Introduction
Rotational Labs, Inc. (“Rotational,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use Rotational’s sites, products, and services.
Rotational is committed to protecting the privacy of its Users whose information is collected and stored while using Rotational’s sites, products, and services through our website or applications. We have a longstanding practice of undertaking internal privacy assessments of our products and services and of adopting a “privacy by design” approach to product development. While we are always reviewing our existing privacy practices and security safeguards, we believe them to be robust and appropriate for the types of data we maintain on behalf of ourselves and our clients.
This Privacy Policy governs the manner in which Rotational Labs, Inc. collects, uses, maintains and discloses information collected from users and clients (each, a “User”) of the https://rotational.io website (“Site”). This privacy policy applies to the Site and all products and services offered by Rotational Labs, Inc. at related websites.
WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.
Please contact privacy@rotational.io with questions about our privacy policy.
Data Privacy Framework
Rotational Labs, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Rotational Labs, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Rotational Labs, Inc. commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.
What is the EU-US Data Privacy Framework?
The EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. Data Privacy Framework (UK Extension to the EU-U.S. DPF) were developed to facilitate transatlantic commerce by providing U.S. organizations with reliable mechanisms for personal data transfers to the United States from the European Union / European Economic Area and the United Kingdom (and Gibraltar) that are consistent with EU and UK law.
What does this mean for you?
By adhering to the DPF, Rotational provides several key assurances to our users and clients:
Jurisdiction: The Federal Trade Commission has jurisdiction over our compliance.
Transparency: We clearly explain how we collect, use, and share your personal data through our Privacy Policy and other resources.
Data Protection Principles: We abide by the DPF’s principles, which are similar to those of the GDPR and Swiss data protection laws. These principles include:
- Lawfulness, fairness, and transparency: We only process your data transparently and for lawful purposes.
- Purpose limitation: We only use your data for the purposes it was collected.
- Data minimisation: We only collect and process the minimum amount of data necessary for the stated purpose.
- Accuracy: We strive to keep your data accurate and up-to-date.
- Storage limitation: We only store your data for as long as necessary for the stated purpose.
- Integrity and confidentiality: We take appropriate technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction.
- Accountability: We are responsible for complying with these principles and are subject to enforcement mechanisms.
Individual Rights: You have certain rights concerning your personal data, such as the right to access, rectify, erase, restrict processing, and object to processing.
Redress Mechanism: You have access to an independent mechanism for resolving complaints about our data practices.
You can view our certification online by visiting the U.S. Department of Commerce’s website at dataprivacyframework.gov.
Rotational remains responsible for any of your personal information shared with subprocessors for external processing on our behalf, as described in the “Sharing Personal Information” section of our Privacy Policy.
In adherence to our privacy policy, if any concerns regarding personal data, as per the Data Privacy Framework (DPF) principles, remain unresolved internally, customers are encouraged to utilize our designated third-party dispute resolution provider EU DPA through the US Council for International Business, free of charge.
Additionally, we agree to cooperate with relevant data protection authorities in the European Economic Area and the UK, if necessary, to address any outstanding complaints.
Under certain conditions (as described under the EU-US DPF Principles that Rotational adheres to), you may invoke binding arbitration by delivering a notice to us via privacy@rotational.io, including when other dispute resolution procedures have been exhausted. Rotational is also subject to the investigatory and enforcement powers of the Federal Trade Commission.
We will remain liable for onward transfers of your personal data to third parties (including our Service Providers) in accordance with applicable data transfer mechanisms. If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles and the UK GDPR, the Principles shall govern with respect to personal data transferred under the DPF. To learn more about the DPF program, including its application in the UK, and to view our certification, please visit dataprivacyframework.gov.
Information Collected
When you register to use our Site, products or services, we collect information for the provision and use of products or services. The information collected will be stored on our servers. Information collected may include:
- Personally Identifying Information: We may collect personally identifying (“PII”) information from Users in a variety of ways, including, but not limited to, when Users visit our Site, place an order, respond to a survey, fill out a form, or in connection with other activities, services, features, or resources we make available on our Site. Users may be asked for, as appropriate, their name, email address, mailing address, phone number, or credit card information. Users may, however, visit our Site anonymously. We will collect personally identifying information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identifying information, except that it may prevent them from engaging in certain Site related activities. You are able to change your personal information via email by contacting us at privacy@rotational.io or through your profile or account settings on our Site, products, or services.
