews.com/ or via our mobile application (collectively “Site”) or via our engagement with users through social media platforms (collectively, our “Services”) and how we use and protect that personal information.

In this Privacy Policy, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or can reasonably be linked, directly or indirectly, with a particular individual, device or household.

WHEN DOES THIS PRIVACY POLICY APPLY?

This Privacy Policy was posted and is effective on the Effective Date listed above. We may update this Privacy Policy from time to time, as detailed below. If you have a question about how your personal information is being used, you can contact us through the methods provided in the “Contact Us” section at the end of this Privacy Policy. If at any time you do not agree to the terms of this Privacy Policy, please stop using our Services as our Privacy Policy is binding upon all users of our Services.

This Privacy Policy applies to the personal information collected from or through our Services, when this Privacy Policy is specifically referenced in our Services or when we ask you to acknowledge it. This Privacy Policy also covers personal information that we collect from individuals who contact us by email or telephone.

This Privacy Policy does not apply to websites and other online services operated by other organizations. We are not responsible for the practices employed by websites and other online services linked to/from our Services nor the information contained therein. Often links to other websites are provided solely as a way for the user to obtain information that may be useful to them. Those other websites and services follow their own privacy policies, not this Privacy Policy. Please make sure to check those privacy policies so you know how your information is handled.

WHAT TYPES OF PERSONAL INFORMATION DOES ROCANEWS COLLECT AND WHY?

1. Information you choose to give us

We collect the personal information you choose to share with us. You have choices about the information we collect. When you are asked to provide personal information, you may decline. However, if you choose not to provide information that is necessary to provide a service, you may not be able to use some of our

Services. The personal information that you choose to give to us typically includes the following types of personal information:

Personal information that RocaNews Collects

Why this Personal Information is Collected

Contact Information:

Email address
Name
Company name
telephone number(s)
photograph
postal address
device type or identifier that you use to access our Service

To set up and maintain your subscription to our newsletter, your account, or registration for other Services.
To communicate with you and respond to your correspondence and requests
To obtain your feedback regarding our Services
To promote our Services, such as by sending you information and updates about our Services that we think will interest you
To provide customer service
To provide the advertising service you request

Other Information you give us when you fill out our on-line forms or send us emails

Company website address
Advertising campaign details

To respond to your request in the form or email, such as when you want to learn more about advertising
To obtain your feedback regarding our Services

Information associated with an account on a social media platform

When you connect to our Services through a social media platform such

as Instagram, we collect the personal information permitted by the social media platform and your account permissions

To provide our Services
To engage with subscribers and followers
To learn how users interact with our Services so that we can improve our Services and develop new features

2. Information automatically collected during use of our Services

We automatically collect certain information from and about use of our Site from users’ computers and mobile devices. Some automatically-collected information is personal information under certain laws. This information is automatically collected using cookies, pixel, web beacons and similar data collection technology (collectively, data collection technology).

The information that we automatically collect includes:

information about your computer or mobile device, such as device type and identification number, browser type, internet service provider, mobile network and operating system
IP address and broad geographic location (e.g., country or city-level location)
how a computer or mobile device interacts with our Site, including the date and time our Site is accessed, links clicked and videos watched
traffic and usage measurements
data about the third-party sites or services accessed before interacting with our Services

3. Personal Information received about prospective users and customers from third parties

The types of personal information that we receive from third parties are:

Marketing services vendors that help us identify individuals who may be interested in learning more about our Services and to supplement personal information we already have, such as when we acquire a contact list from data aggregators
From publicly-available sources so that we can better understand our customers and users

When we combine data from third-party data sources to enhance the personal information that we hold about users or prospects, we require that each data provider confirm that its sharing of personal information with RocaNews is lawful.

4. Other information collected with consent

We may ask individuals for consent to collect specific types of personal information.

5. Site interactions

We may use technology to monitor how you interact with our Site. This may include without limitation which links you click on, information that you type into our online forms, and about your device or browser. Further, we utilize session replay technology to monitor and record keyboard clicks and movements, keystrokes, and pages and content viewed by you. We regularly use these technologies when you use Talk to Roca and Prompts, which are features on our Site similar to a chat that allows you to communicate with Roca Editors. Please discontinue use of the Site if you do not consent to our collection of such information.

HOW DOES ROCANEWS USE PERSONAL INFORMATION?

RocaNews uses personal information to provide our Services, manage our business, protect users and enforce our legal rights.

