Privacy & Cookie Policies
Letters From Rocky – Cookie Policy
Effective Date: Aug 1, 2026
This Cookie Policy describes how Letters From Rocky uses cookies and similar technologies to provide, customize, evaluate, improve, promote and protect our Services. Note that any capitalized terms not defined in this Cookie Policy have the meanings set forth in our Privacy Policy. If you have any comments or questions about this Cookie Policy, feel free to contact us at info@lettersfromrocky.com.
Cookies. Cookies are text or other files stored on or retrieved from your browser or device when you visit a website. They serve a variety of functions, like enabling us to remember certain information you provide to us as you navigate between pages on the Services. When you visit our Services, both first party and third party cookies may be placed on your browser or device. Our Services may require you to affirmatively consent to certain cookies where that’s required or enable you to opt-out of certain cookies where that’s required. We use cookies on our Services for the following purposes:
Authentication, Security and Other Required Purposes. Cookies help us verify your account and device and determine when you’re logged in. We also use cookies to help secure our Services, remember your cookie consent preferences and provide you with the Services.
Functional Purposes:
Customization. Cookies help us provide you with your desired experience by remembering the choices you’ve made on our Services, such as your language preferences.
Performance And Analytics. Cookies help us analyze how the Services are being accessed, used and enable us to track performance of the Services. For example, we use cookies to determine if you viewed a page or section of a page.
Third Party Functionality. Cookies allow us to provide you additional functionality from or via third parties. Third party functionality integrated with our Services may use cookies as part of that integration, including for example to help you sign into their services and connect your use of their Services to your use of our Services. Any such third party cookie usage is governed by the policy of the third party placing the cookie.
Advertising Purposes. We partner with third party publishers, advertising networks and other vendors to manage our ads on other sites. These third party partners may set cookies on your browser or device to gather information about your activities on the Services and other sites you visit, in order to show you or exclude you from being shown Letters From Rocky ads. For example, if you visit Letters From Rocky and also use a social media platform, you may see a Letters From Rocky ad on that social media platform. If you disable these cookies, you may still see our ads on third party websites or apps, but they may be less relevant to you.
Opting Out. You can set your browser to not accept cookies, but this may limit your ability to use the Services.
We do not currently recognize or respond to browser-initiated Do Not Track signals or Global Privacy Control (GPC) signals.
You can manage your cookie settings using the “Cookie Preferences” link in the footer banner when you visit our site.
Please note that your preferences may only apply to the browser and device you use to submit your preferences. You may need to make your choices on each browser and device where you want your choices to apply. Your choices may also be stored using cookies. If you clear your cookies, you may need to make your choices again. Please note that we do not maintain or control third party opt-out tools and are not responsible for their operation.
Third Party Cookies. First party cookies are usually those placed directly by us or from our website domain. Third party cookies are usually those placed by our vendors or business partners. Both types of cookies allow us or our vendors or business partners to access information about your browser, device and/or visit. While some of our cookies are first party cookies placed by Letters From Rocky or are third party cookies placed by and from third party services, we also directly place and manage some third party cookies on our Services. We may also use Google Tag Manager (GTM) to manage some of these third party cookies. Examples of third party cookies that Letters From Rocky places and manages via GTM include Google Analytics and the Meta Pixel.
Updates. We will update this Cookie Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Cookie Policy and post it on our sites. We encourage you to check back periodically to review this Cookie Policy for any changes since your last visit.
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Letters From Rocky – Privacy Policy
Effective Date: Aug 1, 2026
This Privacy Policy sets out what personal information Letters From Rocky (“Letters From Rocky,” “we,” “us” or “our”) collects, what we do with it and your choices and rights.
By using or accessing any of our sites, templates, products, applications, tools, services and features (collectively, the "Services"), you confirm you have agreed to the Terms of Service and have read and understood this Privacy Policy and our Cookie Policy. The Letters From Rocky entity that controls your information depends on where you are located. See Section 12 below.
You can find out about your rights and choices in Section 6 below. We’ve also included at the end of this Privacy Policy some region-specific supplemental information if you are located in: (i) California; or (ii) a U.S. state (other than California) with an applicable data privacy law.
For clarity, we use different defined terms in this Privacy Policy to refer to the different parties who interact with our Services:
A “User” is someone who visits or uses one of our sites, such as www.LettersFromRocky.com mobile applications.
A “Customer” is one of our Users who has an account with us.
An “End User” is someone who visits, purchases from, or otherwise uses one of our sites.
We also use different terms in this Privacy Policy to differentiate between our roles under global data privacy laws with respect to the personal information we process:
“Letters From Rocky Controlled Information” is personal information for which Letters From Rocky acts as the “data controller” (or similar term under applicable law) and determines the purposes and means of processing. This includes information about our Users and Customers. We also act as an independent data controller for personal information relating to End Users which we automatically receive (including via cookies or similar tracking technology) when an End User visits a site hosted on our Services (such as the End User’s IP address) when we process it for our own purposes, including to foster the security and integrity of our Services.
“Customer Controlled Information” is personal information for which a Customer acts as the “data controller” (or similar term under applicable law) and determines the purposes and means of processing. This includes any personal information included in the content uploaded by a Customer to our Services including information provided by an End User via a webform on the our site as well as information automatically received (including via cookies or similar tracking technology) when an End User visits our site.
We explain below how we collect and use Letters From Rocky Controlled Information and your rights.
Table of Contents:
How does this Privacy Policy apply?
Information we collect
How we collect your information
How we use your information
How we disclose your information
Your rights and choices
How we protect your information
How we retain your information
Data transfers
Data Privacy Frameworks
Updates to this Privacy Policy
Who is Letters From Rocky?
