Last Updated: September 1, 2019
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Company gathers from users of the Website Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system and browser type, and the locations of the Web pages the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not personally identifiable, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company analyzes Non-Personally-Identifying Information gathered from users of the Website to help Company better understand how the Website is being used. By identifying patterns and trends in usage, Company is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Company may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline Web Cookies on an individual basis.
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to provide analytics services, inform, optimize, and serve ads based on your past activity on our websites and applications, including Google Analytics for Display Advertising. These vendors may use Web Cookies, Web Beacons and other technologies to collect information about your use of the Website, our service and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver content targeted to your interests on our service and other websites and better understand your online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser () and/or opt out from Google Analytics for Display Advertising or the Google Display Network. You can do so by using Google’s Ads Settings (www.google.com/settings/ads). For more information about interest-based ads, or to opt out in general of having your web browsing information used for behavioral advertising purposes, please visit .
Legal basis (GDPR only) – Consent and Legitimate interest (e.g. essential cookies).
Aggregated and Non-Personally-Identifying Information
We share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also share aggregated information with third parties, including advisors and investors, for the purpose of conducting general business analysis. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when:
(1) Participating in polls, surveys or other features of our service, or responding to offers or advertisements, for the purpose of process your answers and contact you in case that you win the survey. The information collected includes user’s name, address, email address, and telephone number, information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic information, and other relevant information provided/supplied by you. Legal basis (GDPR only) Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and legitimate interest (e.g. process your answers in polls and surveys)
(2) Communicating with us, for the purpose of process and answer your questions, provide support (e.g., to solve problems or issues), and customize your experience and provide a demo. The information collected includes user’s name, address, email address, and telephone number, information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic information, and other relevant information provided/supplied by you. Legal basis (GDPR only) Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and legitimate interest (e.g. respond to an inquiry sent by you)
(3) Signing up to receive newsletters or other information, for the purpose of send you marketing communications. The information collected includes name and email address. Legal basis (GDPR only) consent and legitimate interest (e.g. send marketing communications).
(4) Applying for job positions, for the purpose of process your job application and assess you as a candidate. The information collected includes full name, address, email address, and telephone number, CV and other relevant information provided/supplied by you. Legal basis (GDPR only) Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and legitimate interest (e.g. assess you as a candidate)
Users of the Website are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features.
BY USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
We occasionally use your name and email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We also send you service-related announcements from time to time through the general operation of the service.
Company will disclose Personally-Identifying Information under the following circumstances:
Marketing Communications. Company will email users about products and services that Company believes may be of interest to them, consistent with your consent. If a user wishes to withdraw consent and stop receiving marketing materials from Company, user may do so by following the unsubscribe link in email communications or contacting us using the contact information on the Website or by sending an email to email@example.com.
Third Party Service Providers. We share your Personally-Identifying Information, which includes your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services includes fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting surveys and other features offered through our Website. These service providers have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose e.g. AWS provide our Cloud services.
To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
Where you have provided your consent to us sharing the Personally- Identifying Information (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
If you want to receive the list of recipients of your Personally-Identifying Information, please make your request by contacting us to
Finally, please note that some of the abovementioned Personally- Identifying Information will be used for fraud detection and prevention, and for security purposes.
ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONALLY- IDENTIFYING INFORMATION
Storage: AWS – Ireland / Ohio
Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. Companies of the group are located in Israel and the UK.
Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.
Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
Changing Personally-Identifying Information
PERIOD OF STORAGE OF COLLECTED INFORMATION
Personally-Identifying Information. Your Personally-Identifying Information will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personally-Identifying Information perpetually.
We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.
In addition, in some circumstances we may store your Personally-Identifying Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personally-Identifying Information or dealings.
The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You have the right to request that we rectify any Personally-Identifying Information we hold that it is inaccurate or misleading;
You have the right to request the erasure of the Personally-Identifying Information that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
The right to object, to or to request restriction, of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
The right to data portability. This means that you may have the right to receive your Personally-Identifying Information in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
You have the right to object to profiling;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority;
The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
You also have a right to request details of the basis on which your Personally-Identifying Information is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us at firstname.lastname@example.org. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personally-Identifying Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS
DO NOT TRACK POLICY
Our Website does not respond to “Do Not Track” signals or mechanisms.