We use personal information to provide, personalize and improve our Services, including:

to centralize personal information in our customer relationship management database
to send marketing and non-marketing communications to users
for targeted advertisements (also sometimes referred to as personalized or interest-based advertising) based on information generated by a user’s online activity, such as visiting websites that contain our advertising partners’ cookies. Typically, although not always, the information used for interest-based advertising is collected through data collection technology as described below
to create and update accounts
for customer service
to analyze how users interact with our Services and activity trends so that we can develop new features that meet user expectations
to improve our Services and users’ experience of them
for data analytics, research, product development and machine learning that enable us to better understand our customer base and offerinnovations for them
for monitoring and testing our Services, including to troubleshoot operational problems
to create anonymized data, which are not subject to this Privacy Policy
to detect and protect against fraud and unauthorized use of our Services
for risk management and similar administrative purposes, such as to monitor and enforce compliance with our customer agreements

DO USERS HAVE ACCESS TO PUBLIC POSTING AREAS?

Yes, occasionally if a user submits a good idea or feedback we decide to implement, we sometimes include a screenshot of the message to give credit to the user for their idea. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.

DOES ROCANEWS USE COOKIES AND OTHER DATA COLLECTION TECHNOLOGY?

We use cookies and other data collection technology to recognize users and other individuals and/or their devices when they use our Services.

What are cookies?

Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer or device, such as settings, browsing history and activities conducted while using our Services.

RocaNews also uses “pixels” (sometimes called web beacons). Pixels are transparent images that can collect information about website usage across websites and over time.

COOKIES & THIRD PARTY ADVERTISING

Cookies that RocaNews sets in our Services are called first-party cookies. Cookies set in our Services by any other party are called third-party cookies. Third-party cookies enable third-party features or functionality on or through our Services, such as analytics and marketing automation. The parties that set third-party cookies can recognize your device both when you use it to access our Services and also when you use it to visit certain other websites. To learn more about cookies generally, visit www.allaboutcookies.org. You may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this privacy policy. Again, we do not endorse and are not responsible in any way for the privacy practices of third party websites.

Online Tracking

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser blocks that website from collecting certain information from the browser cache. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including RocaNews, do not yet respond to DNT signals.

Why does RocaNews use cookies and other tracking technology?

Some cookies are required for our Services to operate. Other cookies enable us to enhance the experience of our Services.

The types of cookies served on through our Services and why they are used is as follows:

Strictly necessary cookies are required for our Services to operate.
Performance or Analytics cookies collect information about how our Services are used so we can analyze and improve our Services. Performance or analytics cookies typically remain on your computer after you close your browser until you delete them.
Advertising cookies are used to make advertising messages more relevant to you by helping us display advertisements that are based on your inferred interests, prevent the same ad from appearing too often and ensure that ads are properly displayed for advertisers.

Pixels and similar data collection technology enable RocaNews to monitor traffic patterns from one webpage to another, to deliver or communicate with cookies, to understand whether users visit our Services after seeing our online advertisement displayed on a third-party website, to improve performance of our Services and to measure the success of our email marketing campaigns.

Our Services use Google Analytics for targeted advertising (which Google sometimes refers to as ‘remarketing’). Google uses a cookie that Google recognizes when you visit various websites. The data collected through Google’s cookies help us analyze how our Services are used.

The information generated by the cookie about use of our Services (including your IP address) is transmitted to and stored by Google on servers in the United States.

On behalf of RocaNews, Google will use this information to compile reports for us and third parties that help operate and provide our Services. Google will not associate your IP address with any other data held by Google. For more information about how Google collects, uses and shares your information, please visit https://www.google.com/policies/privacy/partners/ or Google’s Privacy Policy [link to https://policies.google.com/privacy].

RocaNews may use information about interactions with our Services for digital marketing purposes. RocaNews and third parties also may deploy technology that measures the effectiveness of advertisements by using cookies or web beacons to collect information about use of our Services and other websites to provide relevant advertisements on other websites about goods and services that may interest you. The information collected through this process does not enable us or the third parties to identify your name, contact details or similar directly identifying details unless you choose to provide them.

Cookie Choices

You have the right to decide whether to accept or reject cookies. You can set your browser to refuse all cookies or to indicate when a cookie is set. (Most browsers accept cookies automatically but allow you to disable them but note that some features of our Services may not work properly without cookies.)

Google has developed an opt-out browser add-on if you want to opt out of the cookies used for Google Analytics. You can download and install the add-on for your web browser here. You may refuse the use of these cookies by selecting the appropriate settings on your browser.

HOW DOES ROCANEWS DISCLOSE PERSONAL INFORMATION?

RocaNews discloses personal information with people and businesses that help operate our Services and carry out our business and when we are legally permitted or required to do so.