- Non-Personally Identifying Information: We may collect non-personally identifying information about Users whenever they interact with our Site. Non-personally identifying information may include the browser name, the type of computer, and technical information about the User’s means of connection to our Site such as the operating system or the Internet Service Provider utilized and other similar information.
- Geolocation and Equipment Information. We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Site, products, or services., and usage details.
- Financial Information: We currently do not collect or store any credit cards or bank information, as we are using a third-party payment processor. However, we will update this Privacy Policy if we start using and storing such information. We will also inform you via reasonable means if we start collecting such information from you.
- Web Browser Cookies: Our Site may use “cookies” to enhance User experience. The User’s web browser places cookies on their local machine for record-keeping purposes and sometimes to track information about them. A User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site or products or services may not function properly.
How We Collect Information
We collect personal information from you in the following ways:
- At registration on our Site, products or services;
- When you interact with our advertising and applications on third-party website and services, if those applications or advertising include a link to this Privacy Policy;
- From you placing an order, which includes details of transactions you carry out on our Site or products;
- When you subscribe to a newsletter;
- From your responses to a survey;
- From forms, contracts, or agreements signed and completed by you;
- From records or copies of correspondences (including email addresses) if you contact us
We collect information from you automatically when you navigate through our Site or products and services in the following ways:
- Usage details;
- IP addresses
How We Use Collected Information
Rotational may collect and use Users’ personal information for the following purposes:
- Personalize your experience in using our Site, products, and services;
- Provide you with information, products, or services requested from us;
- Provide you with notices about account and/or subscription, including expiration and renewal notices;
- Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection;
- Notify you about changes to our Site, products, or services;;
- Allow you to participate in interactive features on our Site, products, or services.;
- Improve the Site, products, or services.;
- Improve our customer service;
- Process transactions;
- Anonymize data and aggregate data for statistics;
- Contact you for other purposes with your consent;
- Contact you about our products and services that may be of interest;
- Contact you about third parties’ goods and services;
- Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 15, via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to your product and/or service; and (iv) market to our mailing list or continue to send email to you after the original transaction has occurred.
- To advertise, promote, and encourage interaction with the Services: We utilize your contact details and information about your usage of our Services to send marketing communications that are tailored to your interests in order to advertise, promote, and encourage engagement with our Services. You have the ability to manage whether you receive such communications, as explained in “Choices Users Have About How Rotational Uses and Discloses Information”.
How We Protect Your Information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. Rotational’s organizational and technical safeguards include:
- All Rotational employees have signed a non-disclosure and confidentiality agreement regarding access to customer data
- Rotational maintains a written information security policy that specifies the security standards it applies to protect the personal data it processes. The information security policy mandates the use of appropriate technical and organizational security measures to protect personal data against unauthorized and unlawful processing and against accidental loss, damage or destruction.
- Rotational has implemented technical access controls that restrict access to personal data it processes to duly authorized employees only.
- Access to personal data will be controlled through access privileges granted through a formal identity and access management system.
- Rotational takes regular back-ups of the personal data that it processes. Rotational monitors its servers 24-hours/day as a measure to prevent unauthorized access to client data.
Sharing Your Personal Information
There are times when we may share Personal Information that you have provided us with others to enable us to provide you products and services, including contractors, service providers, and third parties (“Partners”). This section discusses only how Rotational may share such information with Partners. We take reasonable measures to ensure that our Partners protect your Personal Information.
Other Disclosure of Personal Information
We may disclose personal information in the following situations: (i) to comply with court orders, laws, or legal processes, including responses to government or regulatory requests; (ii) to enforce our Terms of Service and other agreements, including for billing and collections; (iii) if we believe it is necessary to protect the rights, property, or safety of Rotational, our customers, or others; and (iv) to protect against fraud and reduce credit risk, which may involve sharing information with other companies and organizations.
Third Party Disclosure
We will never sell personal information ever. We do not sell, trade, rent, or share your personal information with others. This excludes our hosting partners and service providers who help us operate our website, products, and services, as long as they agree to keep your information confidential.
