Privacy Policy

Welcome to ROMBI's Privacy Policy!

Please note that this Privacy Policy applies to personal data that is collected and processed by White and Blue Consulting Pvt. Ltd., having its registered A 1203, Swarna CHS, Unique Garden, Kanakia, Mira Road East 401107, THANE, INDIA ("ROMBI", "we", "our" or "us").

ROMBI, as a data controller, collects and processes personal data relating to interactions on the Website (as defined in Section 1 of the Terms of Use). This Privacy Policy describes how ROMBI uses and protects any information that you give us.

We believe in full transparency, which is why we keep our Privacy Policy simple and easy to understand.

We strongly urge you to read this Privacy Policy and make sure that you fully understand and agree with it. If you do not agree to this Privacy Policy, please do not access or otherwise use the Website.

Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Definitions section of the Terms of Use.

1. DEFINITIONS

When we say "you", "your" or "Data Subject" we mean any natural person that shares personal data with us via Website.

When we say "processing" we mean any operation or set of operations which is performed on personal data or sets of personal data. This includes activities such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

When we say "personal data" or "data" we mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, either directly or indirectly. Therefore, data about a company or any legal entity is not considered to be personal data but registering on behalf of a legal entity may include sharing personal data. For example, the information in relation to one-person companies may constitute personal data where it allows the identification of a natural person. The rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company or organization, business e-mail addresses like "[email protected]". This Privacy Policy does not apply to information from which no individual can reasonably be identified (anonymized information).

When we say "Data Processors" or "processor" we mean any natural or legal person who processes the data on behalf of the Data Controller. In some cases, ROMBI is a Data Processor and in others, Data Controller (as further explained in Section 2). In addition, we may use the services of various service providers to process your data more effectively. In such cases, they are either our processors or sub-processors.

When we say "cookies" we mean small pieces of data stored on your device (computer or mobile device). This information is used to track your use of the Website and to compile reports on website activity. For further information about the use of cookies and how you can manage them, please read our Cookie Policy.

When we say "consent" we mean your explicit consent on the processing of personal data. Persons who are 15 years of age or older may give free consent to the processing of their personal data. However, the User of ROMBI has to be of age of majority as defined in Terms of Use.

2. DATA CONTROLLER OR DATA PROCESSOR

In relation to your personal data processed on or via the Website and the Service, ROMBI may be either a Data Controller or Data Processor.

When ROMBI acts in the capacity of a Data Controller, ROMBI determines the purposes and the essential means of the processing of personal data. The purpose of data processing is the reason why we process your personal data. The table in Section 4.1 of the Privacy Policy presents the purposes and legal basis for data processing. In such cases, ROMBI is responsible for your personal data.

Apart from Section 4.2, this Privacy Policy primarily contains information on processing your data in the capacity of a Data Controller. Should you have any inquiries, or you wish to exercise any of the rights of a Data Subject stipulated in Section 10, please contact us:

By using the Service, you may disclose, share, record, or otherwise use various types of data via a login as the User Content. The type of User Content is determined by the person that owns the login and not by us. The extent to which personal data is processed while using the Service also depends on the Rombi functionalities that the owner of the login decides to use. Thus, ROMBI does not analyze, disclose or access such data unless a User (including an Enterprise as a User) sends a request for support and, in these cases, the access is limited to enabling the functioning of the Service.

Given that ROMBI strongly supports the principle of transparency of personal data processing, despite being a Data Processor, ROMBI made an additional effort to explain personal data processing via the Service in Section 4.2 of this Privacy Policy. The information contained therein outlines how personal data processing via Rombi functions in general. Nevertheless, should you wish to send an inquiry or exercise any of your Data Subject's rights which you may have under the applicable data protection legislation to the owner of the Workspace, please contact such owner of the relevant login as Data Controller.

Please also note that we do not collect or process your personal data if you are an End User of Server Rombi. In that case, Client (the company that has Rombi installed on their server) is responsible for your personal data.

If you represent a User that falls under the scope of application of the GDPR or similar data protection legislation, you may sign the Data Protection Addendum to these Terms of Use ("DPA"), with ROMBI as a Data Processor based outside the EEA. The DPA includes the Standard Contractual Clauses adopted by the European Commission, as applicable, and reflects the Parties' agreement with respect to the terms governing the processing of personal data under the ROMBI'S Terms of Use. Signing the DPA will be considered as an amendment to the Agreement (within the meaning of Section 1 of the Terms of Use) and will be considered to form a part of the Agreement.

If would like to sign a DPA with us, please contact us at [email protected] for more information.

