Privacy Policy

We Are Rosie, LLC (the “Company” or “We”) maintains a network of consultants (“Rosies”) who provide marketing and related services (the “Services”) to the Company’s customers (each a “Customer”).

The Company respects Your privacy and is committed to protecting it through our compliance with this Privacy Policy (this “Policy“). This Policy describes the types of Personal Information (as defined below) We may collect from You or that You may provide when You use our website, wearerosie.com (the “Website”), whether through a computer or on a mobile device. This Policy is intended to be read by and pertains to processing of Personal Information provided by Customers, Rosies and prospective Rosies, and users of the Website (“You” or “Your“).

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.

This Website is not intended for use by minors. Subsequently, minors and children should not use the Website.

This Policy only applies to the use of Personal Information obtained by the Company, whether from You directly or from a third party. It does not apply to personal data collected by third parties during Your communications with those third parties or Your use of their products or services (for example, where You follow links on our Website to third-party websites over which We have no control).

Further, this Policy is not intended to cover the processing of workplace personal data. Accordingly, if You are engaged as an employee with us, please see our Employee Handbook which sets out further information about how We may process Your personal data in connection with Your employment and/or engagement.

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 practices regarding Your Personal Information. When You visit the Website or endeavor to become a Rosie, You consent to our collection and use of information about You as described below.

If You do not agree with our policies and practices, You can choose to discontinue use of the Website or not provide any Personal Information as defined below. When You use our Website, We may receive “do not track” requests from you, whether via signals from web browsers or other mechanisms. We will respond accordingly.

Third parties to whom We provide Personal Information will have their own privacy policies. When interacting with third parties, they will have their own privacy policies available on their websites.

The Company reserves the right to amend this Policy at our discretion and at any 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, please email us at privacy@wearerosie.com, or write to us at We Are Rosie, LLC, 1450 W Peachtree St NW #200, PMB 29069, Atlanta, Georgia 30309

Collection

This Policy applies to personal data We collect; where such collected data 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”). When We talk about Personal Information, We mean any information that relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address), or to other factors that are specific to them, such as their physical appearance.

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 may collect and process the following categories of Personal Information from its Website users, Rosies, and prospective Rosies through the methods described below within the last twelve (12) months (not intended to be exhaustive).

What Personal Information We Collect

Identity Data	First name; last name.
Contact Data	Delivery address; billing address; email address; telephone number; social media handle.
Applicant Data	Date of birth; gender; country; nationality; CVs, work experience; dietary requirements any other personal data that You may provide in advance of/during Your supply of services to us.
Profile Data	Interests and preferences; contact/marketing preferences; feedback and survey responses.
Behavioral Data	Data relating to Your browsing activity, obtained through the use of cookies, pixel tags and other similar technologies; information about when Your current or previous sessions started; details about any services You viewed or purchased through the Site.
Technical Data	IP address; browser type and operating system; geolocation, to ensure we’re showing You the correct notices and information; any other unique numbers assigned to a device.
Publicly Available Data	Information about articles (or similar) that You may have published; information about Your interests or affiliations or publicly stated positions on political matters, corporate matters, and similar.

How We Collect Personal Information

Personal data You provide to us	You may give us Your personal data directly, for example, when You obtain services via our Site, contact us with inquiries, complete forms on our Site, subscribe to receive our marketing communications, or provide feedback to us.
Personal data We collect using cookies and other similar technologies	When You access and use our Site, We will collect certain Behavioral Data and Technical Data. We collect this personal data by using cookies and other similar technologies. 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.
Personal data received from third parties	We may receive personal data about You from third parties. Such third parties may include analytics providers, data brokers, third-party directories, and third parties that provide technical services to us so that We can provide our Site and our Services.
Publicly available personal data	From time to time, We may collect personal data about You (Identity Data, Contact Data, or Publicly Available Data) that is contained in publicly available sources (including open source data sets or media reports) or that You or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).

Who We Collect Personal Information from

Site visitors	We will collect and process Your personal data in connection with Your interaction with us and our Site.
People who contact us with inquiries	If You contact us with an inquiry through our Site, submit a complaint, or provide any feedback to us in our surveys and feedback forms, We will collect and process Your personal data in connection with Your interaction with us and our Site.
Client personnel	We may collect and process Your personal data in connection with the supply of services to You and/or Your organization.
Talent	If You supply services and/or content to us and/or work with us to provide services to our client (including featuring in content We produce), We may collect or process Your personal data, such as Your Identity Data, Contact Data, Financial Data, CVs in connection with such supply of services and/or content to us and our clients.
Partner/supplier personnel	If You (or Your organization) supply products or services to us or otherwise partner with us, We may collect and process Your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as Your Contact Data.
Event attendees	If You attend one of our events, We will process personal data about You in connection with Your attendance at the event. For example, We may ask You to complete a registration or feedback form, or other documents relating to the event.
Job applicants	If You apply for a job with us, whether through the Site or otherwise, We will collect and process Your personal data in connection with Your application.
Members of the public	We may process Your data in connection with the provision of the Services to our clients.

Use of Personal Information

How We Use Personal Information

Operation of the Website

When You browse our Website, We collect and process Behavioral Data and Technical Data to help us understand how You are using and navigating our website. We do this to better understand which parts of our Website are more or less popular and to improve the structure and navigation of our Website.

Provision of client-facing services

We may, acting on our own behalf and on behalf of our Customers, collect personal data about You; including the types of personal data we listed above in connection with the provision of our Services. We use Your Personal Information to engage and onboard Rosies, and to match Rosies (and prospective Rosies) to projects for our Customers. We may use Your Personal Information in marketing materials that We provide to our Customers.

Marketing

We may use your Personal Information for marketing communications by email or via phone. Our marketing can include press releases and information about us. 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.

How We Share Personal Information

The Company does not generally disclose, share, or sell Your Personal Information to third-parties. Unless We gain Your explicit consent to do so, the Company does not disclose, share, or sell Your Personal Information to third-parties.We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality, and security standards and obligations.

Security

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.

Rights & 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: privacy@wearerosie.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.

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 input Personal Information (also called a data portability request).

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 the 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.

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 who 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.

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.

Non-Discrimination

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.

Contact

If You have any questions or suggestions regarding this Policy or Your rights hereunder, please contact us as follows:

By email: privacy@wearerosie.com

By mail: We Are Rosie LLC, 1450 W Peachtree St NW #200, PMB 29069, Atlanta, Georgia 30309