PRIVACY STATEMENT

(Last Updated 7/1/2023)

This Privacy Statement (also referred to herein as the “Statement”) describes Our policies and procedures related to the collection, use, retention, and disclosure of Your information when You use the Service as defined below. By using the Service, You agree to the collection, use, retention, and disclosure of Your information in accordance with this Privacy Statement.

I. DEFINITIONS

For the purposes of this Privacy Statement:

· "Account" means a unique account created for You to access Our Service or parts of Our Service.

· "Company" (referred to as either "the Company", "We", "Us" or "Our") refers to Martco L.L.C. (“Martco”), also known by its tradename RoyOMartin.

· "Country" refers to the United States of America.

· "Cookies" generally refer to small files placed on Your computer, mobile or any other device by a website which contain details about Your browsing history on a website.

· "Device" means any device that can access the Service such as a computer, cell phone or digital tablet.

· "Personal Data" is any information that relates to You or any identified or identifiable individual.

· “Recruitment Data” refers, generally, to information gathered and retained by Us, or a third-party on Our behalf, during the recruitment and hiring process.

· "Service" refers to the Company Website accessible at <https://royomartin.com>.

· "Service Provider" means any natural or legal person who processes data on behalf of the Company. Service Provider also includes third-party individuals or business entities engaged by the Company to provide, perform, facilitate or analyze activities related to the Service.

· "Usage Data" refers to data collected automatically, whether generated by Your use of the Service or from the Service infrastructure.

· "Website" refers to the Company website accessible at <https://royomartin.com>.

· "You" means any individual or business entity accessing or using the Service or any other legal entity accessing or using the Service on behalf of You or any individual.

II. COLLECTION OF PERSONAL AND USAGE DATA

A. Types of Data Collected

1. Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information (“Personal Data”) that can be used to identify or contact You. Personal Data may include, but is not limited to Your:

· Email address

· First name and last name

· Phone number

· Address, State, Province, ZIP/Postal code, City

· Usage Data

2. Usage Data

Usage Data is collected automatically when using the Service through a Device.

Usage Data may include, but is not limited to:

· The type of Device used to access Our Service,

· Your Device's Internet Protocol address, browser type or version,

· Pages visited on Our Service,

· The time, date and length of time spent on Our Service,

· Unique device identifiers, diagnostic data, and

· Other information that Your browser sends to Us.

When You access the Service by or through a mobile device, We may automatically collect, in addition to the information listed above, information related to the mobile device Internet browser used and other unique mobile device identifiers and data.

We may also collect information that Your browser sends to Us whenever You visit Our Service.

3. Recruitment Data

In connection with our hiring process, We use Pinpoint, an online software product provided by the Infuse Group Ltd (“Pinpoint”) to collect, process and analyze Recruitment Data.

Recruitment Data includes, but is not limited to:

Your name, email address, physical/home address, date of birth, qualifications, experience and any information relating to Your employment history, skills and experience that You provide to Us.
Your correspondence (written and verbal) to the Company.
Details about Your visits to Website including Your Website traffic, Your location and other communication data, the site that referred You to our Website and the resources You access while on Our Service.

B. Tools Used for the Data Collection Process

We use Cookies and Web Beacons as tracking tools on our Service to: (1) follow User activity, (2) collect and store certain information, and (3) analyze and improve our Service.

1. Cookies or Browser Cookies.

Unless you have adjusted Your browser setting to refuse Cookies, Our Service may use Cookies to track and retain Personal or Usage Data. If You do not accept Cookies, You may not be able to utilize parts of Our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You are offline. Session Cookies are deleted as soon as You close Your web browser.

We use Persistent and Session Cookies for the following purposes:

1. Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us

Purpose(s): to (1) provide You with services available through the Website and to enable Your use some of its features and (2) help authenticate users and prevent fraudulent use of user accounts. Without Necessary/Essential Cookies, Our Services cannot be effective.

2. Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us

Purpose(s): to assure Users have accepted the use of Cookies on the Website.

3. Functionality Cookies
Type: Persistent Cookies
Administered by: Us

Purpose(s): to assure the Service maintains login details and language preferences of Service Users.

4. Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties

Purpose(s): to (1) track information about User traffic to and utilization of the Website and (2) test Users’ responses to new pages, features, and the general functionality of the Website.

2. Web Beacons

Web Beacons are small graphic images or other objects embedded in an HTML-formatted web page or email. Web Beacons are sometimes referred to as clear gifs, pixel tags, and single-pixel gifs. Our Service uses Web Beacons to track User activities while on the Website and to gather other Website statistics.