Rotational does not and will not sell aggregated, non-personally identifiable data about our users or website visitors to 3rd parties for marketing purposes.
Choices Users Have About How Rotational Uses and Discloses Information
You can make specific decisions concerning your information such as:
- You can set your browser to refuse some or all the browser cookies, but if you disable or refuse cookies, some parts of our Site, products, or services may not be accessible or function properly.
- You have the right to request access to the personal information that we hold about you. As a Rotational customer, you can request a copy of your information, object to our use of your information (including for marketing purposes), request the deletion or restriction of your information. To access your personal data, please follow the instructions provided in Rotational’s Terms of Use for the specific products or services that you consume.
- You may opt-out of receiving marketing or promotional communications from us at any time by clicking on the ‘unsubscribe’ link at the bottom of our emails or by contacting us directly at privacy@rotational.io. See our policy below related to the CAN-SPAM Act of 2003.
Your request and choices may be limited in certain cases:
- We take the privacy of our users seriously and strive to protect their personal information. However, we cannot disclose personal information about another person. Any such data requests will be denied.
- While we take every precaution to protect your personal information, we cannot be held liable for any data shared with third-party service providers for which you have given your consent. If you wish to delete any such information, you must contact those third-party service providers directly.
- Please note that if the products or services are managed for you by an administrator, you may be required to contact them for any requests related to your personal information. Your administrator can assist you with your requests and ensure that they are handled appropriately.
Third Party Websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
Children’s Online Privacy Protection Act (COPPA)
Protecting the privacy of children is especially important. For that reason, we never collect or maintain information at our Site from those we actually know are under 13, and no part of our website is structured or designed to attract or be relevant to anyone under 13. Our Site, products, and services do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at privacy@rotational.io.
CAN-SPAM Act of 2003
The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:
- not use false or misleading subjects or email addresses;
- identify the email message as an advertisement in some reasonable way;
- include the physical address of Rotational Labs, which is Attn: Rotational Labs, 202 N Cedar Ave, Suite #1, Owatonna, MN 55060, USA.
- reasonably monitor third-party email marketing services for compliance, if one is used; h- onor opt-out/unsubscribe requests quickly; and
- give an “opt-out” or “unsubscribe” option.
If you wish to opt-out of email marketing, follow the instructions at the bottom of each email or contact us at privacy@rotational.io and we will promptly remove you from all future marketing correspondences.
Copyright Infringement/ DMCA Notice
If you believe that any content on our Site, products, or services violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.
- Your physical or electronic signature;
- Identification of the copyrighted work(s) that you claim to have been infringed;
- Identification of the material on our Site, product, or services that you claim is infringing and that you request us to remove;
- Sufficient information to permit us to locate such material;
- Your address, telephone number, and email address;
- A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
- A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.
- Rotational’s Copyright Agent to receive DMCA Takedown Notices is Data Protection Officer (DPO), at privacy@rotational.io, Attn: DMCA Notice, 2204 Dayton Ave, St. Paul, MN 55014.
You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by Rotational in connection with the written notification and allegation of copyright infringement.
California Privacy Rights
Rotational does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Site, products, or services that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email at privacy@rotational.io or write Rotational Labs, Inc. 2204 Dayton Ave, St. Paul, MN 55014.
Note that if we delete your Personal Information as requested, (i) we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a period of time during the discontinuation and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at privacy@rotational.io or write Rotational Labs, Inc. 2204 Dayton Ave, St. Paul, MN 55014.
Changes to Our Privacy Policy
Rotational Labs, Inc. has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.
Your Acceptance of These Terms
By using this Site and our products and services, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site, products, or services. Your continued use of our Site, products, or services following the posting of changes to this policy will be deemed your acceptance of those changes.
Contact Us
If you have any questions about this Privacy Policy, the practices of our site, products, and services, or your dealings with this site, please contact us at:
Data Protection Officer
Email: privacy@rotational.io
Address: Attn: Rotational Labs, 202 N Cedar Ave, Suite #1, Owatonna, MN 55060, USA
Changelog
Privacy Policy Last Updated on November 21, 2024.