Privacy Policy

LUMIGO LTD. PRIVACY POLICY

Last Updated: May 7, 2019

This privacy policy (“Privacy Policy”) governs how we, Lumigo Ltd. (together, “Lumigo” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“User”, “you”) such as in the following use cases:

  • When you browse or visit our website, https://www.lumigo.io/ (“Website”);
  • When you make use of, or interact with, our Website
    1. When you request a free trial
    2. When you register to our blog
    3. When we process your job application
    4. When you contact us (e.g. customer support, help, submit a request)
  • When you make use of our Platform
    1. When you sign up for an account, login and purchase our services
    2. When you create administrators for your use of the Platform
    3. When your administrator user create users for your use of the Platform
  • When you attend a marketing event and provide Personal Data
  • When you exchange business cards with us
  • When we use the Personal Data of our service providers
  • When we use the Personal Data of our customers
  • When you interact with us on our social media profiles (e.g., Facebook, LinkedIn, Twitter, Instagram)

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” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Table of contents:

  1. What information we collect, why we collect it, and how it is used
  2. Period of storage of collected information
  3. How we protect and store your information
  4. How we share your personal data
  5. Additional information regarding transfers of personal data
  6. Your rights
  7. Use by children
  8. Public information about your activity on the services
  9. How can I delete my account?
  10. Links to and interaction with third party product
  11. Log files
  12. Cookies and other tracking technologies
  13. Analytics tools
  14. California privacy rights
  15. Our California do not track notice
  16. Deletion of content from California residents
  17. How to 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 the Privacy Policy, as indicated below.  If there will be any significant changes made 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 INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Data we collect Why is the data collected and for what purposes?   Legal basis (GDPR only)     Consequences of not providing the data    
When you browse or visit our Website
Cookies   For more information, please read our Cookie Policy   marketing, analytics and  statistics, to provide better service Consent   Legitimate interest (e.g. essential cookies)     Cannot collect and store the information   Cannot use or access some parts of the Website
When you make use of, or interact with, our Website
When you request a free trial
· Full name · Email address · Company name · Phone number · Any other data that you decide to supply/provide us     · To provide a free trial     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.   Legitimate interest (e.g., To provide a free trial)     Cannot provide a free trial      
· Full name · Email address   · To send marketing communications Consent Cannot send marketing communications
When you register for our blog
· Email address
· Google and/or Facebook log-in
· Message / comments    
· To add you to our blog distribution list
· To allow you to post in our blog    
Consent   Legitimate interest (e.g. to allow you to post in our blog)       Cannot add you to our blog distribution list   Cannot allow you to post in our blog
When we process your job application
· First name
· Last name
· Email address
· Phone number
· Resume
· LinkedIn profile
· Personal website
· Cover letter
· Portfolio
· Personal note
· Any other data that you decide to supply/provide us  
· To process your job application  
· To assess the candidate      
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   Legitimate interest (e.g. process your job application) Cannot process your job application   Cannot assess your suitability as a candidate  
When you contact us (e.g. customer support, help, submit a request)
· Full name
· Email address
· Company name
· Phone number
· Message
· Any other data that you decide to supply/provide us  
· To process and answer questions  
· To provide support (e.g., to solve problems, bugs or issues)  
· To customize your experience        
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   Legitimate interest (e.g. respond to a query sent by you)   Cannot assist you and respond your query   Cannot provide support   Cannot customize your experience  
· Full name
· Email address  
· To send marketing communications   Consent Cannot send marketing communications
When you make use of our Platform
When you sign up for an account, login and purchase our services
· Full name
· Email address
· Company address
· Company name
· Job position
· Phone number
· User name
· Password
· Payment methods
· Any other data you decide to provide/supply    
· To create an account  
· To fulfill your requests for products and/or services and for related activities (e.g., product and service, account management)  
· To perform/execute the agreement  
· To grant you access to the services (our Platform)    
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.   Legitimate interest (e.g. sign up to the service).         Cannot create an account   Cannot fulfill your request for products and/or services   Cannot perform the agreement   Cannot grant you access to the services  
· Full name
· Email address  
· To send marketing communications Consent Cannot send you marketing communications
When you create administrators for your use of the Platform
· Full name
· Email address
· Phone number
· User name
· Password
· Any other data you decide to provide/supply    
· To create administrator users for your use of the Platform  
· To perform/execute the agreement  
· To grant you and your admin users access to the services (our Platform)      
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.   Legitimate interest (e.g. to create administrator users).     Cannot create administrator users for your use of the Platform   Cannot perform the agreement   Cannot grant you access to the services  
· Full name
· Email address  
· To send marketing communications Consent Cannot send you marketing communications
When your administrator user create users for your use of the Platform
· Name
· Email address
· Phone number
· User name
· Password
· Any other data you decide to provide/supply          
· To create users for the use of the Platform  
· To perform/execute the agreement  
· To grant you, your admin users, and users access to the services (our Platform)        
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.   Legitimate interest (e.g. to create users).   Cannot download the app   Cannot perform the agreement   Cannot grant you access to the services    
· To send marketing communications Consent Cannot send you marketing communications
When you attend a marketing event and provide Personal Data
· Full name
· Company name
· Job position
· Email address
· Phone number
· Any other data that you decide to supply/provide us
· To establish a business connection
· To send marketing communications      
Depending on the context, consent or legitimate interest (e.g. send you more information about Lumigo)     Cannot establish a business connection   Cannot send you marketing communications
When you exchange business cards with us
· Full name
· Company name
· Job position
· Email address
· Phone number
· Any other data that you decide to supply/provide us
· To establish a business connection
· To send marketing communications  
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 (e.g. showing you certain products and features that you have shown an interest in).   Legitimate interest (e.g. certain B2B discussions)   Consent Cannot establish a business connection   Cannot send you marketing communications
When we use the Personal Data of our service providers and suppliers
· Full name
· Company name
· Job title
· Email address
· Phone number
· Any other data that you decide to supply/provide us
· To contact our service providers
· To perform the applicable agreement    
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   Legitimate interest (e.g. perform the contract, send contract-related communications)   Cannot communicate with you   Cannot perform the agreement  
When we use the Personal Data of our customers
· Full name
· Company name
· Email address
· Phone number
· Any other data that you decide to supply/provide us
· To provide our products and services  
· To perform the applicable agreement  
· To communicate with our customers/clients  
Processing is necessary for the performance of a contract to which our customer is a party.   Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).   Legitimate interest (e.g. send you contract-related communications) Cannot provide the services and/or our products   Cannot perform the agreement   Cannot communicate with you  
· Full name
· Email address  
· To send marketing communications Consent Cannot send you marketing communications
When you interact with us on our social media profiles (e.g., Facebook, LinkedIn, Twitter, Instagram)
· Full name
· Company name
· Email address
· Phone number
· Any other data that you decide to supply/provide us
· To reply and/or respond to your request or question
· To establish a first business connection/discussion
· To send marketing communications    
Depending on the context, legitimate interest (e.g. replying your requests/questions), pre-contractual discussions (e.g. if you show interest in our products/services) or consent   Cannot reply or respond to your request   Cannot establish a business connection   Cannot send you marketing communications

