Información legal.

These Terms of Use (the “Terms”) govern access to and use of the website located at roicè.com and any related microsites, landing pages, portals, forms, investor pages, transaction pages, restricted areas, subdomains, digital interfaces or online services operated by, on behalf of, or for the benefit of Roicè (together, the “Site”).

The Site is operated by Roicè Consolidated AM Limited, a private company incorporated in Ireland with registered office at 6 Fern Road, Sandyford Business Park, Dublin D18 FP98, Ireland (“Roicè”, “we”, “us”, “our”). Services are contracted only with the entity named in the relevant definitive agreement, which may be Roicè Consolidated AM Limited or EFI Capital USA LLC, a private company (company number 93-20360), 704 N. King Street Suite 500, Wilmington, Delaware, USA. EFI Capital USA LLC does not operate the Site.

By accessing or using the Site, you agree to be bound by these Terms. If you do not agree, you must not use the Site.

1. Changes to These Terms

We may amend these Terms at any time by posting an updated version on the Site. The version in force at the time of your use will apply.

2. Nature of the Site

The Site is provided for general informational, relationship, screening, diligence, communications, operational and security purposes only.

Unless expressly agreed by Roicè in writing:

• nothing on the Site constitutes legal, tax, regulatory, accounting, investment, banking or other professional advice;
• nothing on the Site constitutes an offer, commitment, undertaking, guarantee, invitation, inducement, recommendation or solicitation capable of acceptance;
• no fiduciary, advisory, banking, brokerage, client, mandate, transactional or other formal relationship is created merely by visiting or using the Site, submitting an enquiry, downloading materials, or communicating through the Site;
• no transaction, participation, investment, financing, co-investment, joint venture, sale, acquisition, mandate or service engagement shall arise except under definitive written documentation signed or otherwise formally accepted by Roicè.

3. Eligibility and Lawful Use

You represent and warrant that:

• you have full legal capacity and authority to accept these Terms;
• you will use the Site only for lawful purposes;
• you will not use the Site if such use is prohibited by any law or regulation applicable to you;
• any information you provide to Roicè through the Site is accurate, complete and not misleading;
• you will comply with all applicable laws relating to anti-money laundering, sanctions, anti-bribery, data protection, cybersecurity, export controls, market abuse, unfair competition and commercial conduct.

4. No Reliance

The content of the Site is not intended to be relied upon as the basis for any decision, including any investment, legal, tax, structuring, financing, acquisition, disposition, co-investment, joint venture or other commercial decision.

Any person considering any relationship, transaction or opportunity involving Roicè, including through Roicè Corporate Service or Transactional Services, must rely solely on the definitive transaction documents, formal communications, and their own independent professional advisers.

5. Intellectual Property

All rights, title and interest in and to the Site and all content, code, layout, structure, design, graphics, logos, brand assets, trademarks, service marks, text, imagery, audio, video, data compilations, databases, downloadable materials and software forming part of the Site are owned by or licensed to Roicè and are protected by applicable intellectual property and related laws.

Except as strictly necessary for personal, internal and lawful viewing of the Site, you may not, without Roicè’s prior written consent:

• reproduce, republish, distribute, transmit, display, sell, license or exploit the Site or its content;
• scrape, crawl, harvest, mine, index, copy or extract data or content by automated means;
• use Site content to train, fine-tune or validate any artificial intelligence, machine learning or analytics model;
• reverse engineer, decompile, disassemble or attempt to derive the source code of any software or component of the Site;
• remove or alter any proprietary notices or security controls.

6. Permitted Use

You may use the Site only to:

• learn about Roicè and its activities;
• request a private introduction or contact;
• communicate with Roicè through authorised channels;
• access content intentionally made available to you by Roicè.