3. WHAT DATA DO WE COLLECT ABOUT YOU AND WHEN?

We may collect and receive information about you in various ways:

• (i) Information you provide through the use of the Service (for example, by creating the account on Cloud Rombi).
• (ii) Information you decide to provide through getting in touch with us via [email protected].
• (iii) Information we collect through the use of cookies or similar technologies in accordance with our Cookie Policy (for example, your time zone).

4. PERSONAL DATA WE PROCESS

4.1 ROMBI AS DATA CONTROLLER

4.2 ROMBI AS DATA PROCESSOR

As previously stated, concerning your personal data processed on or via the Service, ROMBI is a Data Processor and the Owner of the Workspace is the Data Controller. ROMBI processes personal data following instructions from the Data Controller and under the Terms of Use and DPA (if any). The purpose of such personal data processing is productivity management during work hours of the team where the Owner of the Workspace may get an accurate report of the workweek, improve project profitability, compile reports for the clients, track attendance of employees and/or other team members and track their work.

As a processor, ROMBI is permitted to collect, use, disclose and/or otherwise process your personal data only following the instructions of the Owner of the Workspace.

Processing prior to using the Service

• The Owner of the Workspace shares your email address to enable you to access the Service.
• The Owner of the Workspace may assign you tasks and projects.
• If you have any questions regarding the legal basis for such personal data processing, please contact the Owner of the Workspace who invited you to the Service.

Processing during the usage of the Service

If you decide to accept the invitation to use the Service, you will be required to create an account. To create the User Account, you will need to share your email address and password.

You manage personal data you share via your account such as name and surname, photo, email data (personal email address and/or work email address).

In the course of the use of the Service we may process system usage data, IP address, work position, attendance at work, time-tracking data you inserted (for example, the time you started work, the time you finished work, tasks or projects worked on), application integration data, navigational data (including website usage information such as interactions with ROMBI, and other electronic data submitted, stored, sent, or received by the Data Controller via the Service.

If you choose to connect your ROMBI account to Google Calendar or Outlook (Office 365), you will be able to track time for events right from such calendars. This function enables a User to have the events from the calendar within the ROMBI calendar and create time entries for each event. Once the calendar is connected, you will see all events from Google Calendar or Outlook right inside ROMBI. If you make changes in the external calendar, those changes will reflect in ROMBI.

To provide this Service, we need to access your Google or Outlook calendar and collect the data from such calendars. The data we collect include name of the event, description of the event, start and end time, link and calendar name. We ask Users for such authorization explicitly prior to processing such data.

Personal data from your connected calendar are only displayed in ROMBI, while data from ROMBI will not be displayed or shared in Google Calendar or Outlook.

While Admins and Team Managers can view other Users' ROMBI calendar, only the User can see events from the connected Google or Outlook calendar (Admins and Managers cannot see events from your connected calendar).

The User may disconnect the calendar at any time by clicking on the Disconnect option on their ROMBI calendar.

ROMBI does not undertake analysis of any special categories of personal data (including racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sex life or sexual orientation) and ROMBI functionalities are not meant to be used for the processing of any such personal data. However, if you decide to provide such personal data to us or Data Controller via the Service, you will be deemed to have consented to such processing of the data.

5. WHAT WE DO NOT DO?

ROMBI will never:

• — Sell any kind of personal information or data
• — Disclose this information to marketers or third parties not specified in Section 7
• — Process your data in any way other than stated in this Privacy Policy.

6. PERSONAL DATA SECURITY

We take administrative, technical, organizational and other measures to ensure the appropriate level of security of personal data we process. Upon assessing whether a measure is adequate and which level of security is appropriate, we consider the nature of the personal data we are processing and the nature of the processing operations we perform, the risks to which you are exposed by our processing activities, the costs of the implementation of security measures and other relevant matters in the particular circumstances.

Some of the measures we apply include access authorization control, information classification (and handling thereof), protection of integrity and confidentiality, data backup, firewalls, data encryption and other appropriate measures. We equip our staff with the appropriate knowledge and understanding of the importance and confidentiality of your personal data security.

7. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

ROMBI utilizes external processors for certain processing activities. We use information audits to identify, categorize and record all personal data that is processed outside the company, so that the information, processing activity, processor and legal basis are all recorded, reviewed and easily accessible.

We have strict due diligence procedures and measures in place and review, assess and background check all processors prior to forming a business relationship. We obtain company documents, certifications, references and ensure that the processor is adequate, appropriate and effective for the task we are employing them for.

We audit their processes and activities prior to contract and during the contract period to ensure compliance with the data protection regulations and review any codes of conduct that oblige them to confirm compliance.

This is the list of processors and sub-processors with whom we share your personal data:

We may also share your personal data with our outside accountants, legal counsels and auditors.