How to contact us
Appendix I. California Supplemental Information
Appendix II. Other US States Supplemental Information
1. How does this Privacy Policy apply?
This Privacy Policy describes what we do with Letters From Rocky Controlled Information, such as Customer account information, information about how Users use and interact with our Services, information Users submit to our customer support, and, when we use it for our own purposes, including to foster the security and integrity of our Services, and End User information which is automatically collected when an End User visits a Customer’s site hosted on our Services.
We have separate privacy policies that apply in relation to our processing of personal information relating to our staff and applicants for jobs at a Letters From Rocky.
We use cookies and similar technologies. Our Cookie Policy describes what we do in that regard.
2. Information we collect
We collect various information regarding you or your device. This includes the following
Account Information:
Customer Account Details: Information you provide to create an account with our Services, specifically email address, password, first name and last name, billing address and mailing address, and phone number.
Optional SMS Account Information: You may optionally provide us with additional account information, such as your phone number, for the purpose of receiving transactional SMS messages from us. We will only send you SMS messages if you opt in to receive them. Examples of use cases include informational notifications or reminders and enabling and utilizing two factor authentication (2FA) on your account with us. Although 2FA may be required for certain actions or in certain scenarios on our Services, 2FA may be utilized without providing any Optional SMS Account Information. For avoidance of doubt, we will not sell, share or otherwise disclose your Optional SMS Account Information to a third party in a manner that permits such third party to use your phone number and/or opt-in consent to send SMS messages to you for the third party’s marketing purposes.
Product Enablement Information:
Other Product Information: We are sometimes required to collect other information from you in order to enable you to use or configure certain of our Services.
SMS Marketing Information: You may provide us with your phone number for the purpose of receiving marketing SMS messages from us. We will only send you marketing SMS messages if you opt in to receive them.
Identity Verification Information: At times, you may be required to provide us with additional information to verify your identity, including a photograph of you captured by you during the verification process, a copy of an official government document which includes a different photograph of you and a bank statement. Identity Verification Information is requested in certain scenarios, including when you have lost access to your account, when there is a dispute between you and others regarding ownership of an account or subscription, and when we suspect or detect suspicious or anomalous activity on your account(s) with our Services. Letters From Rocky does not create, store or otherwise have access to any biometric data. Identity Verification Information also includes details that are listed on such official government documents.
Account History Information: Information about your account’s use of the Services, including your trials, subscriptions, discount code usage and related details. If you integrate your use of our Services with a third party payment processor or other third party service, this would also include information about your account’s use of such Services or third party products.
Payment Information: Information you provide if you sign up for Services you have to pay for (e.g., a product subscription). For most paid Services, this will include your billing address as well as a portion of your payment information which is provided to us from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card).
Marketing Preferences: Your marketing preferences and details, including if you’ve opted out of all or a portion of our direct marketing messages.
Communication Information: The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. Please be aware that information on public parts of our Services is available to others.
Site Usage Information: Technical browsing or other information from your use of the Services or, where you are an End User, from your visits to our sites. This includes IP addresses, preferences, web pages you visited prior to coming to our sites, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings) and information about how you interact with the Services and, if you are an End User, with our sites (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors). If you’re using a mobile application, Site Usage Information could also include your precise location information if your mobile device settings authorize us to collect this information.
Other Individuals Contact Information: In addition to Customer contact information, we may also collect contact information for others, including people who work for our vendors or business partners or other individuals that may include Users and Customers.
Enterprise Sales Information: We collect information about companies and their personnel who are perceived to be potential customers for our Services. Such information may include names, email addresses, mailing addresses, job titles and phone numbers. If we discuss our services with such potential customers, this information may also include recordings of those discussions.
Survey and Research Information: Information you share with us in connection with surveys or research.
Promotion Information: Information you share with us in connection with contests, sweepstakes or other promotions.
3. How we collect your information
We obtain information about you from various sources. We do this in three main ways:
You provide some of it directly (such as by registering for an account).
We record some of it automatically when you use our Services or, where you are an End User, from your visits to our sites (including with technologies like cookies).
We receive some of it from third parties (like when you register for an account using a third party service like Apple, Facebook or Google, when you purchase our products from an authorized reseller, when you make payments to us using our payment processor or via a mobile app store or when we receive information about potential enterprise sales leads).
We’ve described this in more detail below.
a. Information you provide
When you use our Services, we collect information from you in a number of ways. For instance, we ask you to provide your Customer Account Details to create and manage your account. We also maintain your Marketing Preferences and your Communication Information that you provide to us. You might also provide us with information in other ways, including by responding to surveys, participating in user research or entering a contest, sweepstakes or other promotion.
Sometimes we require you to provide us with information for contractual or legal reasons. For example:
we may ask you to provide a mailing address and/or select your jurisdiction when you sign up for our paid Services (e.g., purchase a subscription) to determine if, and how much, tax we need to collect from you;
We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide requested information, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.
b. Information obtained from your use of our Services
When you use our Services, we collect Site Usage Information and Account History Information about your activity on and interaction with the Services. If permission has been granted through your device settings, Site Usage Information for mobile apps may include your precise location information.
If you are an End User, we also get Site Usage Information about your interactions with our sites.
Some of this information is collected automatically using cookies and similar technologies when you use our Services or, if you are an End User, when you visit a our site. We let our Customers control what cookies and similar technologies are used through their sites (except those we need to use to properly provide the Services, such as for functionality, performance or security related reasons). You can read more about our use of cookies in our Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device.
c. Information obtained from other sources
If you use a third party service (such as Apple, Facebook or Google) to register for an account, the third party service may provide us with your Customer Account Details on your behalf, but we don’t collect or store passwords you use to access third party services. We do not control what information a third party service provides to us. The third party service you use may give you options on what the service discloses to us if you link your third party service account with the Services. Make sure you are comfortable with what these third party services share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the third party service.