7. Prohibited Conduct

You must not:

• probe, scan, test or attempt to breach the security, integrity, confidentiality or availability of the Site;
• upload or transmit malware, malicious code, harmful scripts, bots, floods, denial-of-service traffic or any other hostile or disruptive material;
• impersonate any person or entity, misrepresent your affiliation, or conceal the origin or purpose of your access;
• seek unauthorised access to restricted areas, credentials, user accounts, systems, APIs, infrastructure, source materials, logs, communications or data;
• monitor, intercept, capture, exfiltrate or misuse sessions, credentials, cookies, tokens, communications, technical data or proprietary information;
• use the Site for competitive intelligence, benchmarking, surveillance, reverse engineering, commercial copying or any purpose adverse to Roicè;
• use the Site as a vehicle for pressure, disruption, intimidation, extortion, interference, leverage or manipulation in connection with any actual, prospective or contemplated relationship or transaction;
• engage in conduct that is abusive, fraudulent, deceptive, offensive, inappropriate, harassing, defamatory, unlawful or otherwise unacceptable to Roicè.

8. Security Monitoring and Technical Data

To operate, secure and defend the Site and our business, Roicè may monitor, log, collect, correlate, analyse and retain technical, device and security information to the extent permitted by applicable law. The Site does not use analytics, advertising pixels, session-replay or precise-geolocation technologies.

This may include:

• IP addresses;
• device identifiers, browser type, operating system, language and time zone;
• risk signals, anomaly detection indicators, bot signals, session integrity indicators and security logs;
• form activity, response timing, repeat access patterns, and other indicators of intent, misuse, fraud or abnormal behaviour.

Roicè uses only the strictly necessary technologies listed in the Cookie Notice, together with server-side logging, security and fraud-detection tools, for security, performance, abuse prevention and incident response.

Roicè may review and use such information to:

• prevent, investigate and respond to abuse, intrusion, scraping, fraud, cyber threats, interference or misuse;
• protect Roicè, its clients, counterparties, prospective counterparties, personnel, systems, transactions and legal rights.

For data-protection, cookie and tracking requirements, the Site must also be read together with Roicè’s Privacy Notice and Cookie Notice. In the UK and EU, websites can amount to financial promotions and tracking technologies may trigger separate transparency and consent obligations; in the U.S., offering and advertising rules depend on the securities exemption being relied upon. (FCA)

9. Roicè’s Right to Restrict, Suspend or Block Access

Roicè may, at any time, with or without notice where appropriate, restrict, suspend, terminate or block your access to all or any part of the Site if Roicè considers, in its sole but reasonable discretion, that:

• you have breached these Terms;
• your use presents a security, legal, regulatory, reputational or operational risk;
• your conduct is inappropriate, abusive, deceptive, hostile, unlawful or otherwise unacceptable;
• your use is inconsistent with the intended purpose of the Site;
• technical, behavioural or security indicators suggest attempted abuse, scraping, intrusion, fraud, automation, credential misuse, hostile reconnaissance or other improper activity.

Roicè may also invalidate sessions, revoke permissions, block IPs or devices, geoblock access, refuse submissions, preserve evidence and take any other protective or remedial steps it considers appropriate.

10. Materials Submitted Through the Site

Where you submit documents, messages, proposals, diligence materials, personal data, business data or other materials through the Site, you represent and warrant that:

• you are lawfully entitled to provide such materials;
• the materials do not infringe the rights of any person;
• the materials are not misleading, unlawful or malicious.

Roicè may use, review, process, store, internally copy and analyse such materials for communications, diligence, relationship management, transaction screening, risk review, security, legal defence and compliance.

Unless expressly agreed in writing, no submission through the Site creates any confidentiality obligation beyond what is otherwise imposed by law or by an express written agreement.

11. No Offer; No Solicitation; No Financial Promotion; No Public Marketing

11.1 General Website Position

The Site and its contents are not directed at the general public for investment, fundraising or securities distribution purposes and are not intended to constitute:

• an “offer to the public”;
• a “financial promotion” capable of acceptance by the public;
• an “invitation or inducement” to engage in investment activity;
• a “general solicitation” or “general advertising” for securities law purposes;
• a recommendation that any person should subscribe for, acquire, dispose of, participate in or underwrite any security, fund interest, financing, co-investment, note, bond, participation or similar instrument.

