The Rose Group Privacy and Cookie Statement
This Privacy and Cookie Statement (“Statement”) applies to and The Rose Group services, owned and operated by The Rose Group. (“Rose Group”). Protecting Your privacy and the protection of Your Personal Information is very important to The Rose Group. For purposes of this Statement, “Personal Information” is any information that can be used on its own or with other information to identify, contact, or locate an individual, or to identify an individual in context. Here You will find what Personal Information we collect, why we collect it, and what we do with it, and services offered by The Rose Group (“The Rose Group Services”). It also describes the choices available to You regarding the use of, Your access to, and how to update and correct Your Personal Information (defined below). The Rose Group is committed to protecting the privacy and accuracy of the information we collect about You, including Your Personal Information, to the fullest extent possible.

This Privacy and Cookie Statement is revised as of January 28, 2020.

Collection and Use of Personal Information and Non-Personally Identifiable Information
You may be asked to provide Personal Information when You use The Rose Group Services.
Your Personal Information That We Collect From You:
The Rose Group may collect from You the following Personal Information in connection with Your use of The Rose

Group Services:
• Email address and password during account creation.
• Any additional information that You add manually to The Rose Group Services, including answers to surveys and questionnaires, and preferences.
• Internet Protocol (“IP”) address.
• User behavior based upon click stream history or contained in log files (e.g., IP address, browser versions, OS versions, internet service provider “ISP” information, time of day of website use, surfing and viewing habits) of how users are using The Rose Group website and which pages the users have visited.

The Rose Group may also collect certain non-personally identifiable information relating to You and/or Your use of The Rose Group Services (“Non-Personally Identifiable Information”), including aggregated, anonymized information concerning Your use of The Rose Group Services. For example, The Rose Group may collect Non-Personally Identifiable Information regarding the pages and services that You access through The Rose Group Services, and information concerning the browser(s) and Internet platform service provider(s) used to access The Rose Group Services. For more information, see Use of De-Identified Information and Aggregated User Data below.

How We Use the Personal Information We Collect:
The Rose Group’s use Your Personal Information:
• to administer, monitor and moderate The Rose Group Services.
• to direct You to programs, actions, contents and events that are most relevant and helpful to You
• to implement and provide You with The Rose Group Services customized to Your needs.
• to send important notices or other communications to You from time to time.
• to update terms, conditions, and policies.
• for internal purposes such as auditing, data analysis and research, to improve our content and advertising, and to develop, deliver, understand performance, and improve The Rose Group Services, customer communications, internal market research, project planning, troubleshooting problems, and to detect and protect against error, fraud or other criminal activity.
• to administer any promotions or other activities that You are involved in using The Rose Group Services.
• to create aggregated anonymous analytical data.

We may also disclose Your Personal Information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect Your safety or the safety of others, investigate fraud, or respond to a government request. Your Personal Information could be transferred to or acquired by a third-party in the event of a The Rose Group merger or acquisition. You will be notified via email and/or a prominent notice on the Site, of any change in ownership, uses of Your Personal Information, and choices You may have regarding Your Personal Information. We may also disclose Your Personal Information to any other third-party with Your prior consent. User Access and Choice

If Your Personal Information changes, or if You no longer desire our The Rose Group Services, You may correct, update, amend, delete/remove, ask to have it removed from a public forum, directory or testimonial on our Site or deactivate it by making the change on our member information page or by emailing our Customer Support at We will respond to Your request within a reasonable timeframe.
We will retain Your information for as long as Your account is active or as needed to provide You The Rose Group Services. We will retain and use Your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How The Rose Group Uses Cookies and Other Tracking Technologies
We, The Rose Group and analytics providers use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the Site, track users’ movements around the Site, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

When You visit a website, its server may generate a piece of text known as a “cookie” to place on Your computer. The cookie allows the server to “remember” specific information about Your visit while You are connected. The cookie makes it easier for You to use the dynamic features of web pages. Persistent cookies remain on Your phone, tablet or computing device after You log off from a website, close Your browser, or close the applicable app. Session cookies are deleted from Your phone, tablet or other computing device when You log off a website, close Your browser, and/or close Your browser or the applicable app. Cookies from The Rose Group web pages collect only information about Your browser’s visit to the Site. The Rose Group does not use cookies to collect Personal Information.

