Privacy Notice of ROSE Technologies AG

Version dated February 10, 2025

Note: The German version of this privacy notice is legally binding.

In this Privacy Notice, we, ROSE Technologies AG (hereinafter ROSE, we, or us), explain how we collect and otherwise process Personal Data. This is not an exhaustive description; other privacy notices or general terms and conditions, terms of participation, and similar documents may govern specific matters. Personal Data means any information relating to an identified or identifiable natural person.

If you provide us with Personal Data of other persons (e.g., family members, data of work colleagues), please ensure that these persons are aware of this Privacy Notice and only share their Personal Data with us if you are permitted to do so and if such Personal Data is accurate.

This Privacy Notice is designed to meet the requirements of the EU General Data Protection Regulation ("GDPR"), the Swiss Data Protection Act ("DPA"), and the revised Swiss Data Protection Act ("revDPA"). However, whether and to what extent these laws apply depends on the individual case.

1. Controller / Data Protection Officer / Representative

The Controller responsible for the data processing described here is ROSE Technologies AG, c/o Looser, Pilatusstrasse 10, 8032 Zurich, Switzerland. If you have data protection concerns, you can contact us at the following address: privacy@roseframework.io

Our representative in the EEA pursuant to Art. 27 GDPR is: Johannes Scharlach, Luisenstr. 39, 10117 Berlin, Germany.

2. Collection and Processing of Personal Data

We primarily process Personal Data that we receive from our customers and other business partners and other persons involved in the course of our business relationship with them, or that we collect from users when operating our websites, apps, and other applications.

We offer a financial guidance platform for tax, administration, insurance, budgeting, and retirement. Users can centralize all their financial information and have a single place from which they can control their finances.

In addition to the data you provide to us directly, the categories of Personal Data we process include information from public registers, information we learn in connection with official and judicial proceedings, information in connection with your professional functions and activities, information about you in correspondence and meetings with third parties, information about you provided to us by persons in your environment (family, advisors, legal representatives, etc.), information about you from media and the internet (where appropriate in the specific case, e.g., in connection with an application, press review, marketing/sales, etc.), your addresses and, if applicable, interests and other sociodemographic data (for marketing), data in connection with the use of the website (e.g., IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of visit, pages and content accessed, functions used, referring website, location data).

3. Purposes of Data Processing and Legal Bases

We use the Personal Data we collect primarily to conclude and perform our contracts with our customers and business partners, in particular in the context of financial guidance for tax, administration, insurance, budgeting, and retirement with our customers, and the purchase of products and services from our suppliers and subcontractors, as well as to comply with our legal obligations at home and abroad. If you work for such a customer or business partner, you may of course also be affected in this capacity with your Personal Data.

In addition, we process Personal Data of you and other persons, to the extent permitted and deemed appropriate by us, also for the following purposes in which we (and sometimes third parties) have a legitimate interest corresponding to the purpose:

Offering and further development of our offers, services, and websites, apps, and other platforms on which we are present, including automatic classification and data extraction from documents you upload using artificial intelligence;
Communication with third parties and processing of their inquiries (e.g., applications, media inquiries);
Review and optimization of procedures for needs analysis for the purpose of direct customer contact and collection of Personal Data from publicly accessible sources for the purpose of customer acquisition;
Advertising and marketing (including conducting events and sending newsletters), unless you have objected to the use of your data (if we send you advertising as an existing customer, you can object at any time, and we will then place you on a blocking list against further advertising mailings);
Market and opinion research, media monitoring;
Assertion of legal claims and defense in connection with legal disputes and official proceedings;
Prevention and investigation of criminal offenses and other misconduct (e.g., conducting internal investigations, data analysis for fraud prevention);
Ensuring our operations, in particular IT, our websites, apps, and other platforms;
Video surveillance to protect property rights and other measures for IT, building, and facility security and protection of our employees and other persons and values owned or entrusted to us (such as access controls, visitor lists, network and mail scanners, telephone recordings);
Purchase and sale of business divisions, companies, or parts of companies and other corporate transactions and associated transfer of Personal Data as well as measures for business management and to the extent necessary for compliance with legal and regulatory obligations as well as internal regulations of ROSE.

To the extent that you have given us consent to process your Personal Data for certain purposes (for example, when you register to receive newsletters or to conduct a background check), we process your Personal Data within the scope of and based on this consent, unless we have another legal basis and we need one. Consent given can be revoked at any time, but this has no effect on data processing that has already taken place.

4. Cookies / Tracking and Other Technologies in Connection with the Use of Our Website

We typically use "cookies" and similar technologies on our websites with which your browser or device can be identified. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser used when you visit our website. When you visit this website again, we can recognize you in this way, even if we do not know who you are. In addition to cookies that are only used during a session and deleted after your website visit ("session cookies"), cookies can also be used to store user settings and other information for a certain period (e.g., two years) ("permanent cookies"). However, you can set your browser to reject cookies, only store them for a session, or otherwise delete them prematurely. Most browsers are preset to accept cookies. We use permanent cookies so that you can save user settings (e.g., language, auto login), so that we can better understand how you use our offers and content, and so that we can show you customized offers and advertising. Some of the cookies are set by us, some also by contractual partners with whom we work. If you block cookies, certain functionalities (such as language selection, shopping cart, ordering processes) may no longer work.

We sometimes incorporate visible and invisible image elements in our newsletters and other marketing emails, through whose retrieval from our servers we can determine whether and when you opened the email, so that we can also measure and better understand how you use our offers and tailor them to you. You can block this in your email program; most are preset to do this.

By using our websites and consenting to receive newsletters and other marketing emails, you agree to the use of these techniques. If you do not want this, you must set your browser or email program accordingly.

