PRIVACY POLICY

Last updated May 29, 2024

This privacy notice for Rome Labs ("we," "us," or "our"), describes how and why we

might collect, store, use, and/or share ("process") your information when you use our

services ("Services"), such as when you:

  • Download and use our mobile application (Rome AI), or any other application

of ours that links to this privacy notice

  • Engage with us in other related ways, including any sales, marketing, or

Events



Questions or concerns? Reading this privacy notice will help you understand your

privacy rights and choices. If you do not agree with our policies and practices, please

do not use our Services. If you still have any questions or concerns, please contact

us at daryl@romelabs.co



SUMMARY OF KEY POINTS



This summary provides key points from our privacy notice, but you can find

out more details about any of these topics by clicking the link following each

key point or by using our table of contents below to find the section you are

looking for.



What personal information do we process? When you visit, use, or navigate our

Services, we may process personal information depending on how you interact with

us and the Services, the choices you make, and the products and features you use.

Learn more about personal information you disclose to us.



Do we process any sensitive personal information? We do not process sensitive

personal information.



Do we receive any information from third parties? We do not receive any

information from third parties.



How do we process your information? We process your information to provide,

improve, and administer our Services, communicate with you, for security and fraud

prevention, and to comply with law. We may also process your information for other

purposes with your consent. We process your information only when we have a valid

legal reason to do so. Learn more about how we process your information.



In what situations and with which parties do we share personal information?

We may share information in specific situations and with specific third parties. Learn

more about when and with whom we share your personal information.



What are your rights? Depending on where you are located geographically, the

applicable privacy law may mean you have certain rights regarding your personal

information. Learn more about your privacy rights.



How do you exercise your rights? The easiest way to exercise your rights is by

submitting a data subject access request, or by contacting us. We will consider and

act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the

privacy notice in full.



TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL

INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. WHAT ARE YOUR PRIVACY RIGHTS?

7. CONTROLS FOR DO-NOT-TRACK FEATURES

8. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

9. DO WE MAKE UPDATES TO THIS NOTICE?

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT

FROM YOU?



1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express

an interest in obtaining information about us or our products and Services, when you

participate in activities on the Services, or otherwise when you contact us.

Sensitive Information. We do not process sensitive information.

Application Data. If you use our application(s), we also may collect the following

information if you choose to provide us with access or permission:

Push Notifications. We may request to send you push notifications regarding

your account or certain features of the application(s). If you wish to opt out

from receiving these types of communications, you may turn them off in your

device's settings.

This information is primarily needed to maintain the security and operation of our

application(s), for troubleshooting, and for our internal analytics and reporting

purposes.

All personal information that you provide to us must be true, complete, and accurate,

and you must notify us of any changes to such personal information.



2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our

Services, communicate with you, for security and fraud prevention, and to comply

with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on

how you interact with our Services, including:

To save or protect an individual's vital interest. We may process your

information when necessary to save or protect an individual’s vital interest,

such as to prevent harm.5/29/24, 11:06 AM Termly

https://app.termly.io/dashboard/website/d2a6b4d5-8cb2-4551-85d9-f8cc8e95cac4/privacy-policy 3/11



3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS

YOUR INFORMATION?



In Short: We only process your personal information when we believe it is necessary

and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like

with your consent, to comply with laws, to provide you with services to enter into or

fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate

business interests.



If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain

the valid legal bases we rely on in order to process your personal information. As

such, we may rely on the following legal bases to process your personal information:



Consent. We may process your information if you have given us permission

(i.e., consent) to use your personal information for a specific purpose. You can

withdraw your consent at any time. Learn more about withdrawing your

consent.



Legal Obligations. We may process your information where we believe it is

necessary for compliance with our legal obligations, such as to cooperate with

a law enforcement body or regulatory agency, exercise or defend our legal

rights, or disclose your information as evidence in litigation in which we are

involved.



Vital Interests. We may process your information where we believe it is

necessary to protect your vital interests or the vital interests of a third party,

such as situations involving potential threats to the safety of any person.



If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e.,

express consent) to use your personal information for a specific purpose, or in

situations where your permission can be inferred (i.e., implied consent). You

can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to

process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be

obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to

assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next

of kin

If we have reasonable grounds to believe an individual has been, is, or may be

victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise

the availability or the accuracy of the information and the collection is

reasonable for purposes related to investigating a breach of an agreement or a

contravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or

rules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business,

or profession and the collection is consistent with the purposes for which the

information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations5/29/24, 11:06 AM Termly

https://app.termly.io/dashboard/website/d2a6b4d5-8cb2-4551-85d9-f8cc8e95cac4/privacy-policy 4/11



4. WHEN AND WITH WHOM DO WE SHARE YOUR

PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section

and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection

with, or during negotiations of, any merger, sale of company assets, financing,

or acquisition of all or a portion of our business to another company.



5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes

outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the

purposes set out in this privacy notice, unless a longer retention period is required or

permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal

information, we will either delete or anonymize such information, or, if this is not

possible (for example, because your personal information has been stored in backup

archives), then we will securely store your personal information and isolate it from

any further processing until deletion is possible.



6. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United

Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater

access to and control over your personal information. You may review, change, or

terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain

rights under applicable data protection laws. These may include the right (i) to

request access and obtain a copy of your personal information, (ii) to request

rectification or erasure; (iii) to restrict the processing of your personal information; (iv)

if applicable, to data portability; and (v) not to be subject to automated decision-

making. In certain circumstances, you may also have the right to object to the

processing of your personal information. You can make such a request by contacting

us by using the contact details provided in the section "HOW CAN YOU CONTACT

US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data

protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing

your personal information, you also have the right to complain to your Member State

data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and

Information Commissioner.



Withdrawing your consent: If we are relying on your consent to process your

personal information, which may be express and/or implied consent depending on

the applicable law, you have the right to withdraw your consent at any time. You can

withdraw your consent at any time by contacting us by using the contact details

provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

below.

However, please note that this will not affect the lawfulness of the processing before

its withdrawal nor, when applicable law allows, will it affect the processing of your

personal information conducted in reliance on lawful processing grounds other than

consent.



Opting out of marketing and promotional communications: You can unsubscribe

from our marketing and promotional communications at any time by clicking on the

unsubscribe link in the emails that we send, or by contacting us using the details

provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

below. You will then be removed from the marketing lists. However, we may still

communicate with you — for example, to send you service-related messages that are

necessary for the administration and use of your account, to respond to service

requests, or for other non-marketing purposes.

If you have questions or comments about your privacy rights, you may email us at

darylab17@gmail.com.



7. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications

include a Do-Not-Track ("DNT") feature or setting you can activate to signal your

privacy preference not to have data about your online browsing activities monitored

and collected. At this stage no uniform technology standard for recognizing and

implementing DNT signals has been finalized. As such, we do not currently respond

to DNT browser signals or any other mechanism that automatically communicates

your choice not to be tracked online. If a standard for online tracking is adopted that

we must follow in the future, we will inform you about that practice in a revised

version of this privacy notice.



8. DO UNITED STATES RESIDENTS HAVE SPECIFIC

PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia,

you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect? We collect email addresses.



We have NOT collected the following categories of personal information in the past twelve

(12) months:



Category Examples Collected

A. Identifiers

Contact details, such as real name, alias,

postal address, telephone or mobile

contact number, unique personal identifier,

online identifier, Internet Protocol address,

email address, and account name



B. Personal information as

defined in the California

Customer Records statute

Name, contact information, education,

employment, employment history, and

financial information



C. Protected classification

characteristics under state

or federal law

Gender and date of birth 



D. Commercial information

Transaction information, purchase history,

financial details, and payment information



E. Biometric information Fingerprints and voiceprints 



F. Internet or other similar

network activity

Browsing history, search history, online

behavior, interest data, and interactions

with our and other websites, applications,

systems, and advertisements



G. Geolocation data Device location



H. Audio, electronic, visual,

thermal, olfactory, or similar

Images and audio, video or call recordings

created in connection with our business information activities



I. Professional or

employment-related

information

Business contact details in order to

provide you our Services at a business

level or job title, work history, and

professional qualifications if you apply for

a job with us



J. Education Information Student records and directory information 



K. Inferences drawn from

collected personal

information

Inferences drawn from any of the collected

personal information listed above to create

a profile or summary about, for example,

an individual’s preferences and

characteristics



L. Sensitive personal

Information 



We may collect other personal information outside of these categories through

instances where you interact with us in person, online, or by phone or mail in the

context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, "HOW DO WE

PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a

written contract between us and each service provider. Learn more about how we

disclose personal information to in the section, "WHEN AND WITH WHOM DO WE

SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for

undertaking internal research for technological development and demonstration. This

is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a

business or commercial purpose in the preceding twelve (12) months. We will not sell

or share personal information in the future belonging to website visitors, users, and

other consumers.



California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law

permits our users who are California residents to request and obtain from us, once a

year and free of charge, information about categories of personal information (if any)

we disclosed to third parties for direct marketing purposes and the names and

addresses of all third parties with which we shared personal information in the

immediately preceding calendar year. If you are a California resident and would like

to make such a request, please submit your request in writing to us using the contact

information provided below.

If you are under 18 years of age, reside in California, and have a registered account

with the Services, you have the right to request removal of unwanted data that you

publicly post on the Services. To request removal of such data, please contact us

using the contact information provided below and include the email address

associated with your account and a statement that you reside in California. We will

make sure the data is not publicly displayed on the Services, but please be aware

that the data may not be completely or comprehensively removed from all our

systems (e.g., backups, etc.).5/29/24,



CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer

Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a "residents" as:

(1) every individual who is in the State of California for other than a temporary or

transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the

State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and

obligations regarding your personal information.



Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your

personal information, we will respect your request and delete your personal

information, subject to certain exceptions provided by law, such as (but not limited to)

the exercise by another consumer of his or her right to free speech, our compliance

requirements resulting from a legal obligation, or any processing that may be

required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell or share personal information to third parties;

the categories of personal information that we sold, shared, or disclosed for a

business purpose;

the categories of third parties to whom the personal information was sold,

shared, or disclosed for a business purpose;

the business or commercial purpose for collecting, selling, or sharing personal

information; and

the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete

consumer information that is de-identified in response to a consumer request or to re-

identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are

the same person about whom we have the information in our system. These

verification efforts require us to ask you to provide information so that we can match it

with information you have previously provided us. For instance, depending on the

type of request you submit, we may ask you to provide certain information so that we

can match the information you provide with the information we already have on file,

or we may contact you through a communication method (e.g., phone or email) that

you have previously provided to us. We may also use other verification methods as

the circumstances dictate.

We will only use personal information provided in your request to verify your identity

or authority to make the request. To the extent possible, we will avoid requesting

additional information from you for the purposes of verification. However, if we cannot

verify your identity from the information already maintained by us, we may request

that you provide additional information for the purposes of verifying your identity and

for security or fraud-prevention purposes. We will delete such additionally provided

information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer

relevant, or ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on

your behalf. We may deny a request from an authorized agent that does not

submit proof that they have been validly authorized to act on your behalf in

accordance with the CCPA.

You may request to opt out from future selling or sharing of your personal

information to third parties. Upon receiving an opt-out request, we will act upon

the request as soon as feasibly possible, but no later than fifteen (15) days

from the date of the request submission.

To exercise these rights, you can contact us by submitting a data subject access

request, or by referring to the contact details at the bottom of this document. If you

have a complaint about how we handle your data, we would like to hear from you.



Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act

(CPA), you have the rights listed below. However, these rights are not absolute, and

in certain cases, we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted

advertising, the sale of personal data, or profiling in furtherance of decisions

that produce legal or similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email

darylab17@gmail.com or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our

decision, please email us at darylab17@gmail.com. Within forty-five (45) days of

receipt of an appeal, we will inform you in writing of any action taken or not taken in

response to the appeal, including a written explanation of the reasons for the

decisions.



Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data

Privacy Act (CTDPA), you have the rights listed below. However, these rights are not

absolute, and in certain cases, we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data5/29/24, 11:06 AM Termly

https://app.termly.io/dashboard/website/d2a6b4d5-8cb2-4551-85d9-f8cc8e95cac4/privacy-policy 9/11

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted

advertising, the sale of personal data, or profiling in furtherance of decisions

that produce legal or similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email

darylab17@gmail.com or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our

decision, please email us at darylab17@gmail.com. Within sixty (60) days of receipt

of an appeal, we will inform you in writing of any action taken or not taken in

response to the appeal, including a written explanation of the reasons for the

decisions.



Utah Residents

This section applies only to Utah residents. Under the Utah Consumer Privacy Act

(UCPA), you have the rights listed below. However, these rights are not absolute, and

in certain cases, we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted

advertising or the sale of personal data

To submit a request to exercise these rights described above, please email

darylab17@gmail.com or submit a data subject access request.



Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting

only in an individual or household context. It does not include a natural person acting

in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an

identified or identifiable natural person. "Personal data" does not include de-identified

data or publicly available information.

"Sale of personal data" means the exchange of personal data for monetary

consideration.

If this definition of "consumer" applies to you, we must adhere to certain rights and

obligations regarding your personal data.

Your rights with respect to your personal data

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted

advertising, the sale of personal data, or profiling in furtherance of decisions

that produce legal or similarly significant effects ("profiling")5/29/24, 11:06 AM Termly

https://app.termly.io/dashboard/website/d2a6b4d5-8cb2-4551-85d9-f8cc8e95cac4/privacy-policy 10/11

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at darylab17@gmail.com or submit a data subject

access request.

If you are using an authorized agent to exercise your rights, we may deny a request if

the authorized agent does not submit proof that they have been validly authorized to

act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to

verify you and your consumer's request. If you submit the request through an

authorized agent, we may need to collect additional information to verify your identity

before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases,

within forty-five (45) days of receipt. The response period may be extended once by

forty-five (45) additional days when reasonably necessary. We will inform you of any

such extension within the initial 45-day response period, together with the reason for

the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision

and reasoning behind it. If you wish to appeal our decision, please email us at

darylab17@gmail.com. Within sixty (60) days of receipt of an appeal, we will inform

you in writing of any action taken or not taken in response to the appeal, including a

written explanation of the reasons for the decisions. If your appeal is denied, you may

contact the Attorney General to submit a complaint.



9. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant

laws.

We may update this privacy notice from time to time. The updated version will be

indicated by an updated "Revised" date and the updated version will be effective as

soon as it is accessible. If we make material changes to this privacy notice, we may

notify you either by prominently posting a notice of such changes or by directly

sending you a notification. We encourage you to review this privacy notice frequently

to be informed of how we are protecting your information.



10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at

darylab17@gmail.com or contact us by post at:

Rome Labs

555 San Antonio Rd

Mountain View, CA 94040

United States



11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE

DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request

access to the personal information we collect from you, change that information, or

delete it. To request to review, update, or delete your personal information, please fill

out and submit a data subject access request.