If you sign up for our paid Services via a third party service acting as an authorized reseller of our products, the reseller business partner may provide us with information on your behalf which is necessary for us to complete your paid Services sign up or otherwise manage your relationship with us, such as your Customer Account Details.
If you use third party services which are integrated with the Services we may receive information about your use of such third party services via our integration business partners.
Currently, the payment processors we use to bill you for paid Services are Stripe and PayPal. Each payment processor uses and processes your complete payment information in accordance with its applicable privacy policy (Stripe and PayPal).
If you sign up for paid Services with us using a payment card, we obtain limited information about your payment card from our payment processor, such as the last four digits, the country of issuance and the expiration date.
If you sign up for paid Services with us using PayPal or another non-payment card payment method, we may obtain information about your payment method from our payment processor, such as: (i) for PayPal, the email address associated with your PayPal account; and (ii) for Single Euro Payments Area (SEPA), the last four digits of your bank account number, the country of your bank account and your bank’s bank code and branch code.
The preceding payment processors paragraph is not applicable:
if you sign up for paid Services via a third party service acting as an authorized reseller of our products. Please see the authorized reseller’s privacy policy for information about how they use and process your payment information.
4. How we use your information
When we process your information pursuant to this Privacy Policy, we do so for the following purposes:
Provision of the Services to Customers. Create and manage your account, process your payments to us, and receive support for your inquiries.
Communicating with you. Communicate with you, including by sending you emails about your transactions and Service-related announcements.
Surveys and research and contests, sweepstakes or other promotions. Conduct and administer surveys and research, as well as contests, sweepstakes or other promotions.
Processing your payments. Receive payment from you for paid Services.
Promotion and sales. Promote and sell our Services and send you tailored marketing communications about products, services, offers, programs and promotions of Letters From Rocky and our business partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on your current subscription plan or what we think may interest you based on your Account History Information.
Advertising. Learn about and analyze your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for paid Services or we may choose to serve you a particular advertisement based on your current subscription plan or what we think may interest you based on your Account History Information. In certain US states, you have the right to opt out of our sharing of your information with such third party online services.
Customizing the Services. Provide you with a customized Services experience. For example, we may use your location information to determine your language preferences or display accurate date and time information. We may also use cookies and similar technologies to help us achieve this purpose.
Improving our Services. Learn about and analyze how the Services are accessed and used and evaluate and improve our Services (including by developing new products and services and managing our communications). For example, if we learn that most Customers of paid Services use a particular feature, we might wish to expand on that feature.
Security. Foster the safety, security and integrity of our Services.
Third party relationships. Manage our vendor, business partner and other third party relationships.
Enforcement. Enforce our Terms of Service and other legal terms and policies.
Protection. Protect our and others’ interests, rights and property.
Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts or law enforcement requests.
We may de-identify information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified form and use such information for purposes such as to conduct research, to improve our Services, for troubleshooting purposes or to help detect and protect against error, fraud or other criminal activity. We commit to not de-aggregating or re-identifying the aggregated and/or anonymized data that we process. Our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation.
For our Users in the European Economic Area (“EEA”) and the United Kingdom (“UK”) we rely on the legal bases set out in the table below to process your information. The legal bases on which we rely for Users from other jurisdictions may differ from those listed below.
a. Performance of a contract. We process your information as necessary for us to provide you with the Services and/or perform our Terms of Service or other relevant contract(s) with you. You cannot use our Services if we cannot process your information for the below purposes.
Purpose
Categories of Personal Information
i. To create and manage your account with Letters From Rocky and provide our Services.
For our Customers, we collect certain information so you can login to our Services and manage and use your paid Services.
Customer Account Details
Optional SMS Account Information
Other Product Information
Identity Verification Information
Account History Information
ii. To receive payment for paid Services.
We use certain information to receive payment from our Customers who purchase paid Services from us. This involves us sharing information with our payment processors. Such payment processors will process your information in accordance with their own privacy policies.
Account History Information
Payment Information
iii. To send communications about your transactions with us and other Service-related announcements.
As a Customer, if you make purchases from the Services or we need to otherwise notify you about our Services or your use of them, we need to communicate with you, including via email and/or by sending you an alert via the Services.
Customer Account Details
Optional SMS Account Information
Other Product Information
Account History Information
iv. To provide support for our Services and resolve issues or disputes.
We use certain information to receive, review and respond to User, Customer and other individuals’ requests for support or other inquiries. We may also use your information to resolve any issues or disputes.
Customer Account Details
Optional SMS Account Information
Other Product Information
Account History Information
Payment Information
Communication Information
Site Usage Information
Other Individuals Contact Information
v. To foster the safety, security and integrity of our Services.
We use certain information (including in an automated manner) to foster the security and integrity of our Services, including: (A) to detect, investigate and/or prevent suspicious, harmful, unsafe or unlawful activity or behavior, including fraud, spam or other safety or security issues and any other violations or potential violations of our Terms of Service or applicable policies.
Customer Account Details
Optional SMS Account Information
Other Product Information
Identity Verification Information
Account History Information
Payment Information
Communication Information
Site Usage Information
vi. To administer contests, sweepstakes and other promotions.
We use certain information about individuals who enter our contests, sweepstakes or other promotions to, as applicable, assess eligibility, manage and operate the promotion, select winners and provide prizes.
