Last updated: March 1, 2020
Table of Contents
- What information we collect and how we use it
- How (and with whom) we Share your Personal Data
- Rights of EU individuals under the GDPR
- Transfers of Personal Data to other Countries outside the EU or EEA
- Your California Privacy Rights
- California Do Not Track Notice
- Personal Data of Children
- Unsubscribing to Commercial Messages
- Anonymous Information
- WHAT INFORMATION WE COLLECT AND HOW WE USE IT.
We collect and receive Personal Data from you when you submit or send us information about yourself and when you visit our Site and we use this Personal Data as follows:
- Contacting Us. If you contact us to make certain requests or to ask questions, whether by email or through a contact form we make available on the Site (“Contact Form”), we will use this information to respond to your requests or questions. When you submit information through the Contact Form, we require you to provide us with a name and email address and information about your request. We also ask that you provide us with your phone number, though this is not required. We use the Personal Data you provide in order to to respond to your request. The legal basis for our use of such information is your consent. Unless otherwise required due to the nature of your request or the relationship between us, we retain such Personal Data for a period of six (6) months after we are able to respond to or resolve your request or inquiry, in case you contact us again with similar requests or problems. If we were not able to collect and process this Personal Data, we would not be able to respond to your requests properly or at all.
- Newsletter or Marketing Sign Up. In the event you sign up to receive promotions, newsletters or other commercial or marketing communications from us or otherwise request to receive such communications, we will use the Personal Data you provide (such as your email address) to send you such communications. You may contact us at any time to request that we stop sending you such communications or opt-out of such communications by using the “unsubscribe” link at the bottom of e-mails we send. The legal basis for our use of such Personal Data is your consent. We will retain it until you request to unsubscribe from or stop receiving these communications, at which point we will delete such information within a period of ninety (90) days. Without this Personal Data, we will not be able to send you such communications.
- How (and with whom) we Share your Personal Data
We share Personal Data with third parties in the following manner:
- Marketing Services. We share data we collect with our marketing agents, SANA Group Ltd., who assist us in our marketing efforts and communicating with you.
- Web Hosting. Our Site is hosted by Hilkaltex Sh.Y. (1988) Ltd. (known as “Octopus Computer Solutions”), and data collected on or through the Site is transferred to and stored by Octopus Computer Solutions.
- Data Storage. We store Personal Data on the cloud using Office 365 SharePoint, a service provided by Microsoft Corporation.
- Law Enforcement or Other Government Entities. Where required by law or government or court order, we will disclose Personal Data relating to you, but only to the extent we are required to do so by law.
- With your Consent. In the event that you have requested or have consented to the transfer of Personal Data relating to you (such as by checking a box to signify your agreement) we will transfer Personal Data to the relevant third party.
- Disputes. In case of any dispute with or concerning you, we may disclose Personal Data relating to you with our legal counsel, professional advisors and service providers, the relevant court or other tribunal and other third parties as needed in order to resolve the dispute, defend ourselves against any claims, or enforce our rights.
- Mergers and Acquisitions. In the event that we, or a part of our business, are sold to a third party, or if we are merged with another entity, or in the event of bankruptcy or a similar event, we will transfer information about the relevant portions of our business as well as relevant customers and users, to the purchaser or the entity with which we are merged.
- Affiliates. We share Personal Data with our affiliates, such as our French subsidiary, Weebit Nano France S.A.R.L., who assist us in processing Personal Data and providing our Services.
- Rights under the GDPR.
General Data Protection Regulation
Subject to certain exceptions and exclusions, the following rights apply to individuals who are protected by Regulation (EU) 2016/679, known as the
”). This includes, but may not be limited to, individuals who reside in, and who are citizens of, EU member states. If you are such a person, then:
- Right of Access. You may request that we confirm to you whether or not we store Personal Data about you and to provide you with a copy of the Personal Data we maintain about you and information about: (a) the purposes of the processing of the Personal Data; (b) the categories of Personal Data being processed; (c) the names of the recipients or the categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) if possible, the period we believe we will store the Personal Data, or the criteria we use to determine that period; (e) the sources of the Personal Data, if not collected from you; and (f) whether we use automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
- Right to Rectify. You may request that we rectify any Personal Data about you that we maintain that is incorrect. Depending on the purpose for which the data is used, this may also include the right to complete incomplete Personal Data.
- Right to Erasure (“Right to be Forgotten”). You may request that we erase or suppress Personal Data that relates to you in the following cases: the data is no longer needed by us; when the data is collected with your consent and you withdraw that consent; when you have a right to object to our use of the data (as described below under, “Right to Object”); we are not lawfully processing the data; or we are otherwise required by law to delete the data. However, there may be circumstances in which we may retain your data or we may refuse your request, for example when we review the data to defend ourselves or make legal claims or exercise are own rights. In addition, this right may not apply to the display or access of your Personal Data outside of the European Union.
- Right to Restrict Processing. You may request that we restrict our use or processing of your Personal Data if: you claim the Personal Data is inaccurate, during the time we investigate your claim; our processing of the Personal Data was unlawful; we no longer require the Personal Data; we processed the Personal Data for our legitimate interests and you object to this use (as you are permitted to do under Article 21(1) of the GDPR), during the time that we investigate whether our legitimate interests override your request. However, there may be circumstances in which we are legally entitled to refuse your request.
