1. Scope

This Privacy Policy describes how ROI Technology Inc. (“ROI”) collects, uses, and protects personal information in connection with its website, services, and client relationships. This Privacy Policy is incorporated by reference into, and governed by, the Master Services Agreement (“MSA”).

2. Information Collected

ROI collects only the minimum personal information reasonably necessary to operate the website, deliver contracted services, and comply with applicable laws. This may include:

Contact information provided voluntarily by visitors or clients (e.g., name, email, phone).
Technical information automatically collected by browsers and servers (e.g., IP address, device type, cookies, analytics data).
Information provided in forms, chats, or communications with ROI.

ROI does not actively collect sensitive categories of personal data unless required for service delivery or legal compliance.

3. Use of Information

ROI may use personal and technical information collected through any lawful means for the following purposes:

Providing, operating, and supporting services;
Conducting internal analytics, monitoring, and reporting;
Improving, enhancing, and developing new services;
Communicating with clients and prospective clients; and
Complying with contractual, legal, and regulatory obligations.

ROI may use cookies, tracking technologies, log files, or any other technical means to collect such information. ROI does not sell personal information to third parties. All information collected is used internally or with trusted vendors under NDA solely for ROI’s business purposes.

ROI does not disclose personal information to third parties except:

As necessary to perform contracted services (e.g., trusted vendors under NDA);
As required by law, subpoena, or legal process;
As expressly authorized by the individual.

ROI contracts include nondisclosure obligations protecting client information.

5. Data Retention

ROI retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy or as required by applicable law or regulation. ROI may retain de-identified or aggregated data without limitation.

6. Rights

Subject to applicable law, individuals may request access to, correction of, or deletion of their personal information by contacting ROI at [email protected]. ROI will respond as required by law and reserves the right to deny requests not mandated by law.

ROI does not sell personal information. California residents can learn more about their rights under the CCPA at oag.ca.gov/privacy/ccpa.

7. Cookies & Analytics

ROI reserves the right to use cookies, pixels, log files, device fingerprinting, and any other tracking or analytics technologies to monitor website usage, service interaction, and network activity. Such technologies may collect technical, behavioral, and network-related information about visitors and users.

For general visitors to ROI’s public website, certain browser or device settings may allow the restriction or blocking of some tracking technologies, though doing so may impair website functionality. ROI makes no guarantee of full functionality if such technologies are disabled.

For active ROI clients: Any traffic originating from client-owned devices, client networks, or client employees’ home networks when accessing ROI services is subject to tracking and monitoring without opt-out. Such tracking is integral to service delivery, operational security, and compliance. By engaging ROI services, clients and their users consent to such monitoring as a condition of service.

For active ROI clients, any tracking and monitoring is further governed by Section 28 (Monitoring and Tracking) of the Master Service Agreement (MSA).

All tracking and analytics information is used exclusively for ROI’s internal purposes, including analytics, service delivery, security, and service improvement. ROI does not sell such information to third parties. ROI may share data only with trusted vendors under NDA and solely for ROI’s business purposes.

8. Limitation of Liability

ROI provides its website and services “as is” with respect to privacy. ROI disclaims all liability for actions of third-party services or integrations. To the fullest extent permitted by law, ROI’s liability related to personal information is limited in accordance with Section 17 of the MSA (Limitation of Liability).

9. Changes

ROI may update this Privacy Policy at any time. Continued use of ROI’s website or services constitutes acceptance of any revised Privacy Policy.

10. Disclaimer

ROI provides its services and this Privacy Policy on an “as is” and “as available” basis. ROI makes no representation or warranty that personal information will never be accessed, disclosed, altered, or destroyed except as required by law. To the fullest extent permitted by law, ROI disclaims all warranties, express or implied, relating to privacy and data security.

11. Governing Law

This Privacy Policy shall be governed by and construed under the laws of the State of Washington, without regard to its conflict of law principles, and any disputes shall be resolved in accordance with the dispute resolution provisions of the Master Service Agreement (MSA).

12. Reservation of Rights

ROI reserves all rights to collect, use, retain, and process information to the fullest extent permitted by applicable law. Nothing in this Privacy Policy is intended to limit ROI’s rights except as expressly stated herein.

13. Relationship to MSA

In the event of any conflict between this Privacy Policy and the Master Service Agreement, the terms of the Master Service Agreement shall control. ROI reserves the right to interpret and amend this Privacy Policy in its sole discretion, subject only to applicable law.

14. Client and User Responsibilities

Clients and users remain solely responsible for safeguarding their own devices, accounts, credentials, and network access. ROI is not responsible for unauthorized access or disclosure of information resulting from a client’s or user’s failure to secure their own systems, passwords, or personnel.

15. Data Security and Breach Notification

ROI maintains reasonable administrative, technical, and physical safeguards designed to protect personal information. However, ROI does not guarantee absolute security. ROI shall have no liability for unauthorized access, disclosure, or loss of personal information caused by factors outside its reasonable control, including but not limited to client negligence, third-party service providers, or zero-day vulnerabilities. ROI will provide legally required breach notifications, if any, in the manner and timeframe required by applicable law.

16. Severability

If any provision of this Privacy Policy is held to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

17. Entire Agreement

This Privacy Policy, together with the Master Service Agreement, constitutes the entire agreement between ROI and any client or user regarding the collection, use, and protection of personal information. It supersedes all prior or contemporaneous statements, agreements, or understandings, whether written or oral, relating to its subject matter.

18. Assignment

In the event of a merger, acquisition, corporate reorganization, sale of assets, or other business transaction involving ROI, personal information may be transferred as part of such transaction. Any successor or assign of ROI shall be permitted to continue using such information in accordance with this Privacy Policy. Clients and users have no right to block, veto, or limit the transfer or continued use of information in connection with any such transaction.

Privacy Policy