We use analysis services on our websites. This is a service provided by PostHog, Inc., with which we can measure and evaluate the use of the website. Permanent cookies set by the service provider are also used for this purpose. We use the EU-hosted version of PostHog, where all data is stored on servers within the European Union. As part of this analysis, we transmit your email address to PostHog, making you identifiable as a user. In addition, we use session recordings, which record your interactions with our platform, including content displayed in the user interface. Since you manage financial information in our platform as a user, these recordings may contain Sensitive Personal Data. The processing of your Personal Data by PostHog is the responsibility of PostHog in accordance with its data protection provisions and based on a Data Processing Agreement between us and PostHog. These analyses help us improve our platform and fix errors.

We also use so-called plug-ins from social networks such as Facebook, Twitter, Youtube, TikTok, or Instagram on our websites. This is visible to you (typically through corresponding icons). We have configured these elements so that they are deactivated by default. If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and where, and can use this information for their purposes. The processing of your Personal Data is then the responsibility of this operator in accordance with its data protection provisions. We do not receive any information about you from them.

5. Data Disclosure and Data Transfer Abroad

In the course of our business activities and for the purposes set out in Section 3, to the extent permitted and deemed appropriate by us, we also disclose data to third parties, either because they process it for us or because they want to use it for their own purposes. This concerns in particular the following recipients:

Our service providers (such as IT providers), including processors;
Dealers, suppliers, subcontractors, and other business partners;
Customers;
Domestic and foreign authorities, offices, or courts;
Media;
The public, including visitors to websites and social media;
Competitors, industry organizations, associations, organizations, and other bodies;
Purchasers or interested parties in the purchase of business divisions, companies, or other parts of ROSE;
Other parties in possible or actual legal proceedings;

all collectively Recipients.

These Recipients are partly domestic but can be located anywhere in the world. Most of the service providers we use process your data in the European Union or Switzerland: Supabase, Inc. (Zurich), Fly.io, Inc. (EU), Hound Technology, Inc. (EU), Plus Five Five, Inc. (EU), PostHog, Inc. (EU). However, you must expect the transfer of your data to the USA for the use of Google LLC/Google Ireland Limited (Gemini API for automatic classification and data extraction from uploaded documents).

If a Recipient is located in a country without adequate legal data protection, we contractually obligate the Recipient to comply with the applicable data protection (for this purpose, we use the revised Standard Contractual Clauses of the European Commission, which are available here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless they are already subject to a legally recognized framework for ensuring data protection and we cannot rely on an exception provision. An exception may apply in particular to legal proceedings abroad, but also in cases of overriding public interests or if contract performance requires such disclosure, if you have consented, or if it concerns data you have made generally accessible and whose processing you have not objected to.

6. Duration of Storage of Personal Data

We process and store your Personal Data as long as it is necessary for the fulfillment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e., for example, for the duration of the entire business relationship (from initiation, execution to termination of a contract) and beyond in accordance with legal retention and documentation obligations. It is possible that Personal Data will be retained for the time during which claims can be asserted against our company and to the extent that we are otherwise legally obligated to do so or legitimate business interests require this (e.g., for evidence and documentation purposes). As soon as your Personal Data is no longer required for the above purposes, it will generally and as far as possible be deleted or anonymized.

Deleted user account data and all uploaded data are retained for 90 days before being permanently deleted. For operational data (e.g., system logs), shorter retention periods of twelve months or less generally apply.

7. Data Security

We take appropriate technical and organizational security precautions to protect your Personal Data from unauthorized access and misuse, such as the issuance of instructions, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymization, and controls.

8. Obligation to Provide Personal Data

In the context of our business relationship, you must provide the Personal Data that is necessary for the establishment and execution of a business relationship and the fulfillment of the associated contractual obligations (you generally do not have a legal obligation to provide us with data). Without this data, we will generally not be able to conclude a contract with you (or the entity or person you represent) or execute it. The website also cannot be used if certain information to ensure data traffic (such as IP address) is not disclosed.

9. Profiling

We partially process your Personal Data in an automated manner with the aim of evaluating certain personal aspects (profiling). We use profiling in particular to inform and advise you about products in a targeted manner. We use evaluation tools that enable us to communicate and advertise according to needs, including market and opinion research.

For the establishment and execution of the business relationship and also otherwise, we generally do not use fully automated decision-making (as regulated in Art. 22 GDPR). Should we use such procedures in individual cases, we will inform you separately, provided this is required by law, and inform you of the associated rights.

10. Rights of the Data Subject

You have, within the framework of the data protection law applicable to you and to the extent provided therein (such as in the case of the GDPR), the right to information, correction, deletion, the right to restriction of data processing, and otherwise to object to our data processing, in particular that for purposes of direct marketing, profiling operated for direct advertising, and other legitimate interests in processing, as well as to the release of certain Personal Data for the purpose of transfer to another entity (so-called data portability). Please note, however, that we reserve the right to assert the legally provided restrictions on our part, for example, if we are obligated to retain or process certain data, have an overriding interest in it (to the extent we may invoke this), or need it for the assertion of claims. If you incur costs, we will inform you in advance. We have already informed you in Section 3 about the possibility of revoking your consent. Please note that the exercise of these rights may conflict with contractual agreements and may have consequences such as premature termination of the contract or cost consequences. We will inform you in advance where this is not already contractually regulated.

The exercise of such rights generally requires that you clearly prove your identity (e.g., by a copy of ID, where your identity is otherwise not clear or can be verified). To assert your rights, you can contact us at the address given in Section 1.

Each data subject also has the right to enforce their claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

11. Changes

We may adjust this Privacy Notice at any time without prior notice. The current version published on our website applies. If the Privacy Notice is part of an agreement with you, we will inform you of the change by email or in another appropriate manner in the event of an update.