Customer Account Details
Site Usage Information
Promotion Information
b. Where necessary to comply with our legal obligations. We have a legal obligation to process your information for the below purposes.
Purpose
Categories of Personal Information
i. To comply with applicable tax laws.
We use certain information about paying Customers, such as their billing address, to comply with our obligations under applicable tax laws, including the Taxes Consolidation Act, 1997 and the Value-Added Tax Consolidation Act 2010 (each, as amended).
Customer Account Details
Account History Information
Payment Information
Enterprise Sales Information
ii. To respond to a legal request or comply with applicable law where we have a legal or regulatory obligation.
We use, retain and disclose information where we have a legal or regulatory obligation to do so. For example: (A) if we receive a valid legal request, such as a court order, preservation order or search warrant, related to your account, we may use, retain and disclose your information to comply with such request (even if you subsequently exercise your rights under Section 6 below); (B) to the extent we have an obligation to detect, investigate and/or prevent suspicious, harmful, unsafe or unlawful activity or behavior, including fraud, spam or other safety or security issues, we may use certain information (including in an automated manner) for such purposes; and (C) in connection with litigation, potential disputes or regulatory matters, we may use, retain and disclose your information related to a legal claim or complaint, such as where we are subject to a regulatory investigation or need to defend ourselves in legal proceedings or respond to a regulatory complaint made by you or others. Such laws may include the European General Data Protection Regulation (including as amended and/or incorporated into UK law, the "GDPR"), the Data Protection Act 1988-2018, Regulation (EU) No 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters, the Digital Services Act (Regulation (EU) 2022/2065), Council Regulation (EC) No 1206/2001 of 28 May 2001 on cooperation between the courts of the Member States in the taking of evidence in civil or commercial matters, Section 10 of the Criminal Justice (Miscellaneous Provisions) Act 1997 (as amended) and the Criminal Justice Act 2011.
Letters From Rocky does not disclose data to law enforcement, regulatory or governmental bodies unless required by applicable law and objects to unlawful requests.
All categories listed in Section 2 above
c. Where necessary for our legitimate interests or the legitimate interests of a third party such as our Customers. For example, we have a legitimate interest in operating our business and our Customers have a legitimate interest in having our site function properly, safely and securely. We won’t process your information if your interests or your fundamental rights and freedoms override ours or others’ legitimate interests. You have the right to object to this processing at any time.
Purpose
Categories of Personal Information
i. To understand and analyze how you use our Services and improve your experience on the Services.
We use certain information to learn about and analyze our Users’ and Customers’ experience with our Services, including for bug detection and user research. We use these insights and this information to improve our Services. For example, if we learn that most Customers of our paid Services use a particular integration or feature, we might wish to expand on that integration or feature.
Other Product Information
Account History Information
Payment Information
Marketing Preferences
Communication Information
Site Usage Information
Enterprise Sales Information
Survey and Research Information
Promotion Information
ii. To customize our Services for our Users and Customers.
We use certain information to customize our Services for you and tailor our communications for you. For example: (A) we use your location information to determine your language preferences or display accurate date and time information; and (B) we use information about how you use our Services to communicate relevant information to you. We also use cookies and similar technologies for this purpose.
Customer Account Details
Account History Information
Payment Information
Marketing Preferences
Communication Information
Site Usage Information
Enterprise Sales Information
Survey and Research Information
iii. To tailor our advertising outside of the Services.
We use and share certain information with online advertising business partners.
Account History Information
Site Usage Information
iv. To identify, respond to and propose solutions for actual or potential business Customers.
We use certain information to identify, respond to and propose solutions for actual or potential business Customers in respect of our Services.
Enterprise Sales Information
v. To maintain the safety, security and integrity of our Services.
We use certain information (including in an automated manner) to foster the security and integrity of our Services, including: (A) to detect, investigate and/or prevent suspicious, harmful, unsafe or unlawful activity or behavior, including fraud, spam or other safety or security issues and any other violations or potential violations of our Terms of Service or applicable policies; and (B) to maintain the integrity of our Services.
Customer Account Details
Optional SMS Account Information
Other Product Information
Identity Verification Information
Account History Information
Payment Information
Communication Information
Site Usage Information
Enterprise Sales Information
vi. To protect our legal rights.
We may use, retain or share information to protect or exercise our legal rights or defend against actual or potential legal claims, including to address a violation or potential violation of our Terms of Service or policies.
All categories listed in Section 2 above
vii. To manage our vendor, business partner and other third party relationships.
We use certain information to manage our relationships with vendors, business partners and other third parties.
Other Individuals Contact Information
Enterprise Sales Information
viii. In the event of a business transfer.
If Letters From Rocky is involved in a reorganization, merger, acquisition, sale of some or all of our assets or other business transaction, depending on the circumstances, we may use or share information as part of the negotiation, consideration or effectuation of such transaction.
All categories listed in Section 2 above
d. Where you provide your consent. In these scenarios, you have the right to withdraw your consent at any time.
Purpose
Categories of Personal Information
i. To send you marketing.
We need your consent to send you email, SMS or other marketing messages if you are in the EEA, UK or Switzerland (collectively, the “European Region”). You will be given the opportunity to opt out of each marketing communication that we send.
Customer Account Details
SMS Marketing Information
Account History Information
Marketing Preferences
Enterprise Sales Information
ii. To tailor our advertising outside of the Services.
Where we use cookies and similar technologies for this purpose, we need your consent to use or share your information with our online advertising business partners. You have the right to withdraw your consent at any time.