- Right to Data Portability. You may request that we provide you with your Personal Data that we process based on your consent or to fulfill a contract with you or that we process using automated means, in a structured, commonly used and machine-readable format, and to transfer your Personal Data to another entity or have us transfer it directly to such entity.
- Right to Object. You may, based on reasons specifically relating to you, object to our processing of your Personal Data, when: (i) the data is used for our legitimate interests and our interests in processing the data does not override your interests, rights and freedoms and we do not require use of the data for the establishment, exercise or defense of our legal claims or rights; and (ii) we use the data for direct marketing purposes or profiling for direct marketing purposes.
- Right to Object to Automated Decision Making. You may request that you not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.
- Right to Withdraw Consent. Where we process Personal Data relating to you based on your consent (such as by clicking a check box adjacent to a statement of consent), you may withdraw your consent and request that we cease using your Personal Data for the purpose for which you have your consent, or altogether, depending on the situation.
- Right to Make a Complaint. You may file a complaint regarding our practices with the data protection authority in your place of habitual residence, place or work, or the place of the alleged infringement. For a list of data protection authorities in the European Economic Area, please see here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
You can exercise your rights that apply to us by contacting us by email at firstname.lastname@example.org.
We may be permitted by law (including the GDPR and local national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order to comply with your request, including information needed to locate the information requested or to verify your identity or the legality of your request. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.
- Transfers of Personal Data to other Countries outside the EU or EEA
A. Where we store, access and transfer Personal Data
We transfer Personal Data to the following countries outside of the EU and EEA:
- Israel, where we and SANA Group are located, and Octopus Computer Solutions stores our data; and
- Australia, where we have offices (this data is not shared with third parties, but remains with us).
B. Legal Protection for Data outside the EEA
When we transfer Personal Data subject to the GDPR to third parties located in other countries outside the European Economic Area which the European Commission has not determined to adequately protect Personal Data, we enter into contractual agreements approved by the EU Commission with these recipients and receive assurances that the Personal Data will be protected. The form of such agreement is known as the “Model Clauses” and has been approved by the European Commission.
If we share Personal Data with third parties in countries which the European Commission has determined to adequately protect Personal, we may not enter into the Model Clauses. In addition, if we share such Personal Data with recipients in the United States or in Switzerland who have joined the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, we may not enter the Model Clauses with such recipients and instead rely on the Privacy Shield Framework. A list of U.S. entities which have joined the Privacy Shield Framework can be found here.
However, in certain circumstances, as permitted by applicable law, we may transfer Personal Data to which the GDPR applies to countries outside the European Economic Area or which the European Commission has not determined to adequately protect Personal Data, such as where you (if such Personal Data concerns you) have explicitly consented to the transfer, after having been informed of the possible risks, where the transfer is necessary to perform a contract with you or which is in your interest, or in other circumstances specified in Article 49 of the GDPR (Derogations for specific situations).
If you are an individual protected by the GDPR, you may contact us at email@example.com in order to obtain additional information regarding the basis for the transfer of Personal Data relating to you to countries outside the European Economic Area. Please note that information or copies of documents we may provide to you in connection with such requests may be limited or redacted in order to protect the rights of third parties or to comply with contractual obligations we may have (such as obligations of confidentiality).
- Your California Privacy Rights
If you are a California resident you have the right under California law to make certain requests in connection with our use of Personal Data relating to you, as described below. To make such a request, please contact us by email at firstname.lastname@example.org. Please note that certain exceptions may apply.
- Disclosure of Direct Marketing Practices. Under California Civil Code Section 1798.83, one time per year you may request the following information regarding our disclosure of your Personal Data to third parties for their direct marketing purposes: a list of the categories of the personal information disclosed to such parties during the preceding calendar year, the names and addresses of such third parties, and if the nature of the parties’ businesses is not clear from their names, examples of the products or services marketed by such third parties.
- Removal of Public Information. If you are under the age of 18 and have an Account, under California Business and Professions Code Section 22581, you may request the removal of content or information you have publicly posted that is identified with you or your account. Please be aware that certain exceptions may apply and we may not be able to completely remove all such information.
- California Do Not Track Notice.
We do not track individuals’ online activities over time and across third party Web sites or online services nor do we allow third parties to collect personally identifiable information about you when use the Site. We do not respond to Web browser “do not track” signals or similar mechanisms.
- Personal Data of Children.
The Site is not intended for, and we do not knowingly collect Personal Data from persons under the age of eighteen (18). If you believe that a person under the age of eighteen (18) has provided us with Personal Data, or if we have received the Personal Data of such person, please contact us at email@example.com.
- Unsubscribing to Commercial Messages.
You may request that we stop sending you commercial messages by clicking the unsubscribe link located at the bottom of the email you receive. However, we may still send you messages in connection with your Account, requests or reservations you make, to resolve disputes, or as otherwise permitted by applicable law.
- Anonymous Information.
We do not treat information we collect or receive which cannot be connected to any particular person or which is anonymized or aggregated such that it can no longer be connected to or used to identify any particular person as Personal Data even if it was originally linked to or stored with Personal Data. Such information cannot be used to identify you or any other person. We use anonymous information internally for a variety of purposes, may share it with third parties or even publish it for any reason.
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