Under section 21 FSMA, in the UK a person must not, in the course of business, communicate an invitation or inducement to engage in investment activity unless authorised or the content is approved or exempt; the FCA also states that websites and social media may amount to financial promotions. In the U.S., the SEC states that Rule 506(b) private placements prohibit general solicitation, while Rule 506(c) permits general solicitation only if all purchasers are accredited investors and the issuer takes reasonable verification steps. (legislation.gov.uk)

11.2 REFIL1 and REF — No Solicitation / No Offer Clause

Any reference on the Site to REFIL1, REF, any real estate financing framework, any private structure, any co-investment framework, any private capital transaction, any investment opportunity, any fund-like structure, any vehicle, any issuance, any participation, or any similar arrangement is provided solely for high-level informational and relationship-screening purposes.

Accordingly:

• no such reference constitutes, or shall be construed as, an offer, invitation, inducement, recommendation, financial promotion, solicitation, general solicitation, general advertising, prospectus-equivalent communication, or arrangement with the public;
• no person is invited by reason of the Site alone to subscribe, purchase, invest, lend, commit capital, provide financing, join, co-invest, participate or otherwise enter into any transaction;
• no offer or invitation will be made except, where Roicè so elects, through separate confidential materials, targeted communications, gating, eligibility checks, jurisdictional restrictions, investor qualification processes, disclaimers and definitive legal documentation;
• access to any private transaction, structure or opportunity is subject to suitability, eligibility, jurisdiction, relationship status, legal restrictions, internal approvals and such other conditions as Roicè may determine;
• Roicè reserves the right, at any time and without liability, to decline, discontinue, gate, restrict or withdraw any discussion, process, material or opportunity.

11.3 UK / FSMA Position

To the extent any content on the Site could be characterised under UK law as relating to an investment, controlled activity or controlled investment, such content is directed only at persons to whom it may lawfully be made available, and is not intended to be acted on or relied on by retail persons or by persons to whom such communication may not lawfully be made. Any person who is not a lawful recipient must not act on it.

11.4 U.S. Securities Law Equivalent

To the extent any content on the Site relates to a security or securities offering under U.S. law, such content is not intended to constitute a public offering, public distribution, general solicitation or general advertising, unless Roicè expressly designates otherwise in separate offering materials and proceeds under a legally available pathway. Any actual offering, if made, will be made only pursuant to applicable exemptions, definitive documents, investor qualification requirements, and applicable federal and state law compliance, including any required notice filings or investor-verification requirements. The SEC explains that different exempt offering pathways carry different solicitation rules, including Rules 506(b) and 506(c). (sec.gov)

11.5 No Reliance on Website Statements for Transactions

No person may rely on the Site as the basis for entering into any REFIL1, REF, financing, co-investment, joint venture, sale, acquisition, participation or similar arrangement. Any such transaction shall be governed exclusively by the definitive documents relating to that transaction.

12. Transactional Misuse; Corporate Service Protection Clause

Without prejudice to any other right or remedy, where any person, visitor, user, prospect, counterparty, co-investor, seller, buyer, joint venture participant, funder, adviser, target, bidder or any other person connected with any actual, proposed, contemplated or screened matter involving Roicè Corporate Service, Transactional Services, private capital, co-investment, joint venture, purchase, sale, financing, participation or similar commercial activity:

• seeks to compromise the security, integrity, confidentiality or availability of the Site;
• uses the Site as a vehicle for hostile leverage, pressure, extraction of information, market intelligence, interference, manipulation, disruption, bad-faith negotiation conduct, or any improper purpose;
• engages in conduct which Roicè considers reasonably to be inappropriate, abusive, deceptive, unlawful, hostile or incompatible with a trusted relationship;

then Roicè may immediately, and without prejudice to any of its rights:

1. 1.

   terminate, suspend, reject or refuse to commence or continue any relationship, discussion, diligence exercise, negotiation, mandate, transaction or proposed transaction;

2. 2.

   disqualify the relevant person from any ongoing or future process;

3. 3.

   preserve evidence, logs and records and refer the matter to advisers, insurers, law enforcement or regulators;

4. 4.

   seek injunctive relief, interim relief, specific performance, damages, costs, indemnities and all other legal or equitable remedies;

5. 5.

   where permitted by the definitive documents governing the relevant matter, call, enforce, apply, accelerate, retain or set off any deposit, security, guarantee, collateral, earnest money, escrow, undertaking, indemnity, bond, break fee or similar protection held or agreed in connection with the relevant transaction.