Account History Information
Marketing Preferences
Site Usage Information
e. To protect your or others’ vital interests. In rare circumstances, we process your information to protect your or others’ vital interests.
Purpose
Categories of Personal Information
i. To retain, review and share information with law enforcement and others.
We may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies. For example, we may share information to prevent loss of life or personal injury to a Customer, End User or third party, or to prevent crime or fraud.
All categories listed in Section 2 above
5. How we disclose your information
We may disclose information about you in the following circumstances:
Vendors: We disclose information about you to our vendors (including our affiliates) that perform services on our behalf. These include providers of the following types of services:
Customer support vendors. These vendors assist us in hosting our support offerings (including message boards or forums) and helping us track, manage and respond to customer support inquiries. We disclose data such as Customer Account Details and Communication Information to them to enable them to provide these services to us.
Sales and marketing vendors. These vendors assist us in sending marketing and other communications. We disclose data such as Customer Account Details and Account History Information to them to enable them to provide these services to us.
Information technology vendors. These vendors enable us to operate our Services in a fast, reliable manner by providing us with technology services like data hosting and cloud computing resources. We disclose data such as Customer Account Details, Account History Information, Payment Information and Site Usage Information to them to enable them to provide these services to us.
Safety and security vendors. These vendors enable us to keep our Services safe and secure, such as by verifying your identity or scanning, detecting and investigating possible violations of our policies or suspicious behavior, including fraud or other security or safety violations. We share Customer Account Details, Identity Verification Information and Site Usage Information with them to enable them to provide these services to us.
Financial services vendors. These vendors (including Stripe, Sift, Inscribe and Plaid) enable us to operate and provide the financial services, perform administrative payment functions, perform individual identity or bank verification and prevent or investigate suspected risk, fraud, security threats, illegal and malicious activity or violations of our Terms of Service. In accordance with our Terms of Service, we may disclose Customer Account Details, Financial Solutions Services Account Information, Account History Information and Site Usage Information to them to enable them to provide these services to us.
Professional advisors. In limited cases, we may need to disclose your information with our professional advisors like our external lawyers or financial advisors who help us comply with our legal and financial obligations. Depending on the circumstances, we may share any of the information described in Section 2 above to them.
Business partners. We may disclose information about you to our business partners. These include the following types of business partners:
Reseller business partners. We partner with companies who are authorized to resell our products on our behalf to Customers. We may disclose information to these authorized resellers to provide you with support. For example, if you need support related to a resold Service, we may disclose information such as Account History Information to these resellers to assist them and us in resolving your issue.
Supplier business partners. We partner with supplier companies who create products for our Customers. We may disclose information to these business partners to enable you to use your purchased product. For example, if you purchase a letter from us we may disclose Customer shipping information to the Supplier to generate and ship the letter.
Online advertising business partners. We partner with advertising platforms so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may: (a) disclose your Account History Information and, if you’re a Customer, your Site Usage Information, to a third party social media platform on which we advertise to avoid serving our ads to people who are already paying Customers; or (b) disclose information about you to a third party ad serving platform to target our ads to Customers who created accounts but have not yet signed up for paid Services.
Third party plugins and social networks. We may disclose information about you to other parties that operate website plugins, social media platforms or similar third party services to improve your experience, at your direction, or when you intentionally interact with a plug-in. For example, when you use a third party service to create or log in to your account, we disclose the fact that you did so to that third party service.
Process payments. We transmit your Payment Information via an encrypted connection to our payment processors.
Following the law or protecting rights and interests. We disclose your information if we determine that such disclosure is reasonably necessary to comply with the law, regulations and policies, protect our or others’ rights, property or interests (such as enforcing our Terms of Service), prevent fraud or abuse of Letters From Rocky or our Customers or their End Users or prevent other criminal or illegal activity. For example, we may disclose your information in response to valid legal requests sent by public or governmental authorities (such as to meet national security or law enforcement requirements) or sent by third party nongovernmental individuals or organizations pursuant to a validly issued subpoena, other valid legal process under applicable law or bona fide request to investigate or prevent criminal or other illegal activity. Depending on the circumstances, we may disclose any of the information described in Section 2 above to them.
Business transfers. If we're involved in a reorganization, merger, acquisition, sale of some or all of our assets or other business transaction, depending on the circumstances, we may disclose any of the information described in Section 2 above as part of the negotiation, consideration or effectuation of such transaction.
6. Your rights and choices
Where applicable law requires (and subject to any relevant exceptions or obligations under law), you may have the right to access, port, update, change or delete personal information.
You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law.
You can access, update, change or delete personal information (or that of your End Users) in your account. You can also delete your account in the account portal of our website or by requesting your account be deleted by emailing Letters From Rocky. Please note that we may need to verify your identity in connection with your requests, and such verification process may, if you do not have access to your account, require you to provide us with additional information we maintain about you to verify your identity. Even if you have access to your account, we may request additional information if we believe it’s necessary to verify your identity. If we are unable to verify your identity or request, we may not, in accordance with applicable law, be able to fulfill your request. You may also contact us by email at info@LettersFromRocky.com to submit a request.
Please note that, for technical reasons, there will likely be a delay in deleting your personal information from our systems when you ask us to delete it. To the extent permitted under applicable law, we may also retain personal information in order to comply with the law, protect our or others’ rights, resolve disputes or enforce our legal terms or policies.
