Privacy Policy

1. About Rockelis and How to Contact Us

 

Rockelis Partners Inc, (collectively “Rockelis”, “we,” or “us”) are the controllers of personal data provided to us by data subjects.  We also act as data processors when providing certain services to our business clients.

 

Rockelis adopts this notice to provide transparency to individuals about the Personal Data we collect, how that data is used and how we comply with certain regulations.

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If you have any privacy concern or questions about how your personal data is used, please feel free to contact us.

 

You can find our contact details in the last section of this notice.

 

About Rockelis

 

Rockelis offers a myriad of consulting solutions to individuals, corporations, governments, attorneys, and NGOs. We are located in San Juan, Puerto Rico and you can find our contact information here. We are data controllers and data processors. Rockelis is the data controller of information collected through this website or as provided by you when you otherwise interact with us. Rockelis also may serve as a data processor when we provide services and perform work for our business clients. Rockelis’s services are delivered as requested and directed by our clients.  There are certain circumstances where our subsidiaries may also be data controllers or data processors, for instance when you engage us for the provision of services, but we will inform you of these circumstances in advance.

 

How to contact us

 

If you want to exercise your data protection rights, have any questions, or need further information about this Privacy notice or the processing of your Personal Data by Rockelis, please contact us by email at info@rockelis.com.

 

2. Scope of this Privacy Notice

 

This privacy notice applies to information collected through the website, social media, or when you otherwise interact with us. We are also committed to complying with local legal requirements in jurisdictions where we offer services.

 

This Privacy Notice applies to:

 

• All electronic communications with Rockelis, including visiting our website or interacting through social media ads.

• Personal data we receive from anyone who requests information or otherwise interact with us.

• Our marketing activities, including events and conferences.

• Our collection and use of information in the normal course of business.

 

This Privacy Notice is always subject to applicable local law requirements.

 

3. Sources of Personal Data

 

We collect information from different sources depending on the context of your interactions with Rockelis, for instance when you visit our website, when interacting with an ad on social media, or when engaging our services.

 

We collect information and data from you in various ways, including:

 

Information received directly or indirectly from you:

 

• Online data. Through use of the website, including any information you send to us and through our use of “cookies”.

• Contact and event registration. Information that you provide when you contact us, or for event registration.

• Business relationships. When you provide or receive services from Rockelis we usually collect information voluntarily from you, or from third parties, with your authorization.

 

Or from third-party sources:

 

• Information that we obtain from other third-party sources as permitted by local law, such as publicly accessible social media sites, company websites, and subscription-based third-party databases such as business research databases.

 

4. What Personal Data We Collect and Why

 

Depending on the relationship you have with Rockelis and where you are located, we collect and use different types of personal data, according to local laws.

 

“Personal Data” as used herein means all information that can directly or indirectly identify you or other individuals.

 

Technical Usage Information and Analytics

 

When you visit our site, we collect usage information sent to us by your computer or mobile device that tells us how you are using the website, including information such as the browser type, IP address, user language, the operating system, unique device identifier, or location. This information is collected using cookies and similar technologies.

 

Contact information for Event Registration and to respond to inquiries

 

We collect your name, email, title, company, postal address, telephone number or other information that you voluntarily choose to provide to us for event registration, or to send you marketing information as requested.

 

Information related to the provision of our services

 

When providing services to clients, in addition to collecting business contact information, we will process various documents, files, or other data using software or hardware tools at the request of our clients.  The data we process on behalf of our clients may contain personal data, and special categories of personal data. 

 

The receipt and processing of this type of information and the appropriate data protection measures are defined on a case-by-case basis through a risk analysis and/or through a separate agreement with each of our clients.

 

Information from Other Sources

 

The information we collect may be combined with information from outside records (e.g., demographic information, navigation information, additional contact information) that we have acquired in accordance with law. For example, if you work at a law firm but we don’t know your title, we may go to the firm’s website or a social media site to confirm your title.

 

5. Our Use of Personal Data

 

The purposes for which we collect and use your personal data may vary depending on the type of relationship you have with us, such as if you are a website visitor, one of our clients, or an applicant for a job position with us.

 

When it is necessary for entering into or the performance of a contract:

 

• Recruitment. We process your job application for employment management and recruitment purposes.

• Compliance with contracts and engagements. We collect personal data to perform our business functions providing consultancy services to clients, and executing contracts with our providers.

• Billing and payments. We collect data of the appropriate representatives of accounts payable or receivable.

 

To comply with applicable laws:

 

• To comply with laws such as anti-money-laundering rules, fraud prevention, tax, employment, and other relevant national laws.