For the avoidance of doubt, any recourse to a deposit, guarantee, security package or similar protection shall be exercised only to the extent permitted by the governing transaction documents and applicable law; however, these Terms expressly reserve Roicè’s fullest right to pursue such remedies where available.

13. No Obligation to Engage

Roicè is under no obligation to accept any enquiry, proposal, opportunity, investor, participant, counterparty, mandate or transaction, and may cease discussions or decline to proceed at any time, subject only to any binding written agreement to the contrary.

14. Security and Availability Disclaimer

Roicè uses reasonable technical, organisational and operational measures to protect the Site. However, no website, system or transmission is completely secure or uninterrupted.

The Site is made available on an “as is” and “as available” basis to the fullest extent permitted by law. Roicè does not guarantee uninterrupted access, error-free operation, invulnerability, compatibility, completeness, accuracy, timeliness or fitness for any particular purpose.

15. Exclusion of Warranties

To the fullest extent permitted by law, Roicè excludes all representations, warranties, conditions and other terms, whether express, implied or statutory, including as to merchantability, satisfactory quality, fitness for purpose, non-infringement, security, availability and results.

16. Limitation of Liability

To the fullest extent permitted by law, Roicè shall not be liable for any indirect, incidental, consequential, special, punitive or exemplary loss or damage, including loss of profits, opportunity, business, reputation, data or anticipated savings, arising out of or in connection with the Site.

Nothing in these Terms excludes or limits liability where such exclusion or limitation is prohibited by law, including liability for fraud or fraudulent misrepresentation, or any other liability that cannot lawfully be excluded.

Subject to the foregoing, Roicè’s aggregate liability arising out of or in connection with the Site shall not exceed the greater of:

• GBP 100; or
• the amount, if any, paid by you specifically for access to the Site in the 12 months preceding the event giving rise to the claim.

17. Indemnity

You shall indemnify and keep indemnified Roicè, its affiliates, officers, employees, advisers, agents and contractors against all losses, damages, claims, liabilities, costs and expenses (including reasonable legal fees) arising out of or in connection with:

• your breach of these Terms;
• your misuse of the Site;
• any materials submitted by you;
• your infringement of any third-party rights;
• your unlawful, fraudulent, abusive or negligent conduct;
• any security event, investigation, claim or proceeding arising from your acts or omissions.

18. Third-Party Links and Services

The Site may contain links to, integrations with, or references to third-party websites, platforms or service providers. Roicè is not responsible for their content, availability, security or practices.

19. Privacy

Use of the Site is also governed by Roicè’s Privacy Notice and Cookie Notice. Those documents explain how Roicè collects and uses personal data, technical data and security-related data.

20. Recordkeeping and Cooperation

Roicè may retain logs, metadata, backups, evidence and communications for security, legal, compliance, audit, dispute-resolution and business-protection purposes.

Roicè may cooperate with courts, regulators, law enforcement, insurers, hosting providers, forensic experts and advisers where reasonably necessary to investigate, prevent or respond to misuse, fraud, unlawful conduct or security incidents.

21. Injunctive Relief

You acknowledge that unauthorised use of the Site or its content may cause irreparable harm to Roicè for which damages alone may not be an adequate remedy. Roicè shall therefore be entitled to seek injunctive, interim, equitable or other urgent relief in any competent court.

22. Governing Law and Jurisdiction

These Terms and any non-contractual obligations arising out of or in connection with them shall be governed by and construed in accordance with the laws of Ireland, without prejudice to any mandatory provisions of the law of your country of residence that apply to you.

The courts of Ireland shall have jurisdiction to settle any dispute arising out of or in connection with these Terms, without prejudice to any mandatory right you may have to bring proceedings in another court, and save that Roicè may seek interim, injunctive or protective relief in any court of competent jurisdiction. Services provided under a separate agreement are governed by the law and jurisdiction set out in that agreement.

23. Severance

If any provision of these Terms is found to be invalid, unlawful or unenforceable, it shall be severed or construed to the minimum extent necessary, and the remainder shall remain in full force and effect.

24. No Waiver

No failure or delay by Roicè in exercising any right or remedy shall operate as a waiver of that right or remedy.