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
In some jurisdictions, applicable laws provide individuals the right to object to or opt out of a significant decision affecting them if the decision resulted from automated processing. While Letters From Rocky may, in some limited cases as described in this Privacy Policy, process your personal information in an automated manner, it is unlikely that an objection or opt out right would apply to such processing. This is because: (a) a human being may be involved in the process (so the processing is not fully automated); (b) no such right applies because the process relates to an exempted purpose, such as performing our contract with you or the detection or prevention of fraud or illegal activity; (c) the applicable decision is not made by us but by a business partner that enables us to provide certain Services subject to their terms and policies; or (d) the processing does not actually result in a significant decision affecting you as a Customer or End User. If you believe automated processing by our Services has resulted in a significant decision affecting you, you may contact us by email at info@LettersFromRocky.com to request more information and/or request that a human review such decision.
You can also elect not to receive marketing communications by changing your preferences in your Account or by following the unsubscribe instructions in such communications.
Our Cookie Policy explains how you can manage cookies and similar technologies.
You have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. See Section 12 below.
7. How we protect your information
While no service is completely secure, we have a dedicated security team. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing, of the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it).
8. How we retain your information
We retain your information for as long as your account is active or for as long as needed to provide you with the Services. We also retain your information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, protect us in the event of disputes, enforce our agreements or to protect our or others’ interests.
The precise periods for which we keep your information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread.
As Customers may have a seasonal site or come back to us after an account becomes inactive, if you’re a Customer, we may not immediately delete your information when you cancel all your paid Services. Instead, we keep your information for a reasonable period of time, so it will be there for you if you come back.
Please note that in the course of providing the Services, we may create, collect and/or maintain de-personalized information, which we may retain indefinitely.
9. Data transfers
Your personal information may be transferred to countries other than where you live, such as, for example, to our servers in the US. We also store your information locally on the devices you use to access the Services.
Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. For example, data we store may be accessible to law enforcement and national security authorities under certain circumstances.
We rely upon a number of means to transfer personal information which is subject to European Region data protection laws. These include:
Adequacy decision. We may, in accordance with Article 45 of the GDPR, transfer personal information to recipients that are in a country that European Commission, UK or Swiss data protection supervisory authority(ies) have confirmed, by decision, offers an adequate level of data protection (“adequacy decision”). We rely on these adequacy decisions to transfer personal information to recipients located in countries such as the UK. The adequacy decisions are available at the following links:
European Commission adequacy decisions; https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
UK adequacy decisions; https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/#adequacy
Swiss adequacy decisions; https://www.edoeb.admin.ch/edoeb/en/home/data-protection/handel-und-wirtschaft/transborder-data-flows.html
Data Privacy Frameworks. We transfer personal data to Letters From Rocky, Inc. in the US from, as applicable, the EEA, Switzerland and the UK pursuant to the Data Privacy Frameworks. An adequacy decision was adopted for the EU-U.S. Data Privacy Framework, Swiss-US Data Privacy Framework and the UK Extension to the EU-US Data Privacy Framework (each individually and jointly, the “Data Privacy Frameworks).
Standard data protection clauses (“SCCs”) and other transfer methods. For countries without an adequacy decision, we transfer, in accordance with Article 46 of the GDPR, personal information to recipients that have entered into the approved form of transfer contract (SCCs) for the transfer of personal data outside the European Region. We rely on SCCs to transfer personal information to recipients located in countries such as Australia. We may, where there is no adequacy decision, alternatively make a transfer based upon Article 46 of the GDPR using an approved certification mechanism or code of conduct or binding corporate rules.
10. Data Privacy Frameworks
Letters From Rocky, Inc. complies with the Data Privacy Frameworks to provide a legal basis for transfers of personal data to Letters From Rocky, Inc. in the US from, as applicable, the EEA, Switzerland and the UK. Letters From Rocky, Inc. has certified its compliance to the Data Privacy Frameworks.
Letters From Rocky, Inc.’s certification extends to its processing of personal information (received from the European Region under the Data Privacy Frameworks) of the type and for the purposes described in this Privacy Policy. This Privacy Policy also describes the types of third parties to which personal information is disclosed (and the purposes for such), individual’s right of access, the choice and means offered to limit the use and disclosure of personal information and that personal information is disclosed in response to legal requests by public authorities where necessary, including to meet national security or law enforcement requirements.
Letters From Rocky, Inc. is committed to treating personal information received from the European Region pursuant to the applicable Data Privacy Framework in accordance with the principles thereof (the “DPF Principles”). You can learn more about the Data Privacy Frameworks (as determined based upon the country from which the personal information was received) and DPF Principles by visiting https://www.dataprivacyframework.gov/. For purposes of enforcing compliance with the Data Privacy Frameworks, Letters From Rocky, Inc. is subject to the investigatory and enforcement authority of the US Federal Trade Commission.
Our accountability for personal information we receive and subsequently transfer to a third party is described in the DPF Principles. In particular, we may use third parties to process data on our behalf as described in this Privacy Policy, and we remain liable if they do so in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.
If you have a question or complaint you believe to be within the scope of our Data Privacy Frameworks certification, please contact us first at info@LettersFromRocky.com, or using the contact details in the “How to contact us” section below. Any complaint must include a description of your claim and proof of your relationship with Letters From Rocky. We'll respond within 45 days.
Any complaint that we can’t resolve directly after 45 days may be resolved by JAMS, which is the independent organization responsible for reviewing and resolving complaints about our Data Privacy Frameworks compliance. You can contact JAMS free of charge at https://www.jamsadr.com/DPF-Dispute-Resolution. JAMS is an alternative dispute resolution provider based in the US.
