Privacy policy

With this privacy policy (“Policy”), we want you to know how we in Rochalur promise to take care of the personal information we receive from you. This includes the information you provide to us (for example, when you create a Partner account, a Customer account, or by subscribing to our newsletter), information that we find out when you are on our website or when you use our products and services. This "Policy" explains what kind of personal information we receive from you and for what reasons, how we use, store or transfer such data, as well as how you can contact us to ask about your data and protect your rights.
We collect, use, store and transfer (“process”) your personal information following applicable data protection legislation, including, but not limited to (EU) General Data Protection Regulations (2016/679) (“GDPR”), and apply national data protection legislation.
Depending on whether you are a site visitor, a Client or a Partner, we will process your relevant personal information. For more information about the personal information we collect, use and process, see the sections below.

We will involve other companies to fulfil our goals and commitments outlined in this “Policy”. When we collect personal information about you, you have the following rights under applicable law:
- The right to access and correct your personal information;
- The right to object to our processing of personal data;
- The right to limit our processing of personal data;
- The right to require us to delete your personal information;
- The right to transfer your data to other holders of information.
For more information about the rights you have concerning your personal information, see the sections below.

If you have any questions about how we use your personal information, we ask you to contact us first. However, you can always file a complaint with the appropriate authority, in particular, where you live, work, or where you think a violation of your rights has occurred.

If you have any questions about the personal information that we collect, how we use your data and how we transfer it to achieve our goals, as stated in this document, please contact us at: support@rochalur.com or by mail, which is listed in Section 23 below.


1. Who we are
2. What we promise
3. Definition of personal information
4. Reasons for processing your data
5. When to collect your data
6. What data we collect
7. How we use your data
8. With whom we share your information
9. Children and our services
10. How we use cookies and tracking technology
11. Security measures to protect your data
12. If you choose not to share data with us
13. Where your personal data will be stored
14. How long we will keep your data
15. How to access, change and update your data
16. The right to object to process your data
17. The right to delete
18. The right to restrict
19. How to get a copy of your data 
20. How to ensure your rights
21. How to withdraw your consent or terminate cooperation
22. Changes in privacy policy
23. How to contact us and how to file a complaint
24. Other useful information


We are ROCHALUR, address: 5 Devova Street, Ljubljana, Slovenia
This “Policy” applies to the website we operate - rochalur.com and also applies to all members of our business system and all users of our services and products (from now on “Services”).
We control collected personal information. If you have questions or would like to know more concerning your personal information, contact us directly at support@rochalur.com or contact us at the address that is listed in Section 23 below.


We promise to keep your data safe and not to transfer them to third parties, except for:
- Receiving the official request of law enforcement agencies;
- Execution of a court decision;
- Preventing fraud;
- Protection of user rights.
The transfer of personal data to third parties can also be carried out with your direct consent.
We promise to give you the right to access and edit your data, as well as provide you with ways to manage and analyze your marketing decisions or any other information you receive from us.


Personal information may be any information relating to an identified individual. In other words, it can be any information that can allow us to identify you either directly or indirectly (for example, your name, email address, IP address or your mailing address). In this "Policy," we will use the word "data" to denote personal information.


We will use and process data about you only if we have one of the following reasons:
- Fulfil the contract between us (for example, when you registered or subscribed to our Services);
- When it is our legal obligation (for example, for accounting purposes and to fulfil our commitments to state bodies);
- When you give consent to this (for example, when you subscribe to our newsletter or register for our services);
- When it is in our legitimate interests (for example, to ensure compliance with our policies, to manage daily affairs, to conduct statistical analysis, for direct marketing purposes, to provide information security, to prevent fraud, or, if necessary, to transfer Data to another part of the organisation).

Relying on legitimate interests, we concluded that our interests are not cancelled by your interests or fundamental rights and freedoms. You can contact us to learn more about how we came to this conclusion.