25. Assignment

You may not assign or transfer any of your rights or obligations under these Terms without Roicè’s prior written consent. Roicè may assign or transfer these Terms to any affiliate, successor or acquirer.

26. Contact

Questions concerning these Terms, the Site, privacy or security should be sent to:

Legal (all related matters to this T&C and Roicè itself): legals@roicet.com

This Privacy Notice explains how Roicè Consolidated AM Limited and, where applicable, its affiliates and related entities (“Roicè”, “we”, “us”, “our”) collect, use, disclose, store and otherwise process personal data and related information when you access or use our website, any related microsites, portals, landing pages, forms, investor pages, restricted areas, subdomains or digital interfaces (together, the “Site”), or otherwise interact with us in connection with the Site.

This Privacy Notice should be read together with our Terms of Use and Cookie Notice.

1. Who We Are

The controller responsible for your personal data for the purposes of this Site is:

Roicè Consolidated AM Limited, a private company

Registered office: 6 Fern Road, Sandyford Business Park, Dublin D18 FP98, Ireland. Contact for legal and data-protection matters: legals@roicet.com.

Where another Roicè entity is more directly responsible for a particular relationship, transaction, enquiry or service, that entity may also act as controller or joint controller depending on the circumstances.

2. Scope of This Privacy Notice

This Privacy Notice applies to personal data and related information collected through or in connection with:

• visits to and use of the Site;
• contact forms, enquiry forms and private introduction requests;
• interactions with restricted pages or gated content;
• communications made through the Site;
• security, fraud prevention and site protection activities;
• pre-relationship, relationship-screening, investor-screening, transaction-screening and diligence-related interactions initiated through the Site.

This Privacy Notice does not necessarily apply to data processing governed by a separate privacy notice issued in connection with a specific mandate, client relationship, transaction, employment relationship or investment process.

3. The Information We Collect

Depending on how you interact with the Site, we may collect the following categories of personal data and related information.

3.1 Information You Provide Directly

We may collect:

• your name;
• email address;
• telephone number;
• company, family office, institution or affiliation details;
• job title or role;
• country, city or jurisdiction;
• information contained in any enquiry, form, message or uploaded material;
• records of your communications with us;
• preferences, interests or relationship context you choose to provide.

3.2 Technical and Device Information

We may collect:

• IP address;
• browser type and version;
• device type and identifiers;
• operating system;
• language settings;
• date and time of access;
• time zone;
• referrer URLs;
• network information;
• session identifiers;
• authentication or access-event data where relevant.

3.3 Usage Information

The Site does not use analytics, behavioural-tracking or session-replay tools. Server and security records may register technical events, such as requests, errors and abuse-prevention signals, as described in sections 3.2 and 3.5.

3.4 Location-Related Information

We do not collect precise location data through the Site and do not use location for analytics, profiling or marketing. Technical records such as IP addresses (section 3.2) may indicate an approximate country or region; they are used only to operate and protect the Site.

3.5 Security and Risk Information

We may collect information used for site protection and risk management, including:

• log files;
• security events;
• anomaly indicators;
• bot-detection signals;
• fraud indicators;
• IP reputation and network intelligence indicators;
• device-recognition or session-integrity signals;
• suspicious activity markers;
• evidence and records relating to attempted misuse, scraping, intrusion or abuse.

3.6 Information from Third Parties

We may receive information from:

• hosting and infrastructure providers;
• cybersecurity and fraud-prevention providers;
• CRM, communications or lead-management providers;
• identity, sanctions or screening providers where applicable;
• professional advisers;
• publicly available sources;
• counterparties or introducers, where relevant to an enquiry or proposed relationship.

4. How We Use Your Information

We may use personal data and related information for the following purposes.

4.1 Site Operation and Administration

To operate, maintain, troubleshoot, test, improve and administer the Site and related systems.

4.2 Communications and Relationship Management

To respond to enquiries, process requests, assess whether a contact or introduction is relevant, communicate with you, and manage our interactions with you.

4.3 Site Improvement

To improve the content, performance and design of the Site using technical information such as error and performance records, without analytics or behavioural-tracking tools.

4.4 Security, Fraud Prevention and Abuse Detection

To detect, prevent, investigate and respond to cyber threats, misuse, scraping, fraud, abuse, denial-of-service activity, account compromise, hostile reconnaissance, unauthorised automation, and other behaviour that may threaten the Site, Roicè, our users, our clients, counterparties or transactions.

