Contact Us | Rock of Eye

Privacy Policy

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.

  1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

 

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.

 

  1. ROE operates software as a service platform that allows our retailers (tailors) subscribers (“Clients”) to streamline the process for storing, transferring to manufacturing third parties, shipping and delivering custom clothing and accessories (“Customers”). Specifically, we provide tools and services (together “Services”) that our Clients use to manufacture bespoke clothing and accessories for the Client’s customers. 

    ROE is committed to respecting and protecting individuals’ privacy rights.  This Privacy Policy explains how ROE collects, obtains, uses, secures, and/or discloses end users’ (“you” or “your”) information in the course of providing the Services.
  1. Personal Information We Collect About You. ROE gathers information about you when you obtain services from third party retailers (tailors) utilizing the ROE Platform. In the preceding 12 months, we have collected the following categories and specific types of consumer personal 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

 

Sensitive Personal Information

Birthday, Address

 

  1. How Your Personal Information is Collected. We collect most of this personal information directly from a Client with whom you have sought services. However, we may also collect information from the following categories of sources:
    • Publicly accessible sources (e.g., property records);
    • Third party (e.g., sanctions screening providers, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers);
    • Third party with your consent (e.g., your bank);
    • Cookies on our website;
    • Automated information collection;
    • Our IT systems, including:
      • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems; and
      • Tracking access to Customer Portals.

 

  1. Why We Use Your Personal Information. We collect consumer personal information for the following business purposes:
    • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
    • 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;
    • Debugging to identify and repair errors that impair existing intended functionality;
    • Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided 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;
    • 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 or service provider;
    • Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer;
    • Undertaking internal research for technological development and demonstration;
    • 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;
    • To comply with our legal and regulatory obligations;
    • For the performance of our contract with you or to take steps at your request before entering into a contract;
    • For our legitimate interests or those of a third party;
    • To prepare reports and analysis on trends and other generalized information regarding consumers that are on our platform; or
    • Where you have given consent.

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.

 

  1. Who We Share Your Personal Information With. In the preceding 12 months, we have shared consumers’ personal information with:
    • Service providers we use to help deliver our services to you, such as payment service providers, warehouses, and delivery companies;
    • Other third parties we use to help us run our business, such as CRM Partners or website hosts;
    • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
    • Credit reporting agencies;
    • Our insurers and brokers;
    • Our banks;
    • External auditors;
    • Our Clients with whom you have received services.
  2. 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.

 

  1. Categories of Personal Information We Sold or Shared. In the preceding 12 months, we have not sold or shared (other than with a Client with whom you have obtained services) personal information.

 

  1. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
    • 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);
    • 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;
    • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
    • Biometric information; and
    • 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.

 

  1. How Long Your Personal Information Will Be Kept. We will keep your personal information while you or the Client with whom you have obtained services have an account with us or while we are providing services related to you. Thereafter, we will keep your personal information for as long as is necessary:
    • To respond to any questions, complaints or claims made by you or on your behalf;
    • To show that we treated you fairly; or
    • To keep records required by law.
  2. 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.

 

  1. Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

 

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.

 

 

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.

 

 

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.

 

  1. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so by emailing Mark Ferguson at mark@rockofeye.ai

    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:

    • Enough information to identify you (e.g., your full name, address and the Client with whom you obtained services);
    • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
    • A description of what right you want to exercise and the information to which your request relates.
  2. 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.

 

  1. Compliance with Privacy Regulations. ROE aligns with data protection laws, including:
    - CCPA/CPRA (for USA based businesses).
    - Australian Privacy Act (for Australian businesses and businesses outside the EU and UK)