If your concern still isn't addressed by JAMS, you may be entitled to a binding arbitration under the DPF Principles through the International Centre for Dispute Resolution, which is the international division of the American Arbitration Association (“ICDR-AAA”) and which is the administrator for the Data Privacy Frameworks binding arbitration program. The administration of all such arbitrations will be in accordance with ICDR-AAA’s applicable dispute resolution rules and procedures in effect at the time any demand for arbitration is filed (the “ICDR-AAA Rules”). If you are in the EEA or the UK, please see the applicable ICDR-AAA Rules. If you are in Switzerland, please see the applicable ICDR-AAA Rules. Notwithstanding anything to the contrary, both you and Letters From Rocky agree to the applicable ICDR-AAA Rules relating to mass arbitration filings, including without limitation the ICDR-AAA Mass Arbitration Supplementary Rules and Fee Schedules, but excluding any rules or procedures governing or permitting class or representative actions.
Any dispute resolution demand or counterclaim, including arbitration demand or counterclaim, asserted by either party must contain sufficient information to provide fair notice to the other party of the asserting party’s identity, the claims being asserted and the factual allegations on which those claims are based, and must include proof that the claimant’s data is subject to this Privacy Policy. ICDR-AAA may require amendment of any demand or counterclaim that does not satisfy these requirements. ICDR-AAA has the right to impose sanctions for any claims it determines to be frivolous or improper (under the standard set forth in Federal Rule of Civil Procedure 11 and any similar standards in other jurisdictions), including for any claim filed on behalf of a claimant whose data is not subject to this Privacy Policy.
Nothing in the Data Privacy Frameworks affects your rights as a data subject to the extent we use any European Commission approved standard data protection clauses for transfers to the US. If there is any conflict between the terms in this Privacy Policy and applicable DPF Principles, the applicable DPF Principles shall govern.
11. Updates to this Privacy Policy
We will update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our sites. If we make material changes to it or the ways we process your information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).
We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit. This will help ensure you better understand your relationship with us, including the ways we process your information.
12. Who is Letters From Rocky?
When we say “Letters From Rocky” (or “we,” “us” or “our”), we mean: (a) Good Bull University, LLC DBA Letters From Rocky.
13. How to contact us
If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at info@LettersFromRocky.com, or write to us using the contact form on our website at www.lettersfromrocky.com/contact
Appendix I. Specific Information for California Residents
This Appendix I is only applicable to you if you are a User or Customer and you reside in the state of California in the US (“California Residents”) and only applies to Letters From Rocky Controlled Information for which Letters From Rocky is a “Business” (as defined in the CCPA). “CCPA” means the California Consumer Privacy Act (Cal. Civ. Code §§ 1798.100 - 1798.199), as may be modified from time to time, including by the California Privacy Rights Act. This Appendix I covers Letters From Rocky Controlled Information we collect about California Residents on or through our Services and through other means (such as information collected offline or in person). It does not apply to personal information we collect from individuals in their capacity as job applicants, employees, or independent contractors of Letters From Rocky. As used in this Appendix I, “personal information” shall have the meaning set forth in the CCPA.
a. Categories, business and commercial purposes, sources and third parties
California law requires us to disclose certain information regarding the personal information we collect. Below is a table showing: (i) all categories of personal information (as described in the CCPA) which Letters From Rocky collects, or has collected, about California Residents, in the twelve (12) months prior to the effective date of this Privacy Policy; (ii) the purposes for which we use that information; and (iii) the categories of other parties to whom we disclose that information for a business purpose.
Category of personal information
Purposes of use
Categories of other parties to whom Letters From Rocky has disclosed or may disclose this category
Personal identifiers, including Customer Account Details, Optional SMS Account Information, Other Product Information, Identity Verification Information, Communication Information, Site Usage Information, Other Individuals Contact Information, Enterprise Sales Information, Survey and Research Information and Promotion Information
Provision of the Services to Customers
Communicating with you
Surveys and research and contests, sweepstakes or other promotions
Processing your payments
Promotion and sales
Advertising
Customizing the Services
Improving our Services
Security
Third Party Relationships
Enforcement
Protection
Complying with Law
Vendors; Business partners; Entities for legal purposes; Entities for transfers of business or assets
Identity and financial data categories listed under the California Consumer Records statute, including Customer Account Details, Optional SMS Account Information, Other Product Information, Identity Verification Information, Communication Information, Other Individuals Contact Information, Enterprise Sales Information, Survey and Research Information and Promotion Information
Provision of the Services to Customers
Communicating with you
Surveys and research and contests, sweepstakes or other promotions
Processing your payments
Promotion and sales
Customizing the Services
Improving our Services
Security
Third party relationships
Enforcement
Protection
Complying with law
Vendors; Business partners; Entities for legal purposes; Entities for transfers of business or assets
Commercial information, including Account History Information, Enterprise Sales Information, Survey and Research Information and Promotion Information
Provision of the Services to Customers
Communicating with you
Surveys and research and contests, sweepstakes or other promotions
Promotion and sales
Advertising
Customizing the Services
Improving our Services
Security
Enforcement
Protection
Complying with law
Vendors; Business partners; Entities for legal purposes; Entities for transfers of business or assets
Geolocation data
Provision of the Services to Customers
Customizing the Services
Security
Enforcement
Protection
Complying with law
Vendors; Entities for legal purposes; Entities for transfers of business or assets
Professional or job-related information, including as part of Enterprise Sales Information
Communicating with you
Promotion and sales
Security
Enforcement
Protection
Complying with law
Vendors; Entities for legal purposes; Entities for transfers of business or assets
Internet activity data of Customers, including Site Usage Information of Customers
Provision of the Services to Customers
Advertising
Customizing the Services
Improving our Services
Security
Enforcement
Protection
Complying with law
Vendors; Business partners; Entities for legal purposes; Entities for transfers of business or assets
Internet activity data of End Users, including Site Usage Information of End Users
Security
Enforcement
Protection
Complying with law
Vendors; Entities for legal purposes; Entities for transfers of business or assets
Sensory data, including recorded discussions as part of Enterprise Sales Information
Communicating with you
Promotion and sales
Security
Enforcement
Protection
Complying with law
Vendors; Entities for legal purposes; Entities for transfers of business or assets
Other information, e.g., any other information you provide to us in connection with the Services
Provision of the Services to Customers
Communicating with you
Customizing the Services
Improving our Services
Security
Enforcement
Protection
Complying with law
Vendors; Entities for legal purposes; Entities for transfers of business or assets
The only categories of personal information for which we “Share" or “Sell” personal information for cross-context behavioral advertising (as described in subsection c. below) are non-sensitive identifiers (e.g., “hashed” email address), commercial transactions, and Internet activity data.
