Privacy Policy Statement

          Effective Date: April 24, 2017

          This Privacy Policy Statement explains how ROIKOI may collect, use, and disclose information we obtain from you through the "Site" on behalf of “your Company” and includes ROIKOI’S Privacy Policy Statement and the EU-US Privacy Shield Statement.

          ROKOI’S PRIVACY POLICY STATEMENT

          DEFINITIONS

          The term "ROIKOI," "we," and "us" includes Plato Labs, Inc. d/b/a ROIKOI and our affiliates and subsidiaries.

          The "Site" means any website, mobile application, or Internet service under the control of ROIKOI, whether partial or otherwise, in connection with providing a platform for ROIKOI's Refer services.

          "Personal Information" means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual who has provided such information.

          “your Company” refers to your employer or the legal entity who has engaged ROIKOI to provide Refer services to its members or employees.

          All terms not defined herein will have the meanings set forth in the Terms of Service.

          THE SITE COLLECTS YOUR INFORMATION

          Personal Information Collection. We may collect your email address when you sign up to use the Site. When you register, we collect certain Personal Information you have made publicly available on social or professional networks, such as your name and picture.

          If you upload or otherwise provide us with lists of connections, like those provided from professional networks or your contact list, we may collect, save, and share with your Company any of your connections’ information that you provide, including, but not limited to their, names, email addresses, current employer, work history, and profile pictures.

          Using the Site. We collect information you post through the Site. We may offer you the ability to message other users through the Site which may forward to your email or to the email of other users.

          Your Contacts/Address Book. You may import individual contacts or your entire address book from any website or any of your devices (including, but not limited to, mobile devices) to the Site. ROIKOI may copy, store, and use the contacts contained in your mobile device’s address book. By permitting ROIKOI to copy, store, and use the contacts contained on your mobile device, you represent that you have the authority to share the transferred data with ROIKOI and your mobile carrier or other access provider.

          Customer Support. We may collect Personal Information through your communications with our customer-support team.

          Cookies, Automatic Data Collection, and Related Technologies. The Site collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics.

          When you visit the Site, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Cookies are small text files placed in visitors' computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

          We may use standard Internet technology, such as web beacons and other similar technologies, to track your use on the Sites. We also may include web beacons in promotional email messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our visitors/customers/Members to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.

          By using the Site, you are authorizing us to gather, parse, and retain data related to the provision of the Site and we may retain and continue to use your data even if you terminate your Member account.

          HOW ROIKOI USES YOUR INFORMATION

          Internal and Service-Related Usage. We use information, including your Personal Information, for internal and service-related purposes and may provide it to selected third parties, including your Company, to allow us to facilitate the use of the Refer service and the Site. We may use and retain any data we collect to provide and improve our services.

          Communications. We may send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance. If you provide your email address to receive notifications about the Site, we may send you such notifications.

          Aggregate Data. Anonymous and aggregate data collected through the Site may be used for any purpose.

          ROIKOI MAY DISCLOSE YOUR INFORMATION

          We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Site. In addition, we may share your information, including usage statistics about your activity on the Site, with your Company.

          Displaying to Other Users. Your first name, last name, and picture may be displayed to other users of the Site, if they demonstrate that they are connected to you on a social, professional, or personal network, including, but not limited to, address books or email address lists.

          Syncing Your Contacts/Address Book. ROIKOI allows you to import or manually enter contacts from your address book and other personal networks. ROIKOI may share any or all of the entered information with your Company in connection with provision of Site services.

          Your Company. We may share information, including Personal Information, about you with your Company to facilitate recruiting and/or hiring efforts at your Company. Your Company may contact your referrals via email or other methods, and may ask for introductions to any of your referrals. Subject to applicable law, there is no restriction on the number of times we may contact your referrals.

          Referrals. We may share information, including Personal Information, about any person whose information you upload via ROIKOI Refer with third parties to facilitate recruiting and/or hiring efforts. The third parties may contact your referrals via email or other methods, and may ask for introductions to any of your referrals.

          As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, including court orders or subpoenas; respond to your requests; or protect your, our, or others' rights, property, or safety.

          Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of ROIKOI assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

          We may also disclose your Personal Information with your permission.

          Subject to the terms of this Privacy Policy, we may maintain information, including your Personal Information, following your discontinued use of the Site and/or your Company’s discontinuance of the Refer service.

          SECURITY OF YOUR INFORMATION

          We take steps designed to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

          By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Site or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at support@roikoi.com.

          CHILDREN'S PRIVACY

          We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Site is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at support@roikoi.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child's account.

          INTERNATIONAL USERS

          By choosing to visit the Site or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of Texas and the adjudication of any disputes arising in connection with ROIKOI or the Site will be in accordance with the Terms of Use.

          If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.

          GPS

          We may provide Global Positioning System (GPS) tracking technology be enabled in ROIKOI products and services in order to determine the location (latitude and longitude) of users of the ROIKOI products and services. This information is transmitted to ROKOI and temporarily stored by ROIKOI. ROIKOI does not provide this information to any other third party.  This information is used in conjunction with ROIKOI's mobile application and services and enables ROIKOI to track locations of users.

