Roxy Privacy Policy
Effective June 15, 2018

Introduction

Your privacy and trust are important to us. This privacy policy explains how Askwithcue, Inc dba Roxy Device ("Roxy", "we", "us" or "our") collects, handles, stores and protects personal information about you in the context of our services. It also provides information about your rights and about how you can contact us if you have questions about how we handle your information.

Who this statement applies to and what it covers

This Statement applies to individuals who use our in-room Roxy device or our Roxy management website (we call these our "Services"). It does not apply to information collected by us offline or through any other means, or by any third party (including through any application or content that may be accessible through our Services).

Roxy provides information and functionality for adult guests. No one under age 13 may provide any information to us through or in connection with the Services, and we do not knowingly collect information from children under 13 (and you are prohibited from providing such information to us). If you are under 13, you may not access or use the Services for any reason whatsoever.

If you do not agree with our policies and practices, your choice is not to use the Services. By accessing or using the Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the privacy policy for changes each time before you use the Services.

Who we are

For some Services we make decisions on how personal information is used in the context of a Service (Roxy is a controller of personal information in this case), and for other Services we will only use personal information as instructed by our customers (Roxy is a processor of personal information in this case). Below you can find more information on the cases in which Roxy is a controller of personal information and information on how to contact us.

Sources of personal information

We collect personal information about you from your interactions with the Roxy device. This information is pseudonymous and is not tied to your name but rather to your room number. Roxy does not have access to information needed to connect your name to your room number. We obtain this pseudonymous personal information from you through your interactions with us and our Service, such as when you make a request to Roxy for an item or for information.

What types of personal information we collect

The type of personal information we collect depends on how you are interacting with Roxy.

You can choose whether or not to provide us with this information, but if you choose not to provide us with such information, you may not access or use Roxy.

The personal information we collect is pseudonymous and consists of the following:

How we use personal information

We use personal information to provide and improve Services and for other purposes that are in our and our users' legitimate interests, as well as for compliance purposes.

Some laws require us to explain our lawful reason for processing your personal information. We process personal information about you on the basis that it is:

You are welcome to contact us for further information on the legal grounds that we rely on in relation to any specific processing of your personal information.

How we share personal information

We share pseudonymised voice transcripts with hotels in order for them to recognize common requests and improve their service. These transcripts are not associated with your name or room number, and the hotels have no ability to connect you with your query. We also share pseudonymised personal information if necessary for compliance for a legal obligation (e.g., to respond to a requirement of applicable law, a court order or other judicial process, or a request from a law enforcement agency, regulatory authority or other governmental authority).

How we secure personal information

Roxy takes the security of personal information seriously, and we use appropriate technologies and procedures to protect personal information (including administrative, technical and physical safeguards) according to the risk level and the Services provided.

Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet the sensitivity of the personal information we handle, our business needs, and changes in technology and regulatory requirements.

How long we keep personal information

The pseudonymised voice data and recordings and retained indefinitely, or until the hotel the data was captured in requests that we delete the data.

Your rights

You may have rights under European Union and other laws to gain access to your personal information and to ask us to rectify, erase or restrict use of your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.

We will honor your rights under applicable data protection laws. You have the following rights under European Union laws and may have similar rights under the laws of other applicable jurisdictions:

These rights are not absolute and they do not always apply in all cases. In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why. In order to exercise your rights please email us at info@roxydevice.com.

How to contact us

If you have any questions, comments, complaints or suggestions in relation to data protection or this Statement, or any other concerns about the way in which we process information about you, please contact our Privacy Team at info@roxydevice.com.