Privacy policy

This privacy policy (hereinafter referred to as the “Privacy Policy”) governs how Sources Rosport SARL, a Luxembourg company with its registered office at 28, Route d’Echternach, L-6580 Rosport, GRAND DUCHY OF LUXEMBOURG, registered with the Luxembourg Trade and Companies Register under number B 174 293, collects, uses, retains, and discloses information gathered from customers or users (hereinafter referred to individually as a “User” or collectively as “Users”) of its websites, social networks, mobile applications, or other services (hereinafter referred to as the “Services”).

Compliance with Data Protection Laws

Sources Rosport acknowledges and commits to complying with laws and regulations governing the processing of personal data, including but not limited to Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 concerning the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “GDPR”), as well as any other applicable national laws or regulations governing the processing of personal data.

Data Protection Officer

Sources Rosport acts as a data controller and has appointed a Data Protection Officer (DPO). The Data Protection Officer appointed by Sources Rosport can be contacted using the following information: Address: Sources Rosport SARL, Attn: Data Protection Officer 19, Rue Edmond Reuter L-5326 Contern Email: contact@rosport.com

Personal Identification Data

Sources Rosport may collect personal identification data from Users in various ways, including but not limited to, when Users visit the website rosport.com, or associated platforms such as optimytool.com or seedtrace.org, as well as their social networks, register there, fill out a form, sign a contract, purchase a product, participate in a contest, or engage in other activities, applications, or services offered by Sources Rosport. Depending on the needs, Users may be asked for their name, date of birth, email address, mailing address, and phone number.

Non-Personal Identification Data

Sources Rosport may collect non-personal identification data about Users each time they interact with its websites, applications, social networks, or other online services. Non-personal identification data may include technical information about Users’ connection methods, such as the operating system and Internet service provider used by the User, geographic data such as country of origin, behavioral information such as time spent on the website, as well as other non-personal analytical data used to improve the “customer experience,” products, and services offered. Each User acknowledges and agrees that the performance of the Services may depend on the collection and processing of personal and non-personal data.

Web Browser Cookies

Sources Rosport may use “cookies” to enhance the User’s experience concerning the Services. In this case, the User’s web browser places cookies on their hard drive to collect certain data used to personalize navigation around the Services, enabling unique functionalities.

How Sources Rosport Uses Collected Data

Generally, personal and non-personal identification data is used to provide Services to Users and ensure the proper functioning of these Services to which the User has subscribed or requested in another form. In this context, Sources Rosport may collect and use the User’s personal and non-personal data for the following purposes:

• To improve the Services: The information provided by Users helps Sources Rosport respond to specific User requests.
• To personalize User experience: Sources Rosport may use non-personal information to understand how Users as a group use the Services offered by Sources Rosport.
• To improve the quality of its websites and other online presences, as well as other communication tools or tools related to specific Services: Sources Rosport may use User feedback to improve its products and services.
• To send periodic emails, text messages, or notifications: Sources Rosport may use the email address or mobile phone number provided by the User to respond to inquiries, questions, or other requests. If the User chooses to subscribe to the notification list, they will receive periodic information, such as blog articles, promotions, contests, company news, updates, product or service information, or information from Sources Rosport’s partners in the context of joint projects. If a User wishes to unsubscribe from the periodic Information Service at any time, Sources Rosport includes detailed unsubscribe instructions at the bottom of each email or text message.

How Sources Rosport Protects Personal Data

Sources Rosport adopts appropriate security practices and measures for collecting, storing, and processing data to protect against unauthorized access, alteration, disclosure, or destruction of personal identification data, within the limits of Sources Rosport’s role within the respective Service (as some specific services may be provided by third parties).

Sharing of Personal Data

Sources Rosport is committed to not selling, trading, or transferring Users’ personal identification data to third parties. However, any User agrees that their personal identification data may be shared (i) with hosting partners and website and social network publishers, as well as other subcontractors assisting Sources Rosport in providing Services, managing its business, or servicing the User, as long as these subcontractors agree to process this information solely according to Sources Rosport’s instructions and comply with the applicable data protection laws. Sources Rosport may also disclose a User’s personal identification information if it believes that such disclosure is necessary to comply with the law, enforce its website terms and conditions, or protect its rights, property, or safety, or that of others. However, non-personal identification data of Users may be provided to third parties for marketing, advertising, or other uses.

Changes to this Privacy Policy

Sources Rosport reserves the right to update this privacy policy at any time. It will revise the date of the last update at the bottom of this page. Sources Rosport encourages Users to frequently check if any changes have been made to this page. Users acknowledge and agree that it is their responsibility to review this privacy policy regularly and be aware of any modifications.

Data Retention

Sources Rosport takes all reasonable steps to ensure that your personal data is processed for the minimum period necessary for the purposes outlined in this privacy policy. The criteria for determining the duration for which we will retain your personal data regarding Services are as follows:

• As long as we maintain an ongoing relationship with you (e.g., you are a recipient of our services, or you are legally included in our mailing list, and you have not unsubscribed);
• As long as your personal data is necessary for the legal purposes outlined in this privacy policy, for which we have a valid legal basis;
• Until the expiration of two (2) months after the end of any applicable statute of limitations; and
• With your prior consent, until the expiration of any additional retention period. Sources Rosport commits to deleting or anonymizing your personal data after the retention period described above.

Data Security and Data Transfers

Sources Rosport has implemented appropriate technical and organizational security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other illegal or unauthorized processing activities. You are responsible for ensuring that any personal data you send to us is sent securely. Sources Rosport does not transfer personal data to a third country or an international organization.

Accuracy and Minimization of Data

We take reasonable steps to:

• Ensure that your personal data is accurate and, where necessary, updated;
• Ensure that your personal data is collected in line with the needs defined in this privacy policy.

Data Subject Rights

Each User has the right under data protection law to access, modify, and object to the processing of their personal data, to request the erasure of their data, and to request the portability of their personal data by sending an email to contact@rosport.com. These rights may only be exercised within the limits of any contractual or legal obligations. Each User also has the right to lodge a complaint with the Luxembourg supervisory authority, the National Commission for Data Protection (https://cnpd.public.lu/en.html).

Acceptance of These Terms

By using the Services, Users indicate their agreement with this privacy policy. If a User does not agree with this privacy policy, Sources Rosport advises the User not to use the Services. Continued use of the Services following the posting of changes to this privacy policy will be deemed acceptance of those changes.

 

Last update of this privacy policy: 09/05/2024