4.5 Legal, Regulatory and Compliance Purposes

To comply with legal obligations, cooperate with law enforcement, regulators or courts, preserve evidence, establish or defend legal claims, enforce our Terms of Use, and protect our legal and commercial interests.

4.6 Relationship, Transaction and Opportunity Screening

Where relevant, to assess enquiries, requests, submissions, counterparties, introductions, proposals, transaction-related contacts or investment-related communications, including preliminary diligence and internal screening.

4.7 Marketing and Business Development

Where permitted by applicable law, to send updates, communications or relationship-related materials, and to understand whether there may be a business fit. Where consent is required, we will seek it. The ICO notes that privacy notices should explain individuals’ rights, including the right to withdraw consent where consent is the lawful basis. (ico.org.uk)

5. Site Monitoring

We monitor technical and security events to operate and protect the Site, for example request records, rate limiting of the contact form and abuse-prevention signals. We do not profile visitors, track their behaviour across websites or infer their precise location.

If non-essential cookies or tracking technologies are introduced, we will update this Privacy Notice and the Cookie Notice and, where required by law, seek consent before deploying them.

6. Legal Bases for Processing

For individuals in the UK and EEA, we rely on one or more of the following legal bases, depending on the context:

6.1 Legitimate Interests

We process personal data where necessary for our legitimate interests, including:

• operating and improving the Site;
• understanding user engagement;
• managing enquiries and communications;
• protecting the Site and our business from misuse;
• preventing fraud, abuse and cyber threats;
• preserving evidence and enforcing our legal rights;
• assessing whether a relationship or interaction is appropriate.

6.2 Contract or Steps at Your Request

We may process data where necessary to take steps at your request before entering into a contract, or where necessary for the performance of a contract.

6.3 Legal Obligation

We may process data where necessary to comply with legal, regulatory, court or enforcement obligations.

6.4 Consent

Where required by law, including for certain cookies, tracking technologies, or certain marketing communications, we will rely on your consent.

The ICO states that organisations should determine their lawful bases before they start using personal data and explain those bases in the privacy notice. (ico.org.uk)

7. Sensitive Personal Information and Similar Categories

We do not intentionally seek to collect special category personal data through the Site unless it is specifically relevant and lawfully required. If you choose to submit sensitive information through the Site, you do so at your own discretion, and we may process it where permitted by law and necessary for the relevant purpose.

For California residents, we may collect categories of sensitive personal information where applicable, including for example precise geolocation if ever enabled with appropriate notice and, where required, consent. California law requires disclosure of the categories of sensitive personal information collected and the purposes for which they are used. (cppa.ca.gov)

8. Cookies and Similar Technologies

The Site does not use analytics, advertising, tracking pixels, session-replay or precise-geolocation technologies. It uses only what is strictly necessary to deliver the Site. The Cookie Notice lists each technology observed on the Site, its purpose and its duration.

9. Disclosure of Your Information

We may disclose personal data to the following categories of recipients where reasonably necessary:

• Roicè affiliates and group entities;
• hosting, cloud, infrastructure and website service providers;
• cybersecurity, fraud prevention and monitoring providers;
• communications, CRM and lead-management providers;
• professional advisers, including lawyers, auditors, consultants and forensic experts;
• regulators, courts, law enforcement or competent authorities where required or appropriate;
• insurers or claims-related counterparties;
• transaction counterparties, diligence teams or screening parties where relevant to a relationship or transaction and lawfully justified;
• acquirers, successors or participants in a corporate reorganisation, subject to appropriate safeguards.

We do not disclose personal data more broadly than is reasonably necessary for the purposes described in this Privacy Notice.

10. International Transfers

Your information may be processed in countries outside the UK, EEA, United States or Hong Kong, including where our service providers or affiliates operate.