• Courts, and law enforcement requests. Including disclosures to courts, public authorities, and law enforcement.

 

For our legitimate interests in:

 

• Collecting Technical usage information and Analytics. We collect information automatically for administering and improving our website, including analyzing the traffic patterns of our site, according to our Cookie Policy.

• Responding to inquiries and information requests.

• Providing registration for Events. We collect information necessary for the organization of events, seminars, and publications related to our different practices and services.

• Conducting Marketing activities. Our marketing activities include sending newsletters, updates, and other information and materials related to our services and events that we think will be of your business interest.

• Engaging in Business development. Building business relationships and synergies for future projects with our clients and potential clients, including business strategy decisions.

• Client Administration and management. Consolidating information relating to our clients, potential clients, and service providers among Rockelis’s offices for the provision of services and for business development purposes.

• Information security. Implementing security measures to protect availability, integrity and confidentiality of information processed by Rockelis, and to prevent and respond to cybersecurity threats and data breaches.

• Defending our interest and legal rights. For instance, to enforce our website terms, policies and contracts with clients and providers, for the establishment, exercise, or defense of legal claims.

• Business transfer. Sharing certain personal data in the context of a merger, sale, acquisition, reorganization, dissolution, or other change of ownership of control.

 

We also use your personal data based on your consent; in these cases, you can withdraw that consent at any time:

 

• When appropriate and permitted by applicable local laws we process special categories of personal data based on your explicit consent (for instance when you provide diet preferences or disability-related needs when you register to our events).

• Some marketing activities and events are based on your consent (for instance, when we don’t have a business relationship with you).

 

6. Data Retention

 

We retain personal data only for the length of time required to fulfill the purpose for which the data was collected or to comply with legal obligations.

 

According to our retention policy, we retain Personal Data as necessary for the duration of the purposes outlined in this Privacy Notice and to comply with our legal obligations. The retention period depends on the context in which we process personal data, for instance:

 

• Technical Usage Information. Information collected automatically using cookies is retained for a maximum period of 13 months.

• Remaining information. Retention periods for data not referenced above are determined by the purposes defined above for which the information is collected and used, for instance when it is necessary to continue providing a service or to comply with our professional obligations, considering applicable data protection laws, and legal requirements, including tax and anti-money laundering regulations, that may vary depending on the jurisdiction.

 

We will delete or block your Personal Data after these retention periods, unless you authorize us to keep it, or when it is necessary to enforce our agreements or resolve disputes.

 

These retention terms apply unless agreed upon otherwise in a contract with Rockelis or as required by applicable local law.

 

7. Who Receives Your Data

 

At times, we disclose your personal data to our Rockelis subsidiaries and to our vendors to help accomplish our business objectives and provide you services. There are other circumstances where we are required by law to disclose personal data to public bodies or judicial authorities.

 

Information collected may be shared with:

 

Rockelis subsidiaries

 

We may share the information we collect about you with our Rockelis affiliates and subsidiaries.

 

The information may be disclosed (i) to provide services (e.g. consultancy services); (ii) to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) to guide decisions about our Rockelis services, website, and communications.

Service Providers and Other Third Parties.

 

We may disclose your information to service providers under contract who help with our business operations, including sub-contractors supporting the delivery of professional, technology, or communication services. Any providers or third parties we engage will be vetted to ensure they have the appropriate privacy and security practices in place.

 

Other Entities with your Consent

 

We will disclose your information to other third parties to whom you explicitly ask us to send your Personal Data. On this site, you may have opportunities to express interest in or register for other services such as registering for events and webinars organized by third parties. If you do, we will provide your Personal Data to those third parties to fulfill your request.

 

Social media sites

 

When you interact with our website through social media sites, plug-ins, or other applications, depending upon your privacy settings, this information may become public on the Internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.

 

Legal Obligations

 

We may disclose your Personal Data as required by law, such as to comply with lawful requests by law enforcement and public authorities or courts, when we believe in good faith that disclosure is necessary to comply with such legal process, or to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We will use reasonable endeavors to notify you before doing so unless we are legally restricted from so doing.

 

Change of Control

 

Rockelis may in the future reorganize or transfer all or part of its businesses, which may result in the transfer of your Personal Data to new Rockelis entities or third parties through which the whole or a part of the Rockelis businesses will be carried out. If Rockelis becomes insolvent, enters receivership or any similar or equivalent event occurs, parts of the business may be sold or transferred to a third party. This change of control may result in the transfer of your Personal Data to a third party that will carry out the business.

 

8. Opt-Out of Marketing Communications

 

You can opt-out of your marketing communications anytime.