          UPDATE/REMOVE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

          If you would like to update or correct any information that you have provided to us through your use of the Site or otherwise, or if you have suggestions for improving this Privacy Policy, please send an email to support@roikoi.com.

          Any information that you upload or sync with the Site via any of your devices (including, but not limited to, your mobile devices) is covered by the Terms of Use and this Privacy Policy. If you would like to remove your picture, name, and any other Personal Information from the Site, please email us at support@roikoi.com.

          CHANGES TO OUR PRIVACY POLICY AND PRACTICES

          Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. We recommend that you bookmark this page and read this Privacy Policy periodically.

          New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses if required by law.

          Contact Information

           Plato Labs, Inc. d/b/a ROIKOI
           106 E. Sixth Street Suite 900
           Austin, Texas 78701
           support@roikoi.com

          EU – US Privacy Shield Statement

          Plato Labs, Inc. d/b/a ROIKOI (“ROIKOI”) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.

          ROIKOI has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. If there is any conflict between the policies in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles will govern. This Privacy Statement outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information.

          A). Definitions

          “Personal Data” means information that (1) is transferred from the EU/EEA to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

          “Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

          B). Principles

          ROIKOI may receive Personal Data from parties located in the EU/EEA. Such information may contain names, addresses, email addresses and payment information and may be about customers, clients of customers, business partners, consultants, employees, and candidates for employment and includes information recorded on various media as well as electronic data.

          ROIKOI generally does not collect Personal Data directly from individuals. ROIKOI, however, may receive Personal Data indirectly via its customers. ROIKOI expects that those customers comply with the Principles. ROIKOI will cooperate with its customers to enable them to comply with the Principles, to the extent a Principle is applicable to ROIKOI.

          Whenever ROIKOI collects Personal Data directly from individuals, ROIKOI complies with the Principles:

            1. Notice. We shall inform an individual of the purpose for which we collect and use their Personal Data and the types of third parties to which our Company discloses or may disclose that Personal Data. Our Company shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to our Company, or as soon as practicable thereafter, and in any event before our Company uses or discloses the Personal Data for a purpose other than for which it was originally collected. ROIKOI may be required to disclose Personal Data in response to lawful request by public authorities, including to meet national security or law enforcement requirements.

            2. Choice. We will offer individuals the opportunity to choose (opt out) whether their Personal Data is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.  To limit the use and disclosure of your personal information, please submit a written request to support@roikoi.com.  For Sensitive Personal Information, our Company will give individuals the opportunity to affirmatively or explicitly (opt in) consent to the disclosure of the information to a third party or for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Our Company shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

            Agents, technology vendors and/or contractors of ROIKOI may have access to an individual’s Personal Data on a need to know basis for the purpose of performing services on behalf of ROIKOI or providing or enabling elements of the services. All such agents, technology vendors and contractors who have access to such information are required to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for ROIKOI or as otherwise required by law.

            3. Accountability for Onward Transfer. Prior to disclosing Personal Data to a third party (as detailed in the above in “ROIKOI MAY DISCLOSE YOUR INFORMATION”), we shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Our Company shall ensure that any third party to which Personal Data may be disclosed agrees, in writing, to provide a level of privacy protection that is no less protective than those set out in this Policy.

            ROIKOI’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, ROIKOI remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless ROIKOI proves that it is not responsible for the event giving rise to the damage.

            4. Data Security. We shall take reasonable steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. Our Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, our Company cannot guarantee the security of Personal Data on or transmitted via the Internet.

            5. Data Integrity and Purpose Limitation. We shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, our Company shall take reasonable steps to ensure that Personal Data is accurate, complete, current and reliable for its intended use.

            6. Access and Recourse. We acknowledge the individual’s right to access their Personal Data. We shall allow an individual access to their Personal Data and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to support@roikoi.com. If requested to remove data, we will respond within a reasonable timeframe.

            7. Enforcement and Liability. In compliance with the EU-US Privacy Shield Principles, ROIKOI commits to resolve complaints about privacy and our collection or use of Personal Data. European Union individuals with inquiries or complaints regarding this privacy policy should first contact us at:

            Plato Labs, Inc. d/b/a ROIKOI
            106 E. Sixth Street Suite 900
            Austin, Texas 78701
            support@roikoi.com

            ROIKOI has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

            ROIKOI has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

            Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel, to be created by the U.S. Department of Commerce and the European Commission.

            ROIKOI compliance under the Privacy Shield is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)

          C). Amendments

          This Privacy Statement may be amended from time to time consistent with the requirements of the EU-US Privacy Shield Framework. We will post any revised policy on this website.

          D). Information Subject to Other Policies
          We are committed to following the Principles for all Personal Data within the scope of the EU-US Privacy Shield. However, certain information is subject to policies of ROIKOI that may differ in some respects from the general policies set forth in this Privacy Statement.