Privacy policy of rool.am

1. Who is responsible for your data

The site and the ROOL project are run by Rudolf Harutyunyan, an individual, Armenia. For questions about your data and the subscription, write to: rool.app.company@gmail.com

2. What this policy covers

The rool.am website and the news subscription. The ROOL app and signing in to an account are covered by a separate policy.

3. What data we receive

When you simply open the site. The site uses no cookies, analytics, advertising pixels or third-party scripts. Your browser keeps only the language you chose. Fonts and images are loaded from rool.am itself. Like any website, our server records technical request logs: your IP address, the address of the page you opened, details of your browser and the browser language.

When you subscribe to the news. You enter your email address and tick the consent box. We receive the address, the page language, the time and version of your consent text, and the fact that the subscription was made through the form on the site. The subscription takes effect only after you click the confirmation link in the email.

4. What we use the data for

• Sending news about the launch of ROOL and major updates, and only if you agreed. For this we also send the confirmation email and keep a record of your consent (time, text version, source) so that we can show it if needed.
• Running and protecting the site: technical request logs and a temporary request counter protect the site from abuse and help find faults.
• Email statistics: information about opened emails and clicked links helps us see whether the news are read.

We do not show third-party advertising and we do not sell addresses. If we want to use the data for anything else, we will ask for your separate consent.

5. Who else processes your data

• Brevo (an email service) stores your address and subscription details on our behalf and sends the confirmation email and the news. By its own terms, Brevo’s servers are in France and Belgium. Brevo also uses contractors and companies of its group, including in the USA and India, for support and maintenance; for such cases Brevo relies on standard contractual clauses and the EU-US Data Privacy Framework. For limited purposes (accounting, statistics, defending its rights) Brevo also processes data itself. More: Brevo’s data processing terms and contractor list, https://www.brevo.com/legal/termsofuse/ (the Data Processing Agreement section).
• Hosting (a virtual server at Netcup, Germany): the site runs there and the technical logs are kept there.
• We do not sell addresses and do not pass them to advertisers. Subscription data is processed only by the parties named here: Brevo (with its contractors) and the hosting provider.
• By subscribing, you agree to your address being passed to Brevo and its contractors in the countries listed.

6. Tracking in emails

By default Brevo adds an invisible image (a pixel) and individual links to the emails it sends on our behalf. They record when you opened an email and which links you followed. For each subscriber Brevo records the date and time of opening, link clicks and the IP address from which the email was opened. This information is tied to your address and is visible to us in the contact record and in Brevo reports. We use it to see whether the news are read, and not for advertising. Brevo processes this information (section 5). You can limit open tracking by blocking image loading in your mail program.

7. Server logs

Technical request logs are limited by size: old records are deleted as the log fills up. No fixed deletion period is set at present. Your email address does not appear in them. To protect against abuse, your IP address is counted in a request counter for about an hour. The logs are not part of the database backups.

8. How long we keep data

• The address and subscription details while you are subscribed.
• If you unsubscribed: the contact stays with Brevo (the address, the “do not email” mark and details of earlier emails) for as long as this is needed so that we do not write to you again, or until deletion at your request (see section 10).
• Details of emails (sent, delivered, opened, link clicks, IP address at opening) are kept by Brevo while your contact exists. When we delete the contact at Brevo, it disappears from our account; whether it is also removed from Brevo’s own backups and service logs, we cannot yet confirm.

9. Duration of consent, withdrawal, unsubscribing and subscribing again

Your consent lasts until you withdraw it. You can withdraw it at any time with the “unsubscribe” link in any email or by writing to rool.app.company@gmail.com. After withdrawal we stop sending news. The contact stays with Brevo with a “do not email” mark: the address and details of emails sent earlier, including opens, clicks and IP address, are kept with it until the contact is deleted (see sections 8 and 10). Every email has an unsubscribe link. After unsubscribing, the form on the site cannot subscribe you again automatically, and we do not restore a subscription by hand. If this changes, we will update this policy and ask for new consent.

10. Your rights and requests

You may ask for information on how your data is processed, see it, and ask us to correct, block or delete it if it is incomplete, inaccurate, outdated, unlawfully obtained or not needed for the purpose. Write to rool.app.company@gmail.com. We will give you information about your data within 5 days of receiving the request; we must correct, block or delete data immediately or, if that is not possible, within 3 working days. If we refuse, you will receive a written decision with the reason within 5 days. You may apply to the authority of Armenia for the protection of personal data. Before deleting the contact of a person who has unsubscribed, we will explain that the “do not email” mark disappears from our Brevo account with it, and offer a choice. We do not promise that data will be erased from all of Brevo’s systems: that depends on Brevo. To make sure the request comes from you, we may ask you to confirm it from the same address.

11. Changes

If we change how data is processed, we will update this page and the version date. If the purpose of the mailing changes, we will ask for new consent.