Where required by applicable law, we will use lawful transfer mechanisms and safeguards for international transfers, such as adequacy regulations, standard contractual clauses or equivalent protections. The EU and UK both require organisations to use appropriate mechanisms where data is transferred internationally without an adequacy decision. (ico.org.uk)

11. Data Retention

We retain personal data for as long as reasonably necessary for the purposes set out in this Privacy Notice, including to:

• manage communications and enquiries;
• administer and improve the Site;
• maintain security records;
• investigate incidents;
• comply with legal and regulatory requirements;
• preserve evidence;
• enforce rights or defend claims.

Retention periods vary depending on the nature of the data, the context in which it was collected, applicable limitation periods, legal obligations, and our legitimate business and security needs.

Where possible, we will delete, anonymise or de-identify information when it is no longer reasonably necessary.

12. Your Rights

Depending on where you are located, you may have the right to:

• request access to your personal data;
• request correction of inaccurate data;
• request deletion of certain personal data;
• request restriction of processing;
• object to certain processing;
• request portability of data in certain circumstances;
• withdraw consent where processing is based on consent;
• complain to a supervisory or regulatory authority.

UK and EEA

Individuals in the UK and EEA have rights under the UK GDPR / GDPR, and may complain to the relevant supervisory authority. In Ireland, this is the Data Protection Commission (www.dataprotection.ie), which acts as lead supervisory authority for cross-border processing linked to our main establishment in Ireland; you may also complain to the supervisory authority where you live, where you work or where an alleged infringement took place. In the UK, this is the Information Commissioner’s Office. The ICO says privacy notices should explain people’s information rights and how they can complain. (ico.org.uk)

California

California residents may have rights under the CCPA/CPRA, including rights to know, delete, correct, limit the use and disclosure of sensitive personal information in certain cases, and rights related to sales/sharing where applicable. (cppa.ca.gov)

Hong Kong

Individuals in Hong Kong may have rights under the PDPO, including rights of access and correction, subject to the PDPO and applicable exemptions. (pcpd.org.hk)

To exercise any applicable rights, contact us at legals@roicet.com.

13. California-Specific Supplemental Notice

If you are a California resident and the CCPA/CPRA applies to us in relation to your interaction with the Site, the following additional points apply.

Categories of Personal Information We May Collect

We may collect the following categories, depending on your interaction with the Site:

• identifiers;
• internet or network activity information;
• commercial or professional information;
• sensitive personal information, only where you choose to provide it (see section 7).

Purposes

We may use these categories for:

• site operation;
• security and fraud prevention;
• communications;
• relationship management;
• legal compliance;
• business improvement.

Sales / Sharing

Through this Site we do not sell personal information and do not share it for cross-context behavioural advertising. This statement describes this Site only; processing in other services or relationships is covered by their own notices.

Sensitive Personal Information

If we collect sensitive personal information, we use and disclose it only for the purposes permitted by law and/or as disclosed in this Privacy Notice and any applicable notice at collection.

14. Hong Kong-Specific Supplemental Notice

If the PDPO applies to your interaction with the Site, Roicè will handle personal data in accordance with the Ordinance and applicable guidance.

Where online behavioural tracking involves personal data, Roicè will seek to ensure that such use is appropriately disclosed and handled in line with the PDPO and PCPD guidance. (pcpd.org.hk)

If we intend to use personal data for direct marketing in circumstances where Hong Kong law requires consent, we will do so only in accordance with those requirements.

15. Security

We use technical, organisational and operational measures designed to protect personal data and the Site. These measures may include access controls, monitoring, logging, rate limiting, fraud prevention, security tooling, anomaly detection, device/session analysis and incident response protocols.

However, no system or transmission is completely secure, and we cannot guarantee absolute security.

16. Children

The Site is not intended for children, and we do not knowingly collect personal data from children through the Site unless expressly indicated in a specific context.

17. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. The latest version published on the Site will apply.

18. Contact Us

If you have questions about this Privacy Notice or wish to exercise applicable rights, contact:

Legal and data protection: legals@roicet.com

Address: Roicè Consolidated AM Limited, 6 Fern Road, Sandyford Business Park, Dublin D18 FP98, Ireland

Ireland

You may lodge a complaint with the Data Protection Commission (www.dataprotection.ie), without prejudice to your right to complain to another competent supervisory authority.

UK Complaints

If you are in the UK and are dissatisfied with how we handle your personal data, you may have the right to complain to the Information Commissioner’s Office. (ico.org.uk)

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