Privacy Policy

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

● When you provide such information directly to us.
● When you create an account or use our interactive tools and Services.
● When you voluntarily provide information in free-form text boxes through the Services or through responses
to surveys or questionnaires.
● When you send us an email or otherwise contact us.
● When you use the Services and such information is collected automatically.
● Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
● If you use a location-enabled browser, we may receive information about your location.
● If you download and install certain applications and software we make available, we may receive and collect
information transmitted from your computing device for the purpose of providing you the relevant Services,
such as information regarding when you are logged on and available to receive updates or alert notices.
● If you download and install certain applications and software we make available, we may receive and collect
information transmitted from your computing device for the purpose of providing you the relevant Services,
such as information regarding when you are logged on and available to receive updates or alert notices.

Public Records

● From public social media posts or other sources.

Third Parties

Vendors

● We may use analytics providers to analyze how you interact and engage with the Services, or third parties
may help us provide you with customer support.
● We may use vendors to obtain information to generate leads and create user profiles.
● Social Networks
● If you provide your social network account credentials to us or otherwise sign in to the Services through a
third-party site or service (e.g., Google or Otka), some content and/or information in those accounts may be
transmitted into your account with us.
● If you provide your social network account credentials to us or otherwise sign in to the Services through a
third-party site or service, some content and/or information in those accounts may be transmitted into your
account with us.

Our Commercial or Business Purposes for Collecting, Using and Processing Personal Data

We will only process your Personal Data if we have a lawful basis for doing so, including the following:

Providing, Customizing and Improving the Services

● Creating and managing your account or other user profiles.
● Processing orders or other transactions; billing.
● Providing you with the products, services or information you request.
● Meeting or fulfilling the reason you provided the information to us.
● Providing support and assistance for the Services.
● Improving the Services, including testing, research, internal analytics and product development.
● Personalizing the Services, website content and communications based on your preferences.
● Doing fraud protection, security and debugging.
● Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in
applicable data privacy laws.

Corresponding with You

● Responding to correspondence that we receive from you, contacting you when necessary or requested, and
sending you information about Root or the Services.
● Sending emails and other communications according to your preferences or that display content that we
think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

● Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as
preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
● Protecting the rights, property or safety of you, Root or another party.
● Enforcing any agreements with you.
● Responding to claims that any posting or other content violates third-party rights.
● Resolving disputes.
● We will not collect additional categories of Personal Data or use the Personal Data we collected for
materially different, unrelated or incompatible purposes without providing you notice.

Contractual Necessity

● Enabling us to provide you (and/or the accountholder) with the Services. When we process data due to
contractual necessity, failure to provide such Personal Data will result in your inability to use some or all
portions of the Services that require such data. The types of data that we may process due to contractual
necessity include, as applicable, Profile or Contact Data, Payment Data, Device/IP Data, and Geolocation
Data.

Legitimate Interest

● Furthering the legitimate interest of us or third parties, which includes, as applicable, Profile or Contact Data,
Payment Data, Device/IP Data, Commercial Data, Web Analytics, Social Network Data, Consumer
Demographic Data, Professional or Employment-Related Data, and Geolocation Data.
● De-identifying or anonymizing Personal Data to further our legitimate interests.
● Examples of these legitimate interests include (as described in more detail above):
   ● Providing, customizing and improving the Services.
   ● Marketing the Services.
   ● Corresponding with you.
   ● Meeting legal requirements and enforcing legal terms.
   ● Completing corporate transactions.

Consent

● Process Personal Data based on the consent you expressly grant to us at the time we collect such data,
which will be expressly indicated to you at the point and time of collection.

Other Processing Grounds

● Complying with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects,
or if it is necessary for a task carried out in the public interest. 

How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section.
Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your
Personal Data.

Service Providers.

These parties help us provide the Services or perform business functions on our behalf. They include

● Hosting, data storage and warehouse, technology and communication providers.
● Security and fraud prevention consultants.
● Support and customer service vendors.
● Product fulfillment and delivery providers.
● Payment processors.

Analytics Partners.

These parties provide analytics on web traffic or usage of the Services. They include:

● Companies that track how users found or were referred to the Services.
● Companies that track how users use and interact with the Services.

Business Partners

These parties have business relationships with us and work with our customers and users. They include:

● Job sites that work with us to screen and hire employees and consultants.
● Commercial partners who provide complimentary products and services.
Parties You Authorize, Access or Authenticate
● Third parties you access through the services.
● Social media services.
● Other users.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition,
bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should
one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to
different privacy and security policies and practices.

Data that is Not Personal Data 

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by
removing information that makes the data personally identifiable to a particular user. We may use such aggregated,
de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze,
build and improve the Services and promote our business, provided that we will not share such data in a manner that
could identify you.

Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript
(collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use
our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small
pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device
to access our Services. We may also supplement the information we collect from you with information received from
third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of
our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

Cookies

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have
requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these
Cookies may make certain features and services unavailable.

Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services,
maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to
personalize our content for you, greet you by name and remember your preferences (for example, your choice of
language or region).

Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our
Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view
on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help
us measure the performance of our advertising campaigns in order to help us improve our campaigns and the
Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in
connection with its Google Analytics services. Google’s ability to use and share information collected by Google
Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy
Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at
www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at

https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an
option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as
(depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in
a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may
have to manually adjust some preferences every time you visit our website and some of the Services and
functionalities may not work. 

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s
menu. To find out more information about Cookies, including information about how to manage and delete Cookies,
please visit http://www.allaboutcookies.org or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the
European Union.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical,
technical, organizational and administrative security measures based on the type of Personal Data and how we are
processing that data. You should also help protect your data by appropriately selecting and protecting your password
and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you
have finished accessing your account. Although we work to protect the security of your account and other data that
we hold in our records, please be aware that no method of transmitting data over the internet or storing data is
completely secure. 

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to
provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply
with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable
law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information
would not identify you personally. 

Personal Data of Children

We do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the
age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we
learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly
as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact
us at legal@root.io.

Data Subject Rights

If you are subject to the GDPR, you have certain rights with respect to your Personal Data, including those set forth
below. For more information about these rights, or to submit a request, please email us at legal@root.io. Please note
that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or
extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances,
we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with
additional information, which may include Personal Data, if necessary to verify your identity and the nature of your
request. 

Access: You can request more information about the Personal Data we hold about you and request a copy of such
Personal Data. You can also access certain of your Personal Data by logging on to your account.

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can
request that we correct or supplement such data. You can also correct some of this information directly by logging on
to your account.

Erasure: You can request that we erase some or all of your Personal Data from our systems.

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of
collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you
exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure
of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our
Services. 

Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we
transmit the data to another controller where technically feasible.

Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

Right to File Complaint: You have the right to lodge a complaint about Root’s practices with respect to your Personal
Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available
here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Root and its service providers, and if you
do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you
acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party,
is being provided to Root in the U.S. and will be hosted on U.S. servers, and you authorize Root to transfer, store and
process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your
data to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses
promulgated by the European Commission, a copy of which can be obtained

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32010D0087

In certain situations, we may be required to disclose Personal Data in response to lawful requests by public
authorities, including to meet national security or law enforcement requirements.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but
we will alert you to any such changes by placing a notice on the Root.io website, by sending you an email and/or by
some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t
provided us with your email address), those legal notices will still govern your use of the Services, and you are still
responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have
been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy
Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal
Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

https://root.io, https://app.root.io

legal@root.io
Root.io Inc., Attention Legal, 100 Summer Street, Ste 1600, Boston, MA 02110