Additional reasons for processing your data:
- Shipment of the ordered products to your address;
- A message regarding the support request and the questions you ask;
- Informing about updates of products and services, sending guides and useful information about services, questionnaires designed to improve user interaction;
- Telling about subscription status, upcoming payments and other account related issues that may prevent you from using our services, products and services;
- Improving your user experience by adapting to location and language;
- Personalisation of services using demographic information.


We will collect data about you using our Services in the following situations:
- When you register an account on our website;
- When you subscribe to our newsletter;
- When you buy our products;
- When you use our Services;
- When you contact our support service or us by email, letter, phone or in person;
- When you use our website and applications;
- When you participate in our surveys;
- If you participate in user research initiatives;
- When you click on one of our ads;
- When you visit our groups in social networks.


We use data that you explicitly provided us within various situations. We also use personal information thatis generated by your device when you use our Services. These categories are described in more detail below.

The data you explicitly provide us with:
- Name
- Last Name
- Date of Birth
- Location
- E-mail
- Telephone number
- Shipping Addresses
- IP address
- Device ID
- Device Description
- Aliases

In addition to the above, and when subscribing to our services, you may have to provide us with the name, registration documents and contact information about yourself as a legal entity.

Finally, we collect any other data that you voluntarily provide us with when you contact support or when you fill out our surveys or join our testing.

The data we collect when you use our services:
- Profile and data usage. This includes the profile you create to identify yourself when connecting to our Services, as well as the IP address and cookies that can uniquely identify your browser. They also contain other data on how you use our Services. We collect this data from devices that you use to connect to these Services, such as computers and mobile phones, using cookies and other tracking software.
- Transaction data
- Location data
- Preferred language
- Gender
- Information about your device, hardware and software
- Transfer of pages and entry/exit time
- Information about professional and service activities
- Service reports on failures and errors
We will always ask for your consent to provide us with your location data. You have the right to withdraw your consent at any time, as described in Section 21 below.

Data from third parties with whom we work:
- Google Universal Analytics
- Facebook Pixel
- Hotjar
- Google adwords
- Google Tag Manager
- Google adsense
- Google admobs
- Google Firebase
- Google Cloud Platform
- Google BigQuery
- MailChimp
- HubSpot
- FreshDesk
- Unity
- Apple App Store
- Google Play Store
- Taxamo
- Braintree
This is used to help us provide you with relevant information, to prevent fraud or abuse, and to collect your geolocation for tax purposes.


We use the information we receive from your use of our Services to provide, maintain, protect and improve the Services, as well as to develop new ones.

We use your information in the following ways:
- To work, improve, develop and provide you with our Services
- To respond to requests or comments from you
- To verify your identity to prevent unauthorised access
- To provide you with software updates
- To understand trends in use
- To calculate marketing conversion rates and other elements of advertising effectiveness
- To help in tracking and correcting errors in the provided services and applications
- To customise your user experience
- To maintain the integrity and security of the Services
- Process transactions and communicate with you regarding these transactions
- To ensure compliance with our terms, such as our license agreement, terms of use, rules of conduct and this policy
- To send you newsletters, advertising notices and offers you previously agreed to
- To ensure the fairness of our Services, investigate and prevent fraud and illegal conduct
- To comply with applicable laws and regulations.

Special marketing information: we use your data to inform you about relevant products and offers, for example, to provide you with targeted marketing. The data we collect in such cases contain the information that you voluntarily provide us with, the data we collect when you use our Services or from third parties with whom we work. We analyse this data to form an idea that, in our opinion, you may need or that may interest you. You can object to the use of your personal information by us for marketing purposes at any time, including any profiling for such purposes, and then we will stop using your personal information for such purposes.


We do not and will not share your information with third parties (unless you permit us to do so), except for:
- receiving the official request from law enforcement agencies;
- execution of a court decision;
- preventing fraud;
- protection of user rights.


We strongly encourage parents or guardians to instruct their children not to disclose any data on the Internet. If we receive factual information that we have collected data from the child, we will immediately delete it, unless we are required by law to store such data.