 

You can opt-out of receiving our newsletter or other marketing communications by following the opt-out instructions in our commercial e-mails or by contacting info@rockelis.com.

 

9. Transfers of Personal Data

 

If you are located outside the United States and you interact with our website or provide Rockelis personal data, then your information may be transferred to the United States. Only in certain circumstances, your personal data will be transferred to other jurisdictions. However, we provide appropriate safeguards to ensure the same level of protection of your personal data.

 

If you are located outside the United States and you interact with our website or provide us Personal Data, then your information may be transferred to Rockelis affiliates in the United States or to our third-party service providers located in the United States. In certain circumstances, for instance, when it is necessary for the provision of services, we may transfer your personal data to Rockelis’s offices or service providers based in other jurisdictions. In these situations, we ensure compliance with local data protection requirements.

 

If you are based in the European Economic Area (EEA), the United Kingdom or Switzerland, we use Standard Contractual Clauses (SCC) to ensure appropriate safeguards when we transfer your personal data to the US or to other jurisdictions that do not provide an equivalent level of protection. These contracts can be provided on request. In exceptional situations where it is not possible to use SCC or other transfer mechanisms, we rely on derogations including your explicit consent, necessity to enter a contract with you or in your interest, or for the establishment, exercise or defense of legal claims.

 

10. Data Protection Rights

 

If you reside in these territories or in other locations where similar rules apply, Rockelis is committed to facilitate the exercise of your rights granted by the data protection laws of your country of residence.

 

Rockelis is committed to facilitate the exercise of your rights granted by the data protection laws of your country of residence. Accordingly, some of the rights listed below will only apply in certain circumstances. You can contact us at any time to discuss any of these rights or your privacy concerns at info@rockelis.com.

 

• Transparency and the right to information: we provide you notice of how we use your Personal Data in our day-to-day operations at the time of collection, or as soon thereafter as possible. We also publish this privacy notice for a greater transparency.

• Right to access and rectification: we provide you with access to your own personal data where required by applicable law. In addition, we will rectify your Personal Data when we are notified that it is inaccurate.

• Right to object, restriction of processing, erasure and withdraw consent at any time: for all marketing materials, you can opt-out anytime and free of charge. The right to object for other processing activities, the right of erasure and restriction of processing will be balanced to ensure that these are not incompatible with local laws and regulations or other overriding rights. When we have collected your personal data with your consent, then you can withdraw it at any time.

• Right to data portability: based on your specific situation, we provide you with the right to obtain and reuse your data across different services, including the transfer of your data to you or to another third-party.

• Right to lodge a complaint with your supervisory authority: if you are not satisfied with our response or how we process your personal data you can complain to the data protection authority of your habitual residence.

 

How to exercise these data protection rights

 

All these requests should be submitted as follows:

 

• Opt-out of marketing communications: you can opt-out anytime by following the opt-out instructions in our commercial e-mails or by contacting us at info@rockelis.com.

• To exercise the rest of your rights: you should send a communication in writing to info@rockelis.com. Rockelis will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period, we will contact you.

• You also have the right to lodge a complaint with a supervisory authority.

 

11. Security

 

We take commercially reasonable precautions to try to keep all information obtained from you secure against unauthorized access and use, and we periodically review our security measures.

 

We are committed to processing your data in a secure manner and have implemented appropriate technical and organizational measures designed to help prevent the Personal Data we hold from being accidentally or deliberately compromised.

 

We maintain technical, physical, and administrative security measures to try to protect the security of your Personal Data against loss, misuse, unauthorized access, disclosure or alteration. Authorized Rockelis personnel and third parties will only have access to your Personal Data to the extent needed to do their job or provide their services. Despite these precautions Rockelis cannot guarantee that unauthorized persons will not obtain access to your information.

 

Please note that any electronic communication made between us, including via the website, may not be secure and, unless you are already a client, may not be treated as confidential. While we welcome your inquiries, please do not send us any electronic communication that contains any confidential or sensitive Personal Data.

 

Our site may contain links to other third-party websites. We are not responsible for the privacy practices or the content or security of these third-party sites.

 

Our site does not respond to do-not-track signals.

 

12. Our Policy with respect to Children

 

Our services are not directed to children.

 

We do not knowingly collect personal data from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, please contact us at info@rockelis.com.

 

13. Changes to this Notice

 

We reserve the right to modify this privacy notice at any time. We will duly inform you of any material changes.

 

This Privacy Policy may be amended by us at any time. If we make any material changes to how we treat Personal Data, we will notify you by placing a prominent notice on the site. The time stamp you see on the policy will indicate the last date it was revised.

 

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This Policy was last updated on March 19th, 2022.