Please keep in mind that, subject to your instructions to us while using the Service, your data may be shared with third parties in the following situations:

• — If you join another User's Workspace;
• — If you invite another User to join you Workspace;
• — If you invite a non-user to join ROMBI;
• — If you decide to share User Content from your Workspace to persons who do not have an account on ROMBI by providing links to such User Content.

8. INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

We may transfer your personal data to countries other than the one you reside in. Given that we follow internal rules for the protection of personal data that are stricter than the applicable law (see Section 22 of the Terms of Use), in these cases, we transfer your personal data only:

• 1. To the countries within the EEA;
• 2. To the countries which ensure an adequate level of protection;
• 3. To the countries which do not belong to those specified under item 1. and 2, but only by applying the appropriate safeguard measures.

9. HOW LONG DO WE KEEP YOUR DATA?

The period for which we store your personal data depends on a particular purpose for the processing of personal data, as explained in detail in Section 4. We retain personal data for as long as we reasonably require it for legal or business purposes. In determining data retention periods, we take into consideration the applicable law (see Section 22 of the Terms of Use), contractual obligations, and the expectations and requirements of our Users. When we no longer need personal information, or when you request us to delete your information, where this is legal, we will securely delete or destroy it.

However, as an exception to the retention periods in Section 4 the data may be processed to determine, pursue or defend claims and counterclaims.

10. YOUR RIGHTS

Given that transparency is one of our cornerstone principles, we grant Data Subjects certain rights in relation to their personal data. These rights may be exercised by Data Subject when ROMBI operates as a Data Controller.

If your inquiry or exercise of any of the Data Subject's rights relates to the data on a Workspace processed as explained in Section 4.2 of the Privacy Policy, please contact the owner of the relevant Workspace via which your personal data has been processed.

In the event ROMBI receives a request for exercising any of these rights directly from a Data Subject, we are obliged to notify the owner of the relevant Workspace before responding to such a request.

RIGHT OF ACCESS

You can send us a request for a copy of the personal data we hold about you.

We have ensured that appropriate measures have been taken to provide such in a concise, transparent, intelligible and easily accessible form, using clear and plain language. Such information is provided in writing free of charge. It may be provided by other means when authorized by the Data Subject and with prior verification as to the subject's identity.

Information is provided to the Data Subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months where necessary.

RIGHT TO CORRECTION OF YOUR PERSONAL DATA

If the personal data we have about you is incorrect, you have the right to request that we correct those data. Where notified of inaccurate data by the Data Subject, we will rectify the error within 30 days and inform any third party of the rectification if we have disclosed the personal data in question to them.

RIGHT TO ERASURE

You have the right to request from us that your personal data is deleted in certain circumstances including:

• — The personal data are no longer needed for the purpose for which they were collected;
• — You withdraw your consent (where the processing was based on consent);
• — You object to the processing and no overriding legitimate grounds are justifying us processing the personal data;
• — The personal data have been unlawfully processed; or
• — To comply with a legal obligation.

However, this right does not apply where, for example, the processing is necessary:

• — To comply with a legal obligation; or
• — For the establishment, exercise or defense of legal claims.

RIGHT TO RESTRICTION OF PROCESSING

If the accuracy of the personal data is contested, you consider the processing is unlawful but you do not want it erased, we no longer need the personal data but you require it for the establishment, exercise or defense of legal claims or you have objected to the processing and verification, you can exercise your right to the restriction of processing.

RIGHT TO DATA PORTABILITY

Where you have provided personal data to us, you have the right to receive such personal data back in a structured, commonly used and machine-readable format, and to have those data transmitted to a third-party Data Controller without hindrance but in each case only where:

• — The processing is carried out by automated means; and
• — The processing is based on your consent or the performance of a contract with you.

RIGHT TO WITHDRAW THE CONSENT

If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.

RIGHT TO LODGE A COMPLAINT

If you have any concerns or requests in relation to your personal data, please contact us at [email protected] and we will respond as soon as possible but not later than within 30 days.

11. CALIFORNIA RESIDENTS PRIVACY NOTICE

This Section supplements the information contained in the ROMBI's Privacy Policy and applies solely to visitors, users, and others who reside in the State of California and fall under the scope of the California Consumer Privacy Act ("consumers" or "you") when they visit the Website or use the Services. Under this Notice ROMBI complies with the California Consumer Privacy Act of 2018 ("CCPA").

Any capitalized but undefined term in this Notice shall have the meaning given to it in the CCPA, Definitions section of the Terms of Use, Privacy Policy and Cookie Policy.

This Notice makes an integral part of our Privacy Policy and Terms of Use.

INFORMATION WE COLLECT

For more details about the personal information ROMBI has collected over the last 12 months please see Section 4 of the Privacy Policy - Personal Data We Process.