We use cookies and so-called pixel tags to collect information about visitors on our sites.
Pixel tags are invisible tags that are placed on specific pages of our websites, but, unlike cookies, they are not stored on your computer. 
A cookie is a small piece of data sent from a website to your web browser, and it can be stored on your computer’s hard drive. Cookies allow us to recognise your computer while you are on a website, and help tocustomise your browsing experience and make it more convenient. Cookies are also useful for allowing users to log in more efficiently, track transaction history and store information between sessions. Data gathered from cookies can also be used to improve the functionality of a website and to measure traffic patterns.
Example of improvement: if you visit our website, you will not be asked for your password every time you visit the site, but rather from time to time or when you manually delete your cookies.
There are two main types of cookies: session cookies and persistent cookies. Session cookies are deleted from your computer when you close your browser, while persistent cookies are saved on your computer until they are removed or until they expire. You have the right to choose whether you want to use cookies.
If you do not agree to use cookies, be sure to turn them off using your browser settings, or click the cancel button provided to you when you visit our website for the first time.

Extraneous cookie
Third parties may pass cookies through our website. This is done to:
- Serve advertisements on our site and track whether users have opened such publications;
- Control how often a particular advertisement is shown to you;
- Choose content according to your preferences;
- Keep counting the number of anonymous users of our site;
- Ensure the safety of the shopping basket or transactions.

Web beacons
Some of our web pages may contain electronic images called web beacons (sometimes “clear gifs”), which give us the opportunity to count the number of users who have visited these pages. Web beacons collect only limited information, including the cookie number, the time and date of the page view, the description of the page where the web beacon is located. We may also have web beacons hosted by third-party advertisers. Such tags do not carry any personal identification data and are used only to track the effectiveness of a particular advertising campaign.
Please note that most web browser applications (such as Microsoft Edge, Mozilla Firefox, and Google Chrome) have features that can notify you when they receive cookies or prevent them from being sent. However, if you disable cookies, you will not be able to use certain personalised features of our website.


We maintain physical, electronic, and procedural safeguards to help protect your data following applicable privacy policies. If transactions are offered in the Services, transaction information is transferred to and from the Service in encrypted form using industry-standard Transport Layer Security (TLS, formerly called SSL) connections to protect such information from interception. We strictly control the authorised access to your data and provide it only to those who have a legitimate purpose to gain access to it. We also have security measures to protect against the loss, misuse and alteration of the data we process. We recommend that you be careful when sharing data with other users when using our Services (for example, in forums or chats). We will NEVER ask youto send your password in text. Anyone who does this is probably trying to steal access to your data.


We may need to collect data to fulfil our legal obligations, fulfil the conditions of an agreement with you, or provide our Services to you. If you decide not to provide us with this data, this may prevent us from fulfilling our obligations. It may also mean that we cannot afford the services necessary to launch your Account. It may also say that we must refuse to provide our Services to you. You will be identified in the case when data collection is optional and can be skipped.


Rochalur operates in many countries around the world. The data we collect about you may be transferred and stored within and outside the European Economic Area. They can also be processed by employees who are outside the European Economic Area and work for us or any of our suppliers. By submitting your personal data, you agree to their transfer, storage and processing. We take all reasonable steps necessary to ensure the security of your data and compliance with the Privacy Policy and relevant laws. The laws of the countries to which we may transfer your data may not provide the same level of data protection as the laws of the state in which you presented this data. When we transfer your personal data to other countries, we protect this data as specified in this Policy and following applicable law. For personal data collected within the European Economic Area and transferred to countries that were not recognised by the European Commission as providing an appropriate level of data protection, we apply the EU Standard Data Protection Provisions to ensure the confidentiality of your personal data. More information about EU Standard Data Protection Applications can be found at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer- personal-data-third-countries_en.
Contact us using the contact details below if you have any questions regarding protective measures that we must use to ensure the security of your personal data when transferring it outside the European Economic Area (including obtaining a copy or advice on these protective measures ).
All information that you provide to us and that we collect about you is stored on secure servers. All payments that are made online are encrypted using SSL technology and will be processed by independent providers. We do not save and do not collect information on debit and credit cards that are used for online transactions.