III. USE OF PERSONAL AND USAGE DATA

The Company may use Your Personal and Usage Data for several purposes including, but not limited to:

1. Provide, maintain, and monitor Your use of Our Service;

2. Contact You by email, telephone, SMS, or other equivalent forms of electronic communication, such as mobile application push notifications regarding updates to the Service or information about the functionalities, products or contracted services associated with the Website;

3. Provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those You have already purchased or inquired about unless You have opted not to receive such information; and

4. Manage Your requests to Us.

The Company may also use Your Personal and Usage Data to conduct data analysis, identify usage trends, determine the effectiveness of our promotional campaigns, and evaluate and improve our Service, products, marketing and Your overall experience.

IV. COMPANY SHARING OF PERSONAL AND USAGE DATA

The Company may share Your Personal and Usage Data with a variety of third parties including but not limited to:

· Service Providers in an attempt to: (1) monitor and analyze the use of Our Service, (2) process payments, and (3) contact You.

· Another business entity as it relates to negotiations of any merger or sale of Company assets. If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred and subject to a different Privacy Statement. Notice of any change in the Privacy Statement of this Service will be published on our Website.

· Our affiliates, in which case We will require those affiliates to honor this Privacy Statement. Affiliates include any business entity, subsidiary, joint venture partner, or other entity that We control.

· Our business partners in an effort to offer You certain products, services or promotions.

· Law enforcement in response to a valid request by public authorities or as otherwise required by law.

· Other parties when necessary to: (1) protect and defend the rights or property of the Company, (2) prevent or investigate possible wrongdoing in connection with the Service, (3) protect the personal safety of Our Service Users or the public, or (4) protect against legal liability.

· Pinpoint Software to assist with Our recruitment efforts and to process personal information (Recruitment Data) as a data processor on our behalf.

We may also disclose Your Personal and Usage Data with others with Your consent.

Your consent to this Privacy Statement, which is indicated by Your submission of Personal Data to our Service, represents Your agreement to any subsequent transfer of Your Personal or Usage Data.

V. STORAGE OF YOUR PERSONAL AND USAGE DATA

Your Personal and Usage Data is processed at the Company's operating offices and in any other place where the parties involved in the processing are located. This means that Your Personal and Usage Data may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

VI. RETENTION OF PERSONAL AND USAGE DATA

The Company will retain Personal and Usage Data as required by law or for as long as is necessary for the purposes set out in this Privacy Statement.

VII. SECURITY OF PERSONAL AND USAGE DATA

The Company will take all steps reasonably necessary to ensure Personal and Usage Data is treated securely and in accordance with this Privacy Statement. The Company cannot guarantee protection of Your information once it is shared with other parties.

VIII. THIRD-PARTY ACCESS TO OUR SERVICE

A. Google Services

We may use third-party Service Providers to collect, monitor, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies/Procedures. These Third Party Service Providers include, but are not limited to, Google Analytics, Google Fonts, and Google Tag Manager.

B. Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports Website traffic. Google uses data collected to track and monitor the use of Our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having Your activity on the Service made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy and Terms web page: https://policies.google.com/privacy

C. Google Fonts

The Google Fonts API is designed to limit the collection, storage, and use of end-user data to only what is needed to serve fonts efficiently. The use of the Google Fonts Web API is unauthenticated and the Google Fonts API does not set or log Cookies. Requests to the Google Fonts Web API are made to resource-specific domains, such as fonts.googleapis.com or fonts.gstatic.com. Font requests are separate from and do not contain any credentials sent to google.com while using other Google services that are authenticated, such as Gmail.

For more information on the privacy practices of Google, please visit the Google Fonts Privacy and Data Collection web page: https://developers.google.com/fonts/faq/privacy

D. Google Tag Manager

Google Tag Manager is a tag management system (TMS) that allows Website owners to update measurement codes and related code fragments, collectively known as “tags”, on websites or mobile apps. TMS also allows Us to communicate with the Tag Manager servers to safely and easily deploy analytics and measurement tag configurations from a web-based user interface.

