This Privacy Policy applies to www.purerocketfuel.com, the home website of Rocket Fuel Learning International Limited. This is primarily an information website.

If you are engaging with the specific online product MyStrategy, based at www.mystrategy.me , please refer to the specific Privacy Policy and Terms & Conditions on that site.

1 Introduction

The owner of this website (the “Site”) is Rocket Fuel Learning International Limited, Ground Floor, 71 Lower Baggot Street, Dublin 2, Ireland (variously referred to as “RFLI”, “we” or “us”).
We are committed to protecting the privacy, and the privacy of the personal data, of all who use our Site and our services (referred to as “you” or “your” as the context so requires). This policy explains how we do this and gives you details of our privacy practices, including a)
what information we collect about you and in what circumstances as you use this Site; b) how that information is used or disclosed; and c) your rights with respect to our collection, use and retention of your information.

2 Definitions and legal references

The following terms are used in this Privacy Policy. Wherever they appear they have the following meaning: –

“Cookie” refers to Trackers consisting of small sets of data stored in your web browser.

“Data Processor” or “Data Supervisor” refers to the natural or legal person, public authority, agency or other body which processes your Personal Data on our behalf as described in this privacy policy.

“European Union” or “EU” refers to all current member states of the European Union and the European Economic Area unless otherwise specified.

“Personal Data” refers to any information that directly, indirectly, or in connection with other information — including a personal identification number — allows you to be identified as a natural person.

“Service” refers to use of this Site for information purposes, potentially including your use of a Contact Form or your request for addition to a Mailing List.

“Usage Data” refers to information collected automatically through this Site (or third-party services employed in this Site), which can include: the IP addresses or domain names of the computers utilized by you when using this Site, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by you, the various time details per visit (e.g., the time spent on each page within the Site) and the details about the path followed within the Site with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment.

“Tracker” refers to any technology – e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables us to track you, for example by accessing or storing information on your device.

3 Types of Personal Data collected

The primary information collected will be any name and email address you provide for the purposes of contact, via Contact Form or joining a Mailing List.

The types of Personal Data that this Site may collect, by itself or through third parties, may include Cookies; Usage Data; geographic position, email address, first name or name by which you will be known to the Site, gender, date of birth, Personal Data communicated while using the Service and password.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the collection of the Personal Data.

Personal Data may be freely provided by you, or, in case of Usage Data, collected automatically when using this website.

Unless specified otherwise, failure to provide mandatory Personal Data may make it impossible for this Site to provide the requested Services. In cases where this Site specifically states that certain Personal Data is not mandatory, you are free not to communicate this Personal Data without consequences to the availability or the functioning of the Service.

If you are uncertain about which Personal Data is mandatory you are welcome to contact us. Any use of Cookies – or of other tracking tools – by this Site or by the owners of third-party services used by this Site serves the purpose of providing the Service requested by you, in addition to any other purposes described in this Privacy Policy and in the Cookie Policy, if available.

4 Mode and Place of processing the Data

4.1 Methods of processing

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of your Personal Data. Personal Data is processed using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to us, in some cases, the Personal Data may be accessible to certain types of persons in charge, involved with the operation of this Site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, by us. You may request an updated list of these parties from us at any time.

4.2 Legal basis of processing

We may process Personal Data relating to you if one of the following applies:

● You have given your consent for one or more specific purposes. Note: Under certain legislations we may be allowed to process Personal Data until you object to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

● provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;

● processing is necessary for compliance with a legal obligation to which we are subject;

● processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;

● processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

4.3 Place

The Personal Data is processed at our operating offices and in any other places where the parties involved in the processing are located. Depending on your location, data transfers may involve transferring your Personal Data to a country other than your own. To find out more about the place of processing of such transferred Personal Data, you can check the section containing details about the processing of Personal Data. All Personal Data will be held on servers within the European Union. We will not transfer your Personal Data from within the European Union to outside of the European Union, save for the situation in which you are resident outside the European Union and you access the Services from outside the European Union in which case your Personal Data will be transferred to and from the European Union. If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with us using the information provided in the contact section.

4.4 Retention of your Personal Data

We process and retain your Personal Data only for as long as required by the purpose for which they have been collected. Therefore:

● Personal Data collected for purposes related to the performance of a contract between us and you shall be retained until such contract has been fully performed.

● Personal Data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfil such purposes. You may find specific information regarding the legitimate interests pursued by us within the relevant sections of this document or by contacting us. We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, we will delete your Personal Data. Therefore, your rights in respect of access to, erasure of, rectification of and portability of your Personal Data cannot be enforced after expiration of the retention period.

5 The Purposes of Processing

We collect your Personal Data to allow us provide our Service, comply with our legal obligations, respond to enforcement requests, protect our rights and interests (or the rights and interests of you or third parties), detect any malicious or fraudulent activity, as well as the following: analytics, tag management, infrastructure monitoring, displaying content from external platforms, hosting and backend infrastructure, location-based interactions, managing contacts and sending messages, remarketing and behavioural targeting, contacting you, heat mapping, user database management, interaction with support and feedback platforms, managing support and contact requests, registration and authentication provided directly by this Site and SPAM protection.

For specific information about the Personal Data used for each purpose, refer to the next section, “Detailed information on the processing of Personal Data.”

6 Detailed Information on the Processing of Personal Data

Your Personal Data may be collected for one or more of the following purposes and using the following services:

6.1 Analytics

The services contained in this section enable us to monitor and analyse web traffic and can be used to keep track of the behaviour of visitors to the Site.