We will keep your information for as long as you are a subscriber to the newsletter, a Client or a member of our business system (Partner). We can keep your information longer for research or statistical purposes, as well as to enable you to return and start at the level from which you ceased cooperation. If we do this, we will make sure your information is anonymous and not tracked. We will also keep it longer if we cannot remove it for legal or regulatory reasons.
However, we will delete all data that we no longer need after one year from the date of receipt. We will also remove the data at your request.


When you use our Services, we are committed to providing you with ways to quickly update or delete the data you have provided. You have the right to access data relating to you. This includes the right to receive information about whether data about you is being processed, what data about you is being processed, as well as about the purpose of processing. You also have the right, at your request, to gain access to information about any assessment we must conduct when processing your data based on our legitimate interests. Also, you have the right to correct or add data if personal information is inaccurate or incomplete. As soon as we become aware of any inaccuracies in the processed personal information, we will always correct your data without undue delay and notify you accordingly.


You also have the right to object to process your data for reasons related to your particular situation. However, please note that we must still process some personal information about you to provide you with the Services. This means that you cannot object to any use of personal information by us and continue to require us to provide you with the Services.
You can unsubscribe from the newsletter to which you previously subscribed, following the instructions in the letter you receive.


You have the right to request us to erase your data. We will delete your data upon request, provided that it is no longer needed to achieve a specific goal (for example, you cannot require all personal information about you to be deleted, but you still want to receive Services from us) or there is a legal obligation to store personal information.


You have the right to ask us to limit the processing of your personal information, but at the same time you still want us not to delete the data:
- if you dispute the accuracy of the data;
- if you believe that the treatment is illegal;
- if the data are no longer needed to fulfil the purposes for which they were collected;
- if you have informed us that you do not consider our interest as legitimate for certain processing.


You can access a copy of your data by contacting us at support@rochalur.com, if you request access to personal information about you that you provided, or if personal information is processed automatically, or under the agreement between you and Rochalur, or by your consent. You can request the data to be provided to you in a structured, widely used and machine-readable format, and you can also request the transfer of personal information to another holder if this is technically possible.


You can contact us at support@rochalur.com at any time to get a list of all the data we have collected from you, or to delete such data, or to exercise your other rights as described above. We will try to respond to your request on time, but please note that this may take several days.
Please note that if we cannot identify and guarantee who you are, we may ask you to provide us with additional information. Please note that we will not delete any data unless we can confirm that you are their legal owner. However, we will always make every effort to help you.


You can send us a request to support@rochalur.com at any time if you want to withdraw your consent or terminate cooperation. However, we will no longer be able to provide you with certain Services in the future if you do this.
You can unsubscribe from the newsletter at any time by following the instructions in the mailing list you receive. Our newsletters contain mechanisms that allow you to opt out of receiving further newsletters from us.


This Policy may change from time to time. Any changes to this policy will be posted on this page. If the changes are significant, we will send (at our discretion) a more prominent notice to you, for example, via e-mail or as a pop-up window in our services or on the page of your Account. If we ask you to accept significant changes in this Policy, but we receive a refusal, then you may not be able to continue to use our Services in part or in full.


Please let us know if you are unhappy with how we use and process your data by contacting our support department at support@rochalur.com.
We will also be happy to receive feedback from you if you believe that this Policy or any part of it is unclear.
Our legal address is: ROCHALUR, 5 Devova Street, Ljubljana, Slovenia
You always have the right to file a complaint with the relevant authority, in particular, where you live, work or where the alleged violation of the GDPR occurred.


Information on privacy rights for EU residents can be found at https://www.eugdpr.org/


Effective as on 01/23/2019


© Rochalur. All rights reserved.

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