For more information on Google’s use of Google Tag Manager data please visit their terms of service located at https://www.google.com/analytics/terms/tag-manager/

IX. THE GENERAL DATA PROTECTION REGULATION AND RECRUITMENT DATA

A. The General Data Protection Regulation: Purpose

The General Data Protection Regulation (“GDPR”) is a European Union (EU) data privacy law which became effective on May 25, 2018. The GDPR is designed to protect personal data of people in the European Union, regardless of where their data is collected, used, or stored. The GDPR applies to individuals and business entities outside the EU where they: (1) offer goods or services to people in the EU or (2) monitor the online behavior of people in the EU. In connection with the collection and retention of Recruitment Data by the Company or third-parties on behalf of the Company (i.e., Pinpoint), the Company is a data “controller” as defined in the GDPR and subject to its provisions. See GDPR Article 4.

The full text of the GDPR can be found at https://gdpr-info.eu.

B. Pinpoint and Recruitment Data

Pinpoint serves as a “data processor” for the Company, as defined in Article 4 of the GDPR to, inter alia: (1) process Recruitment Data (see Privacy Statement Section II (A)(3) above) and (2) link data You provide Us with other publicly available information about You that You have published on the Internet including, but not limited to, information You provide on sources such as LinkedIn and other social media profiles.

C. Lawful Use of Recruitment Data

The Company relies on Our legitimate interests in recruitment and hiring as the lawful basis for Our collection and use of Recruitment Data. See GDPR, Article 6. More specifically, We use Recruitment Data to serve a number of legitimate interests, including, but not limited to:

Consider Your application for the position for which You have applied;
Consider Your application for other open positions at the Company;
Communicate with You in the recruitment process;
Compare and/or enhance information We receive from You with information obtained from third party data providers;
Find qualified candidates to fill Our job openings; and
Help Pinpoint improve their service.

D. Security of Recruitment Data

The transmission of any information via the internet is never completely secure. Although We will do our best to protect Your Recruitment Data, We cannot guarantee the security of your data transmitted through any online means, therefore, any transmission remains at your own risk.

However, We take appropriate measures to ensure that Recruitment Data is secure and We limit access to Recruitment Data to those who have a genuine business need to view it. Those processing Your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify You and any applicable regulator of a suspected data security breach where We are legally required to do so.

E. Storage and Transfer of Recruitment Data

Pinpoint may transfer and store Your Recruitment Data at one of several data center locations in Amsterdam (Netherlands) and it may be synchronized to one of several data center locations in London (United Kingdom) for backup and redundancy purposes. By submitting Your personal data in connection with Our recruitment process, You agree to the transfer, storing and processing of Your Recruitment Data.

Recruitment Data is maintained for 48 months from the time of Your application. You can delete Your Recruitment Data from the Pinpoint service by following the procedure included on the Pinpoint webpage. The Pinpoint webpage can be accessed through the Manage Your Data tool on Our Website.

F. Your Rights Under the GDPR

You have a number of important rights under the GDPR, including, but not limited to:

Access to Your personal data and to certain other supplementary information;
Require Us to correct any mistakes in Your information which We hold;
Request deletion of personal data concerning You in certain situations;
Request access to personal data concerning You which You have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations;
Object, at any time, to processing of personal data concerning You for direct marketing;
Object to automated decisions which produce legal effects concerning You;
Object to Our continued processing of Your personal data;
Otherwise restrict Our processing of Your personal data in certain circumstances;
Claim compensation for damages caused by Our breach of any data protection laws;
Any other rights set forth in GDPR.

To exercise any of those rights, You should:

Utilize the Manage Your Data tool on Our Service which will direct you to Pinpoint or
Contact Us via email at info@royomartin.com with sufficient information for Us to: (1) identify You and (2) understand the subject matter of Your request.

Without prejudice to any other administrative or judicial remedy, the GDPR also permits every “data subject,” as defined in the GDPR, the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation. See GDPR Article 77 and 78 for that process.

X. CHILDREN'S PRIVACY

We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us and we will take steps to attempt to remove the shared information. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We will take steps to attempt to remove that information from Our servers.

XI. LINKS TO OTHER WEBSITES

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to the third party site. We strongly advise You to review the Privacy Statement of every third party site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

XII. CHANGES TO PRIVACY STATEMENT

Any changes to this Privacy Statement after the effective date of July 1, 2023 will be posted on our Website. We will notify You of any Changes by posting the revised Privacy Statement on the Website with a new “Last Updated” date appearing prominently at the top. Changes to the Privacy Statement are effective when they are posted on our Website.

XIII. CONTACT US

If you have any questions about the Privacy Statement, You can contact us by sending an email to info@royomartin.com.