Service Provider	Google Inc.
Service Provided	Google Analytics
Service Description	Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Personal Data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google services. Google may use the Personal Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed	Cookies; Usage Data
Place of processing	United States of America
Service Provider privacy policy	https://www.google.com/intl/en/policies/privacy
Opt-out provisions	https://tools.google.com/dlpage/gaoptout?hl=en

 

6.2 Contacting You

Service Provider	RFLI
Service Provided	Contact Form
Service Description	By filling in the contact form on this Site with your Personal Data, you authorize this Site to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header
Personal Data processed	email address; first name; last name
Place of processing	EU
Service Provider privacy policy	This document

 

6.3 Hosting and backend infrastructure

This type of service has the purpose of hosting data and files that enable this Site to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Site. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data is stored.

Service Provider	Blacknight Solutions
Service Provided	Hosting and backend services
Service Description	Hosting and backend services
Personal Data processed	Several types of Personal Data as specified in the privacy policy of the service provider
Place of processing	See the Blacknight privacy policy
Service Provider privacy policy	https://www.blacknight.com/legal/website-privacy-policy

6.4 Managing contacts and sending messages

This type of services makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with you. These services may also collect data concerning the date and time you viewed the message, as well as when you interacted with it, such as by clicking on links included in the message.

Service Provider	Intuit Inc.
Service Provided	Mailchimp
Service Description	Mailchimp is an email address management and message-sending application
Personal Data processed	Email address, Usage data
Place of processing	EU
Service Provider privacy policy	https://mailchimp.com/legal/privacy

6.5 Managing support and contact requests

This type of service allows this Site to manage support and contact requests received via email or by other means, such as the contact form. The Personal Data processed depends on the information provided by you in the messages and the means used for communication (e.g. email address).

7 Your rights in respect of your Personal Data

You have certain rights regarding your Personal Data as processed by us which you may exercise at any time while we hold your Personal Data. In particular, you have the right to do the following:

● Withdraw your consent at any time: You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data.

● Object to processing of your Personal Data: You have the right to object to the processing of your Personal Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

● Access your Personal Data: You have the right to learn if we are processing your Personal Data, obtain disclosure regarding certain aspects of that processing and obtain a copy of the Personal Data being processed.

● Verify and rectification: You have the right to verify the accuracy of your Personal Data and ask us to update or correct it.

● Restrict the processing of your Personal Data: you have the right, under certain circumstances, to restrict the processing of your Personal Data. In this case, we will not process your Personal Data for any purpose other than storing it.

● Have your Personal Data deleted or otherwise removed: You have the right, under certain circumstances, to obtain the erasure of your Personal Data from us.

● Receive your Personal Data and have it transferred to someone else. You have the right to receive your Personal Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to someone else without any hindrance. This provision is applicable provided that your Personal Data is being processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

● Lodge a complaint: You have the right to bring a claim before your competent data protection authority.

7.1 Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing grounds related to your particular situation to justify your objection. You must know that, however, should your Personal Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Personal Data for direct marketing purposes, you may refer to the relevant sections of this document.

7.2 How to exercise your rights with respect to your Personal Data

Any requests to exercise your rights can be sent to us through the contact details provided at the end of this Privacy Policy. These requests can be made free of charge and will be addressed by us as early as possible and always within one month.

8 Cookie Policy

Please refer to our Cookie Policy

9 Additional information about Data collection and processing

9.1 Legal action

Your Personal Data may be used for legal purposes by us in court or in the stages leading to possible legal action arising from improper use of this Site or the Services.

You declare that you are aware that we may be required to reveal your Personal Data upon request of public authorities.

9.2 Additional information about your Personal Data

In addition to the information contained in this privacy policy, this Site may provide you with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

9.3 System logs and maintenance

For operation and maintenance purposes, this Site and any third-party services used by or accessed via this Site may collect files that record interaction with this Site (System logs) or use other Personal Data (such as your IP Address) for this purpose.

9.4 Information not contained in this policy

You may request further details concerning the collection or processing of your Personal Data from us at any time. Please see the contact information at the end of this Privacy Policy.

9.5 How this Site handles “Do Not Track” requests

This Site does not support “Do Not Track” requests. However you may disallow cookies on the site and they will not be tracked by Google Analytics as set out at 6.1 above. To determine whether any of the third-party services used by this Site honour “Do Not Track” requests, please refer to their respective privacy policies.

10 Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time by notifying you on this page and possibly within this Site. We strongly recommend that you check this page often, referring to the date of the most recent modification listed at the bottom.

Should the changes affect processing activities performed on the basis of your consent, we will collect new consent from you, where required.

This Privacy Policy relates solely to this Site, www.purerocketfuel.com, if not stated otherwise within this document. If engaging with MyStrategy product via www.mystrategyme, please read the specific Privacy Policy, Terms & Conditions and Cookie Policy on that site.

11 Legal information

This Privacy Policy is subject to the laws of Ireland and has been prepared based on the Data Protection Act 1988 as amended by the Data Protection Act 2018 and in accordance with Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

12 Contacting us

You may contact us in relation to this Privacy Policy or any matter relating to your Personal Data by writing to us at our office address and marking the envelope “Privacy Policy” or by emailing us at info@purerocketfuel.com and including the text “Privacy Policy” in the subject line of your email