Table of Content
- Who we are
- Your acknowledgement of this policy
- Which information may we collect about Users?
- How do we collect information about our Users?
- What are the purposes of the collection and processing of information?
- Sharing Personal Information with Third Parties
- Your Rights
- Location of Your Data
- Third Party Service Providers and Third Party Software
- Links to Third Party Websites
- Data Retention
- Have any Questions?
In this policy, references to Wibbitz, or to “we” or “us” are to Wibbitz Ltd. and its affiliates, which is a registered company in the state of Israel (No. 514471606) at 27 Montifiore St.,Tel-Aviv, Israel. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at firstname.lastname@example.org.
We collect from Users of our Site and/or Platform, two types of data and information:
4.1 Non-personal Information.
The first type is non-identifiable and anonymous information. Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).
You may access and browse the Site and/or Platform without voluntarily providing personal information, although, like most online services, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site and/or Platform, the activities of the User on the Site and/or Platform and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers such as Google Analytics to obtain detailed analytics on the device and the User’s behavior on the Site and/or Platform.
4.2 Personal Information.
The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:
4.2.1 Personal Information which is provided voluntarily:
- Opening an Account: In order to use the Platform, you will be required to provide us with certain Personal Information, including: username, password, name, email address.
- Communications with Wibbitz: Personal Information you provide us as part of any communications with Wibbitz, by any means, including by responding to surveys, approaching our customer services or during sales calls (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences). We may record such calls for quality assurance purposes and in order to improve our services.
- Contact Details: when you enquire about our services from the Site and/or Platform, request a demo of our Platform or download content from out Site, we will ask you to provide us some or all of the following details: full name, e-mail address, company, type of company, company size, job role, country and your phone number. You may also voluntarily join our mailing list by providing us with your email address.
Use of the Platform: any other Personal Information you voluntarily upload to the Platform, at your sole discretion, including texts and videos which contain Personal Information.
- Job Applicants: information you provide us when applying for a position via the “Jobs” page available on the Site, as further detailed under Section 4.2.3 below.
4.2.2 Personal Information collected via technology:
- Geolocation data: while using the Site and/or Platform we will access, collect, process, monitor and/or remotely store “geolocation data”, including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes. Please note that we may also analyze your IP address, using our third party service providers, in order to determine the name of the company whose IP address you have used to browse our Site and/or Platform, for the purpose of locating prospects and in order to analyze our Site and/or Platform’s traffic.
- Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 4.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
- Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), Apple IDFA or another unique identifier.
4.2.3. Personal Information relating to job applicants:
You may use the “Jobs” page available on our Site in order to apply for a position at Wibbitz and send us your CV, and in such case the following applies:
- As part of the submission of an application, you will be required to provide your full name, email address and phone number and attach your CV. You may also voluntarily provide us with links to your LinkedIn profile and/or Personal website, attach a cover letter and/or portfolio and send us a personal note.
- The Personal Information collected as part of the application process, including any Personal Information included in your CV, may be accessed by our HR department and/or by Wibbitz managers, worldwide, solely for the purposes of evaluation and to enable us to contact you with respect to the recruitment process.
- Wibbitz will retain Personal Information collected from applicants solely for future consideration by Wibbitz (e.g. future positions at Wibbitz) or for the maximum statutory period in which a claim with respect to the recruitment process may be brought against Wibbitz. If you do not wish for your Personal Information to be retained by Wibbitz for future consideration please contact us at email@example.com and we will delete it from our records.
- Please note that if you have successfully recruited to work for Wibbitz, any Personal Information collected as part of the application process may be retained by Wibbitz for the purposes of your employment.
4.2.4. Personal Information Collected from Third Parties:
We may collect Personal Information about you and your company from public sources, such as Google or other internet search engine results, or publicly available data from Facebook, Twitter, LinkedIn and similar social media. We may also collect Personal Information that we receive from our Service Providers, including our advertising and market research partners, who may provide us with information about your interest in and engagement with our online advertisements.
- We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
There are three main methods we use to collect information:
5.1. We collect information through your entry, connection, access and/or use of the Site and/or Platform.
In other words, when you access or use the Site and/or Platform we are aware of your usage of the Site and/or Platform, and may gather, collect and record the information relating to such usage. For example, when you use the Site and/or Platform, we gather your Technical and Behavioral Information.
5.2. We collect information which you provide us voluntarily.
For example, we collect Personal Information that you provide via the Request a Demo on our Site and/or Platform. We will inform you prior to collecting your Personal Information if it is requested on a voluntary basis and the consequences of not providing voluntary Personal Information.
5.3. We collect information from public sources.
We may supplement personal information that we collect about you with information which you have made public on websites associated with you or your company or on social media platforms such as LinkedIn.
6.1. Non-personal Information is processed in order to:
- Enhance the User’s experience on the Site and/or Platform;
- Create statistical information and learn about the preferences of Users and general trends on the Site and/or Platform (e.g. understand which features are more popular than others); and
- Keep the Site and/or Platform safe and secured and for prevention of fraud.