For more information about each category, purpose of use, and the parties to whom we disclose or share information, please see Section 5 above.
For information on how we retain your personal information, please see Section 8 above.
b. Your requests
Subject to certain exceptions and restrictions, the CCPA provides California Residents the right to submit requests to a business which has collected their personal information: (i) to provide them with access to the specific pieces and categories of personal information collected by the business about such California Resident, the categories of sources for such information, the business or commercial purposes for collecting such information, and the categories of unaffiliated parties to whom such information was disclosed; (ii) to request correction of their inaccurate personal information; and (iii) to delete their personal information (each, a “California Request”). We need certain types of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services.
If you are a California Resident, please follow the instructions in the “Your rights and choices” section above to submit California Requests and please make sure you note that you are a California Resident when you do so. California Residents may designate an authorized agent to make California Requests on their behalf. In order to designate an authorized agent to make a California Request on your behalf, you or your agent must provide proof that the agent has been authorized by you to act on your behalf, such as written authorization signed by you authorizing that agent to act on your behalf. We reserve the right to request additional information from you and/or individuals purporting to be authorized agents, such as when we suspect fraud.
c. Do not sell or share my personal information
California residents may opt out of the "Sale" or “Sharing” of their personal information. The CCPA’s definition of "Sale" includes “Sharing” for purposes of “cross-context behavioral advertising,” which is defined as targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites. We only mean this CCPA definition when “share” or “sharing” are capitalized in this Appendix I or otherwise in this Privacy Policy. We Share information to provide more relevant and tailored advertising to you regarding our Services. Depending on how you use the Services, we may Share device information and identifiers, such as IP address and unique advertising identifiers and cookies, for such purposes. We do not otherwise “Sell” (as defined in the CCPA) your personal information and have not engaged in such activity in the twelve (12) months prior to the effective date of this Privacy Policy.
If you would like to opt out of Letters From Rocky's Sale or Sharing of your information with third parties for such purposes, you may do so by emailing info@LettersFromRocky.com.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. We collect the following categories of “sensitive personal information”: (i) account log-in and password or other credentials that allow access to your account; and (ii) geolocation information. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.
We do not currently recognize or respond to browser-initiated Do Not Track signals.
We do not knowingly Sell or Share the personal information of children under 16.
d. We do not discriminate against you
You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Letters From Rocky does not discriminate against California Residents for exercising their rights.
e. Shine the Light requests
California’s “Shine the Light” law (California Civil Code § 1798.83) allows California residents with whom a business has an established business relationship to request a list of “third parties” to whom we have disclosed certain “personal information” in the preceding calendar year where the business knows or reasonably should know that the third parties used the personal information for their own “direct marketing purposes” (as each of those terms is defined under such California law). Direct marketing purposes means “the use of personal information to solicit or induce a purchase, rental, lease, or exchange of products, goods, property, or services directly to individuals by means of the mail, telephone, or electronic mail for their personal, family, or household purposes.” However, a business like Letters From Rocky is not required to provide this information where it adopts and discloses, in its privacy policy, a policy of not disclosing “personal information” to third parties for their “direct marketing purposes”: (i) unless the resident first affirmatively agrees; or (ii) if the resident has exercised an option that prevents that information from being disclosed. Letters From Rocky maintains such a policy and provides California residents with a cost-free means to exercise that option, and thus is not required to provide this information. Please see the opt-out method described above in subsection (c) (“Do not sell or share my personal information”) of this Appendix I of this Privacy Policy.
Appendix II. Specific Information for Residents of Other US States With An Applicable Data Privacy Law
This Appendix II is only applicable to you if you are a resident of a state other than California with an applicable data privacy law such as Colorado, Connecticut, Oregon, and Texas (“Applicable State Residents”) and only applies to Letters From Rocky Controlled Information for which Letters From Rocky is a “Controller” (as defined in an applicable state data privacy law). It does not apply to personal information we collect about you where you are acting as an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. This Appendix II applies to personal information we collect about Applicable State Residents on or through our Services and through other means (such as information collected offline or in person).
In addition to your rights in Section 6 above, you can:
ask us to confirm we are processing your personal information; and
opt out of processing or sharing of your personal information for online targeted advertising purposes. If you would like to opt out of Letters From Rocky's use of your information for such purposes, you may do so by notifying us via email at info@LettersFromRocky.com.
Certain information may be exempt from such requests under applicable state data privacy law. Depending on where you live, if we deny your request to exercise your rights in whole or in part, you may have the right to appeal the decision. In such circumstances, you may contact us at info@LettersFromRocky.com with the subject “Data Privacy Request Appeal” to provide us with details about why you are appealing the decision.
Residents of the state of Colorado may review the table in Appendix I(a) above for additional details on how we process Letters From Rocky Controlled Information about you.