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Privacy Policy

ACTIVEFENCE PRIVACY POLICY

Last Updated: November 8th, 2020

In order to ensure transparency and give you more control over your Personal Information, this privacy policy (“Privacy Policy”) governs how we, ActiveFence Ltd. and our subsidiaries (together, “ActiveFence” “we”, “our” or “us”) use, collect and store Personal Information that we collect or receive from or about you (“you”) in the following use cases:

  1. When you browse or visit our website https://www.activefence.com/ (“Website”)
  2. When you contact us (e.g. via our Website, email or social media profiles)
  3. When we process your job application
  4. When you attend a marketing event and/or provide us with your Personal Data for marketing purposes
  5. When we use the Personal Data of our service providers (e.g. contact details)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

  1. What Personal Data we collect, why we collect it, and how it is used
  2. How we protect and retain your Personal Data
  3. How we share your Personal Data
  4. Additional information regarding transfers of Personal Data
  5. Your privacy rights.
  6. Use by children
  7. Interaction with third party products
  8. Log files
  9. Analytic tools
  10. Specific provisions applicable under California Privacy Law
  11. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.


1. WHAT PERSONAL DATA WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

1.1 Specific Personal Data we collect

  • Analytic tools, cookies and log files

1.1.2 Why is the Personal Data collected and for what purposes?

  • When you make use of our Website, we will collect information from cookies implemented by third parties, in order to improve our Website and enhance your user experience.

1.1.3 Legal basis (GDPR only, if applicable)

  • Legitimate interest (e.g., essential cookies)
  • Consent (for non-essential cookies)

1.1.4 Third parties with whom we share your Personal Data

  • AWS (Cloud Provider)
  • Google Analytics
  • HotJar – Analytics

1.1.5 Retention period

  • Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

1.1.6 Consequences of not providing the Personal Data

  • Certain non-essential Website features may not be available

1.2. WHEN YOU CONTACT US (E.G. VIA OUR WEBSITE, EMAIL OR SOCIAL MEDIA PLATFORMS)

1.2.1 Specific Personal Data we collect

  • Name
  • Email address
  • Any other information that you decide to provide/supply us with.

1.2.2 Why is the Personal Data collected and for what purposes?

  • To process and answer your questions and respond to your requests

1.2.3 Legal basis (GDPR only, if applicable)

  • 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 (i.e. services agreement).
  • Legitimate interest (e.g., to process and answer your questions).

1.2.4 Third parties with whom we share your Personal Data

  • AWS (Cloud Provider)
  • Google Analytics
  • HotJar – Analytics
  • HelpRange- Analytics
  • MailChimp
  • Newsletter CRM

1.2.5 Retention period

  • Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

1.2.6 Consequences of not providing the Personal Data

  • Cannot process and answer your questions or respond to your requests

1.3 WHEN WE PROCESS YOUR JOB APPLICATION

1.3.1 Specific Personal Data we collect

  • Full name
  • Email address
  • CV 
  • Any other information that you decide to provide/supply.

1.3.2 Why is the Personal Data collected and for what purposes?

  • To process your job application
  • To assess your suitability for the role
  • To schedule an interview
  • To communicate with you regarding the role.

1.3.3 Legal basis (GDPR only, if applicable)

  • 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 (i.e. employment contract).
  • Legitimate interest (e.g., in processing your application for the purpose of evaluating you for the applicable position).

1.3.4 Third parties with whom we share your Personal Data

  • ATS (Applicant Tracking System)

1.3.5 Retention period

  • Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

1.3.6 Consequences of not providing the Personal Data

  • Cannot process your job application
  • Cannot assess your suitability for the role
  • Cannot schedule an interview
  • Cannot communicate with you regarding the role

1.4 WHEN YOU ATTEND A MARKETING EVENT AND/OR PROVIDE US WITH YOUR PERSONAL DATA FOR MARKETING PURPOSES

1.4.1 Specific Personal Data we collect

  • Full name
  • Email address
  • Phone number
  • Title
  • Company name
  • Any other information that you decide to provide/supply us with

1.4.2 Why is the Personal Data collected and for what purposes?

  • To send you marketing communications
  • To initiate a business communication and establish and business relationship

1.4.3 Legal basis (GDPR only, if applicable)

  • Legitimate interest (e.g., in contacting you after you showed interest in our products and services).
  • Consent

1.4.4 Third parties with whom we share your Personal Data

  • MailChimp – CRM
  • Salesforce – CRM

1.4.5 Retention period

  • Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

1.4.6 Consequences of not providing the Personal Data

  • Cannot send you marketing communications
  • Cannot initiate a business communication and establish and business relationship

1.5 WHEN WE USE THE PERSONAL DATA OF OUR SERVICE PROVIDERS (E.G. CONTACT DETAILS)

1.5.1 Specific Personal Data we collect

  • Full name
  • Email address
  • Company name
  • Phone number
  • Address
  • Any other information that you decide to provide/supply us

1.5.2 Why is the Personal Data collected and for what purposes?

  • To contact our service providers
  • To perform the applicable agreement

1.5.3 Legal basis (GDPR only, if applicable)

  • 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 (i.e. services agreement).
  • Legitimate interest (e.g. perform the contract, send contract-related communications).

1.5.4 Third parties with whom we share your Personal Data

  • Our internal Files where we manage our vendors
  • Our auditors or investors, if they request to review contracts

1.5.5 Retention period

  • Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

1.5.6 Consequences of not providing the Personal Data

  • Cannot contact our service providers
  • Cannot perform the applicable agreement

Please note that some of the above mentioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).


2. HOW WE PROTECT AND RETAIN YOUR PERSONAL DATA

2.1 Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2.2 Retention of your Personal Data. In addition to the retention criteria mentioned above, in some circumstances we may store your Personal Data 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 Personal Data or dealings.


3. HOW WE SHARE YOUR PERSONAL DATA

3.1 In addition to the recipients described above, we may share your Personal Data as follows:

3.2 With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.

3.3 To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

3.4 If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;

3.5 In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events; and/or

3.6 Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).


4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

4.1 Storage: See table above.

4.2 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.

4.3 Internal transfers: Transfers within the ActiveFence group will be covered by an intra-group internal data processing agreement.

4.4 External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will execute standard contractual clauses, if applicable.


5. YOUR PRIVACY RIGHTS

5.1 Rights: The following rights (which may be subject to certain exemptions or derogations) apply to certain individuals (some of which only apply to individuals protected by specific laws):

  • You have a right to access Personal Data 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 Personal Data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability in certain contexts. This means that you may have the right to receive your Personal Data 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 the right to withdraw your consent at any time. 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. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
  • 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 or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

5.2 You can exercise your rights by contacting us – privacy@activefence.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law 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 or verify your identity and for security purposes, before processing and/or honoring your request. 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.


6. USE BY CHILDREN

In the context of the use cases described in this privacy policy, we do not knowingly collect Personal Data from children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@activefence.com.


7. INTERACTION WITH THIRD PARTY PRODUCTS

In case we enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”), we are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service

8. LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.


9. ANALYTIC TOOLS

We currently use Google Analytics and Hotjar. We reserve the right to remove or add new analytic tools.


10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

10. 1 Do Not Track Notice. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services. 10. 2 Deletion of Content from California Residents. If you are a California resident under the age of 18, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content. 10. 3 Your Choices. You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.

11. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@activefence.com.