Last Updated: [10th March 2025]
Please take a moment and become familiar with how we collect, use and disclose information.
This Privacy Policy describes our practices in connection with information that we collect through activities that link to this Privacy Policy, including our own website, software and third party websites and applications that work with us, and through your interaction with Rock of Eye’s products and services. By providing information to us, you agree to the terms and conditions of this Privacy Policy and our Terms of Service. You can find out about details of all of ROE’s affiliates by visiting the privacy policies on their respective websites. When we refer to “we”, “us” or “ROE” we are referring to Rock of Eye Software Pty Ltd., an Australian Proprietary Limited company, and its affiliates.
We may update and make changes to this policy, so we encourage you to review it periodically.
We, us, our |
Rock of Eye Software Pty Ltd., an Australian Proprietary Limited company, and its affiliates. |
Our representative |
Mark Ferguson; Mark@rockofeye.ai |
Personal information |
Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household. |
Sensitive personal information |
Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, and citizenship or immigration status. |
Biometric Information |
An individual's physiological, biological, or behavioral characteristics, including information about an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
Categories of Personal Information |
Specific Types of Personal Information Collected |
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) |
First Name, Last Name, Email Address, Address |
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. |
First Name, Last Name, Physical Measurements Necessary to Manufacture Bespoke Clothing, Telephone Number, Credit Card Number, Debit Card Number, Description of Physical Condition Relevant to Manufacturing Bespoke Clothing |
Characteristics of protected classifications |
Physical Measurements Necessary to Manufacture Bespoke Clothing, Description of Physical Condition Relevant to Manufacturing Bespoke Clothing |
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) |
Garments and Accessories Purchased, Personal preferences of colour and style |
Biometric information |
Description of Physical Condition Relevant to Manufacturing Bespoke Clothing, Shoe Size, Height, Weight, Description of Physical Condition Relevant to Manufacturing Bespoke Clothing |
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement) |
History of Accessing Customer Portal, Newsletters and Promotions |
Geolocation data |
Addresses as provided, City, Country |
Audio, electronic, visual, thermal, olfactory, or similar information |
Posture and Face Photos |
Professional or employment-related information |
Industry of Business or Work, Clothing Type to Suit Professional and Casual Occasions |
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) |
University or College Attended |
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
Style, Color and Garment Preferences, Types of Social Events Enjoyed
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Sensitive Personal Information |
Birthday, Address |
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for |
Our reasons |
To provide retailers (tailors) with an automated platform to enter measurements, order goods, order the manufacturing of garments and other accessories, tracking of goods sold and tracking satisfaction of customers of tailors. |
For the performance of our contract with our Clients that are providing services to you |
To prevent and detect fraud against you, our Clients or ROE |
For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator |
To comply with our legal and regulatory obligations |
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies |
To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g., policies covering security and internet use |
For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as improving efficiency, training, and quality control |
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
Ensuring the confidentiality of commercially sensitive information |
For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, e.g., in relation to customer base, product range or other efficiency measures |
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
Preventing unauthorized access and modifications to systems |
For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
Updating and enhancing customer records |
For the performance of our contract with our Clients and you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products |
Statutory returns |
To comply with our legal and regulatory obligations |
Ensuring safe working practices, staff administration and assessments |
To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services to: —existing and former Clients; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. |
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers |
Credit reference checks via external credit reference agencies |
For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services |
External audits and quality checks, e.g., for accreditations and the audit of our accounts |
For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
We never sell retailer data to third parties or use it for external marketing purposes.
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party other than Clients with whom you have received services.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
Disclosure of Personal Information We Collect About You |
You have the right to know, and request disclosure of:
• The categories of personal information we have collected about you, including sensitive personal information; • The categories of sources from which the personal information is collected; • Our business or commercial purpose for collecting, selling, or sharing personal information; • The categories of third parties to whom we disclose personal information, if any; and • The specific pieces of personal information we have collected about you.
Please note that we are not required to:
• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or • Provide the personal information to you more than twice in a 12-month period. |
Disclosure of Personal Information Shared, or Disclosed for a Business Purpose |
In connection with any personal information we may share, or disclose to a third party for a business purpose, you have the right to know:
• The categories of personal information about you that we shared and the categories of third parties to whom the personal information was shared; and • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.
You have the right to opt-out of the sharing of your personal information for targeted behavioral advertising. If you exercise your right to opt-out of the sharing of your personal information, we will refrain from sharing your personal information, unless you subsequently provide express authorization for the sharing of your personal information.
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Right to Limit Use of Sensitive Personal Information |
You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, if the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and · As authorized by further regulations.
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.
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Right to Deletion |
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
• Delete your personal information from our records; and • Direct any service providers or contractors to delete your personal information from their records. • Direct third parties to whom the business has shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.
Please note that we may not delete your personal information if it is reasonably necessary to:
• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; • Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes; • Debug to identify and repair errors that impair existing intended functionality; • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law; • Comply with the California Electronic Communications Privacy Act; • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; • Comply with an existing legal obligation; or • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. |
Right of Correction |
If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
Protection Against Retaliation |
You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: • Deny goods or services to you; • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; • Provide a different level or quality of goods or services to you; or • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, or the retention of personal information. |
Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly, you will need to provide us with:
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
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