6.1.1. Personal Information is processed in order to:
- Enable the operation of the Site and/or Platform and administer your account;
- To register your interest in becoming a new customer;
- Contact you by telephone and/or by email with further information relating to our products or services which you enquired about via the Site. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you;
- Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone, through web-browser notification or through the post. You have the right to opt-out of marketing messages at any time by following the instructions in such message or by contacting us at: firstname.lastname@example.org. For email marketing to an individual subscriber (that is, a non-corporate email address) with whom we have not previously engaged as a client, we need your consent to send you unsolicited email marketing;
- Personalize your experience on the Site and/or Platform;
- Ensure that content on the Site and/or Platform is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
- Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
- Keep the Site and/or Platform safe and secured and for prevention of fraud and crime;
- Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site and/or Platform;
- Maintain our data processing records and general administrative purposes;
- Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
Note to our Users in the EU:
In order for Wibbitz to process your Personal Information, as detailed herein, such processing must be justified by a “basis” for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:
- the processing is necessary to comply with a legal obligation – we may process your Personal Information for disclosure of information to authorities; and
- the processing is in our legitimate commercial interests – subject to your interests and fundamental rights, under our legitimate interest in marketing our products and services via the Site and/or Platform and offering the public comfortable and safe access to our Site and/or Platform, we shall perform the Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the Site and/or Platform, assisting us to prevent crime and fraud, manage our internal operations, maintaining records and email tracking. We may also use the information contained in certain cookies and other such files or tags based on such ground for our legitimate interests in a safe and user-friendly presentation of our Site and/or Platform. Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
Note to non-EU Users:
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR PLATFORM, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.
7.2. In addition to using the information collected by us for the purposes described under Section 6 above, we may also share your information in the following cases:
- Local Distributors and Sales Representatives: When you provide us with your contact details via the Site or make certain requests for information about Wibbitz products or services, we may transfer your name and contact information to the local distributor, dealer, reseller or sales representative of Wibbitz products and services that is located close to your location, solely in order to enable us to respond to your request. We identify the nearest distributor, dealer or sales representative using the location that you provided us. Please note that we instruct our local distributors, dealers, resellers and sales representatives to maintain appropriate data security safeguards in place and they are contractually restricted from using your Personal Information for any purpose other than in order to offer you Wibbitz’s products and services, and/or in order to respond to any other specific request that Wibbitz has received from you. We note that such distributors, dealers, resellers and sales representatives may separately ask you to provide your name and contact information for other marketing activities. Any information that you may transfer to them directly will be used by them according to their privacy practices and Wibbitz will not be responsible for their use of such information.
- Wibbitz Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of Wibbitz for the sole purpose of enabling the operation of the Site and/or Platform and to contact you (as detailed in Section 6 above). Please note that all Wibbitz personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
- Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processers who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site and/or Platform. Please note that we collect, hold and manage your Personal Information through a third party’s cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 11 below.
7.3. For avoidance of doubt, Wibbitz may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site and/or Platform.
Wibbitz acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: email@example.com and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:
- Right to access: you may have the right to request a review of your Personal Information held by Wibbitz. We may refuse to comply with your access request if the request is manifestly unfounded, excessive or repetitive in nature.
- Right to erasure: under certain conditions, you may be entitled to require that Wibbitz will delete or “block” your Personal Information (e.g. if the continued processing of those data is not justified).
- Right to Portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity). The right to data portability only applies where your Personal Information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
- Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either “public interest” or “legitimate interests”, those lawful bases are not absolute, and you may have a right to object to such processing. Where you object on grounds of legitimate interest, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
- The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
- Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
To exercise these rights, where applicable, please contact us by sending an email to: firstname.lastname@example.org
Note to our Users in the EU:
If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries.
In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:
- Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;
- Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;
- Transferring your Personal Information to organizations that are Privacy Shield Scheme certified, as approved by the European Commission.
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE AND/OR PLATFORM, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.
The Site and/or Platform is intended for Users over the age of sixteen (16). Therefore, Wibbitz does not intend and does not knowingly collect directly Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site and/or Platform.
11.2. Note, that we collect, hold and/or manage your Personal Information through Wibbitz’s authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.
11.3. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
11.4. Such third parties service providers include without limitation the following categories of service providers:
- CRM management platforms
- ERP platforms;
- Advertising Networks;
- Business Intelligence, Data Warehousing, and Data Analytics platforms;
13.1. We take appropriate measures to maintain the security and integrity of our Site and/or Platform and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.
13.2. Your Personal Information is hosted on Amazon Web Services (AWS) servers, which provide advanced strict security standards (both physical and logical).
13.3. Some of the security measures that we employ include, without limitation: highly secure services design and implementation using state of the art encryption and architectures mechanisms, and restriction of access to your Personal Information to individuals who need access to it in order to process it on Wibbitz’s behalf.
Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
13.4. Wibbitz will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.
13.5. TO THE EXTENT THAT WIBBITZ IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, WIBBITZ SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.
Wibbitz will retain the Personal Information for as long as we are comfortable that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.