The categories of personal information that are listed in Section 4 are obtained by ROMBI in accordance with Section 3 of the Privacy Policy - What Data Do We Collect About You And When?

USE OF PERSONAL INFORMATION

ROMBI collects personal information for the purposes described in Section 4.1 of the Privacy Policy - ROMBI as Data Controller.

SHARING PERSONAL INFORMATION

ROMBI shares personal information with the categories of third parties described in Section 7 of the Privacy Policy - With whom do we share your personal data?

Please note that ROMBI uses third-party cookies for advertising purposes as further described in our Cookie Policy.

ROMBI DOES NOT SELL YOUR PERSONAL INFORMATION

ROMBI does not sell personal information, including personal information of anyone under 18 years of age.

YOUR RIGHTS AND CHOICES

This section describes your rights under the CCPA and explains how to exercise those rights. These rights may be exercised by consumers when ROMBI operates as a Data Controller.

If your inquiry or exercise of any of the consumer's rights relates to the data on a Workspace processed as explained in Section 4.2 of the Privacy Policy, please contact the owner of the relevant Workspace via which your personal data has been processed.

In the event ROMBI receives a request for exercising any of these rights directly from a consumer, we are obliged to notify the owner of the relevant Workspace before responding to such a request.

RIGHT TO KNOW PERSONAL INFORMATION AND DATA PORTABILITY RIGHTS

You have the right to request that we disclose certain information to you about ROMBI's collection and use of your personal information over the past 12 months, i.e.:

• — Our business or commercial purpose for collecting your personal information.
• — The categories of personal information we collected about you.
• — The categories of third parties with whom we share your personal information.
• — The specific pieces of personal information we collected about you ("data portability request").

We will disclose this information to you once we receive and confirm your verifiable consumer request.

RIGHT TO DELETION

You have the right to deletion your personal information ROMBI collected. ROMBI will delete your personal information from the records once we receive and confirm your verifiable consumer request unless a CCPA exception applies.

Namely, we may deny your deletion request subject to the exceptions in CCPA §1798.105, i.e. if retaining the information is necessary for ROMBI or our service providers to:

• 1. Complete the transaction for which ROMBI collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of ROMBI's ongoing business relationship with you, or otherwise perform our contract with you.
• 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• 3. Debug products to identify and repair errors that impair existing intended functionality.
• 4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• 6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• 7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• 8. Comply with a legal obligation.
• 9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If your request is justified, ROMBI will also direct their service providers to delete your personal information as well.

RIGHT TO NON-DISCRIMINATION

ROMBI will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, ROMBI will not:

• — Deny you use of our Services.
• — Provide you a different level or quality of Services.
• — Charge you different prices or rates for Services, including through the use of discounts or other benefits or by imposing penalties.
• — Suggest that the person exercising their rights will receive a different price or rate for Services or a different level or quality of Services.

RIGHT TO SAY NO TO THE SALE OF YOUR PERSONAL INFORMATION (RIGHT TO OPT-OUT)

The CCPA requires businesses that sell personal information to allow consumers the ability to opt-out of the selling of their personal information.

Again, ROMBI does not sell personal information.

EXERCISING YOUR RIGHTS

To exercise the rights to access, data portability, and deletion, please submit a verifiable consumer request at [email protected] or contact us via our Contact page.

Consumers are entitled to make a request for access or data portability twice within a 12-month period.

To exercise your rights, you may send a request by yourself or use an authorized agent.

If ROMBI cannot verify your identity or authority to make the request and confirm the personal information relates to you, ROMBI cannot respond to your request or provide you with personal information.

We try to respond to consumers' requests within 45 days of their receipt. Sometimes, ROMBI may need more time to respond to the request (up to 90 days total from the moment we receive the request) when ROMBI will inform the consumer of the reason and extension period in writing.

You are not obliged to create an account with us in order to make a verifiable consumer request. We will deliver our written response to the registered email associated with the account if you have an account with us. Please note that any information we provide will only cover the 12-month period preceding the consumer's request receipt. If we cannot comply with your request, we will provide an explanation.

If a consumer files a data portability request, ROMBI will select a format that is readily usable and should allow the transmission of the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If ROMBI determines that the request warrants a fee, ROMBI will:

• — inform you why the decision was made and
• — provide the consumer with a cost estimate before completing the request.

12. CHANGES TO PRIVACY POLICY

We reserve the right to change Privacy Policy from time to time at our sole discretion. If we make any changes, we will publish the new rules on this web page and, if we have your email, we will notify you directly.

Where you have previously consented to our Privacy Policy, your continued use of the Website after we make changes is deemed to be acceptance of the updated rules.

Last updated on 12/01/2022