Privacy

Effective Date: May 1, 2016

ROSCA Finance, Inc. and roscafinance.com, as well as any affiliated or related company (collectively, “ROSCA”, “we”, “us” or “our”), recognizes the importance of your privacy. This privacy policy tells you what personal information we collect and how we use it. ROSCA may change this privacy policy from time to time, in its sole discretion, and any such changes will become effective when we post the revised privacy policy online.

By using any ROSCA service, website, application, product, software, data, content, and/or service (collectively, the "Services"), you are declaring that you understand and agree to the terms of this policy.

1. What Information Do We Collect?

a. Personally-Identifiable Information: We may collect personally identifiable information when you specifically and knowingly provide it to us, for example when you access the Services and provide your name, address, email address and similar personal information; when you register and provide your bank and other financial information; when you create User Content (as defined in the ROSCA Terms of Service); or when you contact us with your name, address, or email address. ROSCA does not consider personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual. We collect and use personally-identifiable information to operate and improve our Services, to allow you to provide third parties or other Users access to your User Content, to provide customer service, to communicate with you when requested, and to perform research and analysis aimed at improving our products, services and technologies.

You may always choose not to provide personal information, but if you so choose, the Services will not be available to you. Note that personally identifiable information we collect and your User Content may be stored and processed in the United States or any other country in which we or our affiliates, subsidiaries, contractors or agents maintain facilities; by using the Services, you consent to any such transfer of information outside of your country.

b. Non-Personally-Identifiable Information: We may collect and aggregate non-personally identifiable information, such hardware types, geographic location, and access times and durations.

c. Website Use and Technologies: When you use the Services, ROSCA, or third parties on our behalf, may collect non-personally identifiable information via the use of pixels, programs, cookies and other similar technologies.

Cookies, for example, are pieces of information that are transferred to an individual's hard drive for record-keeping purposes. They are used to assist you in using site information and content by saving your user preferences which allows us to identify registered users and save you time by eliminating the need to repeatedly enter the same information. They are also used to collect aggregate information about users on an anonymous basis. In addition to cookies, we may use other technologies, including single-pixel gifs (also known as web beacons) on our websites and in promotional e-mail messages or newsletters. These electronic images assist us in determining how many users have visited certain pages or opened messages or newsletters. We do not use these single-pixel gifs to collect personal information. You have the ability to accept or decline cookies. Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies or to request your permission each time a service attempts to set a cookie. Please be aware that the site is optimally designed to operate with cookies enabled in your internet browser. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Services that depend on cookies.

2. What Do We Do With The Information That We Collect?

Except as disclosed in this privacy policy, ROSCA does not share your personal information with any outside parties.

a. ROSCA will use the personally identifiable information directly submitted by you and your User Content solely for the purpose for which you have provided it, such as processing transactions (including related communications); providing notices, updates, security alerts, and support; providing a third-party access to your User Content as provided for on the Services or as needed to complete any Services. We may share this as your agent and attorney-in-fact with the third-parties which you have selected to perform services on your behalf such as financial institutions, payment processors, other Users, or service providers who perform services on our behalf such as providing data storage, data transmission, etc. Service providers will be permitted to obtain only the personal information they need to provide the Services, will be required to maintain the confidentiality of the information, and will be prohibited from using it for any other purpose. Also, if we go through a corporate sale, merger, reorganization, dissolution or similar event, data we gather from you may be part of the assets transferred or shared in connection with due diligence for any such transaction. Any acquirer or successor company may continue to use the data we collect from you as described in this notice.

b. ROSCA, third-parties you authorize, or our third-party partners will use non-personally-identifiable information to track and analyze usage and volume statistical information from our users to administer content and to provide the Services. We may also perform statistical analysis of user behavior in order to measure interest in our online products and services for product development purposes.

c. Disclosure: As a general rule, ROSCA will not disclose any of your personally identifiable information or your User Content except under one of the following circumstances: we have your permission; we determine in good faith that it is legally required to be revealed by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena; information revealed during the course of ROSCA’s enforcement of the policies and procedures of the Services; information that we determine must be disclosed to correct what we believe to be false or misleading information or to address activities that we believe to be manipulative, deceptive or otherwise a violation of law; where you are otherwise notified at the time we collect the data; where we need to share your information to provide the product or service you have requested; when such disclosure is made subject to confidentiality restrictions in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by ROSCA. ROSCA may share the non-personally identifiable information that ROSCA gathers, in aggregate form only, with advertisers and other partners.

3. Children's Policy

The ROSCA Service Terms and Conditions clearly provide that Users must be at least 18 years old to use the Services. ROSCA does not knowingly collect personally identifiable information from Users under 18. In the event that we learn that we have collected any personal information from a User under the age of 13, we will attempt to identify and delete that information from our database.

4. Social Network Applications

The Services allow you to elect to access the data on your profile in social networks, and to interact through features on the social networks. This access is not activated automatically, but require express authorization by you. The Services allow you to authorize us to obtain information about you that is available on the social network (for instance name and surname), as well as to interact with our account. For further information on the use of Personal Information by social networks, you should review their respective privacy policies.

5. International Usage

The Services are owned by ROSCA and may be accessed in the United States and abroad. For data protection purposes, ROSCA is the controller. ROSCA or third-parties you authorize may be the processor of Your User Content. Your data may be sent to the United States and possibly other countries. We store data about and from Users on servers located in the United States, and we may also store this data on servers and equipment in other countries. Information collected may be retained, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction. If you are located outside of the United States, please note that the information you provide to us may be transferred to the United States. By using the Services, you consent to such transfer.

6. How Does A User Change Or Update Information?

If you have any questions or concerns about this privacy policy or would like the personally identifiable information that you have provided to be removed from our files, please contact ROSCA via email at support@roscafinance.com.

7. Security and Encryption

We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security. Our Service has security measures in place designed to protect against the loss, misuse and alteration of the information under our control. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All Services information is maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords.

All bank account information is securely processed directly with SynapseFi.com and are stored using application level Advanced Encryption Standard (AES) 128-bit encryption over secure HTTPS connections. None of our company’s internal servers are able to view or obtain plaintext card numbers.

8. Changes to This Policy

We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the “last updated” date at the top of the policy. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. We encourage you to review this policy whenever you visit one of our sites.

9. Choices about Data

To request deletion of, access to, or to make changes to data we’ve collected from you via the Services, email us at privacy@roscafinance.com. Please note that even if you request that we delete data we’ve collected from you, we may still retain data collected from you in an aggregated or anonymized form that does not identify you. We also will not delete your data if we are legally required to maintain it.