RocaNews discloses personal information with the following categories of recipients:

Professional advisors, such as lawyers, accountants, insurers and information security and forensics experts
Service providers to enable them to perform services on our behalf, including data analytics, data security, marketing, surveys, research and otherwise to help us carry out our business
Potential or actual acquirers or investors and their professional advisers in connection with any actual or proposed merger, acquisition or investment in or of all or any part of our business. We will use our best efforts to ensure that the terms of this Privacy Policy apply to personal information after the transaction or that users receive advance notice of changes to personal information processing
Competent law enforcement, government regulators and courts when we believe disclosure is necessary (i) to comply with the law, (ii) to exercise, establish or defend legal rights, or (iii) to protect the vital interests of users, business partners, service providers or another third party
Other third parties with your permission or as required or permitted by law

When required, the recipients are contractually bound to handle personal information in compliance with this Privacy Policy.

HOW DOES ROCANEWS PROTECT PERSONAL INFORMATION?

RocaNews uses technical, physical, and administrative safeguards intended to protect the personal information in our control. Our safeguards are designed to provide a level of security appropriate to the risk of processing personal information and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and a procedure for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of personal information. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure due to the inherent risks of data transmission over the Internet. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.

You are responsible for maintaining the security of your account credentials. RocaNews will treat access to our Services through a user’s account credentials as authorized by the user.

RocaNews may suspend access to all or part of our Services without notice if we suspect or detect any breach of security. If you believe that information you provided to RocaNews or your account is no longer secure, please notify us immediately at privacy@rocanews.com

If we become aware of a breach that affects the security of your personal information, we will provide you with notice as required by applicable law. When permitted by applicable law, RocaNews will provide this notice to you through the email address associated with your account. By using our Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice via our Site if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

UNAUTHORIZED ACCESS TO PERSONAL INFORMATION AND THE SERVICES – INCLUDING SCRAPING – IS PROHIBITED AND MAY LEAD TO CRIMINAL PROSECUTION.

HOW LONG DOES ROCANEWS RETAIN PERSONAL INFORMATION?

We retain personal information about users for as long as a user’s account is active and otherwise as long as necessary for the purposes described above. We also retain personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

RocaNews regularly updates the information in our Services and removes information when RocaNews becomes aware the information is obsolete or inaccurate. Otherwise, we retain the personal information that we handle subject to this Privacy Policy in accordance with our data retention policy.

At the end of the relevant retention period, we take measures to delete or de-identify personal information or. If working to delete and deletion is not possible, we may segregate and securely store personal information until deletion is possible.

WHAT CHOICES ARE AVAILABLE FOR PERSONAL INFORMATION?

To stop receiving promotional emails from RocaNews, please click the “Unsubscribe” link at the bottom of the email. After you opt out, we may still send you non- promotional communications, such as administrative information about your account or security related notices.

IF YOU ARE LOCATED IN A JURISDICTION WITH DATA PROTECTION LAWS THAT OFFER YOU PRIVACY RIGHTS NOT DESCRIBED IN THIS PRIVACY POLICY, PLEASE CONTACT US AT privacy@rocanews.com. We respect your privacy rights and will do our best to accommodate your requests.

California’s “Shine the Light” law, permits California residents to request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year, or providing a mechanism by which you can opt out of such sharing. At this time, RocaNews does not share personal information with third parties for their direct marketing purposes.

HOW DOES ROCANEWS PROTECT CHILDREN'S PRIVACY?

We do not knowingly collect personal information online from minors. If you become aware that a minor has provided us with personal information without parental consent, please contact privacy@rocanews.com. Once we become aware, we will take steps to remove the minor’s personal information.

DOES ROCANEWS TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?

Our Services are intended for use by residents of the U.S. and our servers are located in the U.S. Nonetheless, RocaNews and/or RocaNews’ service providers may store personal information outside the U.S. These other jurisdictions may have data protection laws that are different from U.S. laws. When your personal information is transferred by us or our service providers, we take measures to deploy appropriate technical and organizational safeguards consistent with the requirements of applicable data protection law. We primarily use Standard Contractual Clauses (including the UK Data Transfer Mechanism) for data transfers from the European Union, the EEA, the UK and Switzerland to countries outside the EEA (including the UK). For transfers between other jurisdictions, we may rely on other legal mechanisms for international transfer, as appropriate under the relevant law. Please contact us for more information and to receive a copy of the standard contractual clauses we may utilize.

WHEN IS THIS PRIVACY POLICY CHANGED?

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. The most current version always is available at www.rocanews.com/privacy.

When we update this Privacy Policy, we will post the updated version on the Site and change the Effective Date above. We also take appropriate measures to inform you in advance of significant changes that we believe affect your privacy rights so that you have an opportunity to review the revised Privacy Policy before it is effective. If your consent is required by applicable privacy laws, we will obtain your consent to changes before the revised Privacy Policy applies to you. Please regularly check this Privacy Policy to ensure you are aware of the updated version.

WHO DO I CONTACT WITH QUESTIONS?

If you have any concerns or questions about any aspect of this Privacy Policy, please contact us as follows:

privacy@rocanews.com

Address for legal notices:

RocaNews

494 Broadway, Floor 2

New York, NY 10012