The Rose Group uses cookies to collect information about Your browser’s visit to the Site. The Rose Group uses persistent cookies to save Your registration ID and login password for future logins to the Site. The Rose Group uses session cookies to better understand how You interact with the Site, and to monitor aggregate usage by customers of the Site and web traffic routing on the Site. If You do not accept cookies, however, You may not be able to use all portions or all functionality of the Site.

We may also occasionally use “web beacons” (also known as “clear gifs,” “web bugs,” “1-pixel gifs,” etc.) that allow us to collect Non-Personally Identifiable Information about Your response to our email communications, and for other purposes. Web beacons are tiny images, placed on a web page or e-mail that can tell us if You have visited a particular area of the Site. For example, if You have given us permission to send You emails, we may send You an email urging You to use a certain feature of the Site. If You do respond to that email and use that feature, the web beacon will tell us that our email communication with You has been successful. Because web beacons are used in conjunction with persistent cookies (described above), if You set Your browser to decline or deactivate cookies, web beacons cannot function.
Internet Protocol (“IP”) Address

We collect the IP address of all visitors to our website. An IP address is a number that is automatically assigned to Your computer when You use the Internet. We use IP addresses to help us diagnose problems with our server, administer our website, analyze trends, and gather broad demographic information for aggregate use to improve our site, and deliver customized, personalized content. IP addresses are not linked to Personal Information. As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about You. We do this to improve services we offer You, to improve marketing, analytics, or site functionality.

We use local storage, such as HTML5, to store content information and preferences. Third-parties with whom we partner to provide certain features on Site or to display advertising based upon Your web browsing activity also use flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

California Do Not Track Disclosures
Our websites and web portals are not configured to respond to do-not-track settings in Your browser.

How The Rose Group uses email
We may use a third-party vendor to help us manage some of our email communications with You. Although we may supply this vendor with email addresses of those we wish them to contact, Your email address is never used for any purpose other than to communicate with You on our behalf. When You click on a link in an email, You may temporarily be redirected through one of the vendor’s servers (although this process will be invisible to You) which will register that You have clicked on that link, and have visited our The Rose Group Services. We never share any information, other than Your email address, with our third-party email vendor, which does not share these email addresses with anyone else. You may opt-out at any time by clicking on the Unsubscribe link at the bottom of these emails.

User Profiles and Submissions
Certain user profile information, including Your name, location, and any video or image content that YOU upload to The Rose Group Services may be displayed to other users to facilitate user interaction within The Rose Group Services. You may limit the profile information that can be seen by others by adjusting Your account privacy settings. Please remember that any content You upload to Your public user profile, along with any Personal Information or content that You voluntarily disclose online in a manner other users can view (on discussion boards and in messages, etc.) becomes publicly available, and can be collected and used by others. The Rose Group reserves the right to delete any comments it deems inappropriate, at The Rose Group’s sole discretion. Your username may also be displayed to other users if and when You send messages or comments through The Rose Group Services, and other users can contact You through messages and comments.

Social Media Widgets
Our Site includes “Social Media Features” such as the Facebook ‘Like’ button, and “Widgets” such as the ‘Share This’ button or interactive mini-programs that run on the Site. These features may collect Your IP address, which page You are visiting on the Site, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third-party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the company providing it.

Our Commitment to Children’s Privacy
Protecting the privacy of children is very important to us. The Children’s Online Privacy and Protection Act of 1998 (“COPPA”) defines a “Child” as anyone under the age of 13. The Rose Group strictly adheres to COPPA. For that reason, we do not collect or maintain information obtained through The Rose Group Services from those we actually know are under 13, and no part of our Site is structured to attract anyone under 13.

Your account is protected by a password for Your privacy and security. You must prevent unauthorized access to Your account and Personal Information by selecting and protecting Your password and/or other sign-on mechanism appropriately and limiting access to Your computer or device and browser by signing off after You have finished accessing Your account.

We endeavor to protect the privacy of Your account and other Personal Information we hold in our records. We employ SSL to encrypt communications between our servers and client applications and do our best to protect our systems so third-parties can’t access Your private information. However, we cannot guarantee complete security — unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

You may direct questions, complaints or claims regarding The Rose Group Services to
Our Statement may change from time to time. We will not reduce Your rights under this Statement without Your explicit consent. We will post any privacy statement changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy statement changes). We will also keep prior versions of this Statement in an archive for Your review.