Finally, please note that some of the abovementioned Personal Data will be used for fraud detection and prevention, and for security purposes.

  1. PERIOD OF STORAGE OF COLLECTED INFORMATION

Personal Data. Your Personal Data (as described above) 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 may 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 Personal Data perpetually.

Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookie policy [add link to the cookies policy] 

  1. HOW WE PROTECT AND STORE YOUR INFORMATION
  • Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. 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.
  • Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 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.
  1. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described in Section 1, we may share your information as follows:

  • 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;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. 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 or assign Personal Data in connection with the foregoing events.
  • We use third party platforms in the context of the use cases mentioned in Section 1.  For more information on Lumigo subprocessors please email privacy@lumigo.io.
  • Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

Storage: We store our information in AWS located in Oregon, US.

Access from Israel is covered by Israel’s Adequacy Decision and involves no data transfer issue. You can read more about this here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Internal transfers: We ensure transfers within the Lumigo group will be covered by an agreement entered into by members of the Lumigo group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to;

External transfers:

  • 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; or
  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
  1. YOUR RIGHTS

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 Personal Data we hold that it is inaccurate or misleading;
  • You have the right to request the erasure of the Personal Data 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 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 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 Personal Data 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 privacy@lumigo.io. 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 Personal Data 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.

  1. USE BY CHILDREN

We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

  1. PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE SERVICES

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Website or otherwise through the Services.

Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

Please also remember that if you choose to provide Personal Data using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

  1. HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing privacy@lumigo.io. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

  1. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS


The Website may enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and 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 may collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

  1. LOG FILES

We may make use of 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 may use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

  1. COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Website may utilize “cookies”, anonymous identifiers and other tracking technologies in order for us to provide our Website and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website. Certain cookies and other technologies may serve to recall Personal Data, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

  1. ANALYTIC TOOLS
  • Google Analytics. The Website may use a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  1. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to info@ClientName.com. Please note that we are only required to respond to one request per customer each year.

  1. OUR CALIFORNIA DO NOT TRACK NOTICE

We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties 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

  1. DELETION OF CONTENT FROM CALIFORNIA RESIDENTS

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Data you have publicly posted. To remove, please send an email to privacy@lumigo.io. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

  1. 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 info@lumigo.io.

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