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PRODALIM PRIVACY POLICY

Last Updated: 09 May 2019

This privacy policy (“Privacy Policy”) governs how we, Prodalim B.V. and any other member of the Prodalim group as applicable (together, “Prodalim”, “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“User”, or “you”) such as in the following use cases:

  1. When you make use of, or interact with our website, http://prodalim.com/(“Website”);

    1. When you click on “For more information andorder”

    2. When you contact us (e.g. customer support, when you submit an inquiry, or leave us amessage)

  2. When you attend a marketing event and provide Personal Data

  3. When you exchange business cards with us

  4. When we use the Personal Data of our customers

  5. When we use the Personal Data of our suppliers

  6. When we process your job application

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 isused

  2. How we protect and store your Personal Data

  3. How we share your Personal Data

  4. Additional information regarding transfers of Personal Data

  5. Your rights

  6. Use by children

  7. Links to and interaction with third party product

  8. Logfiles

  9. How to contactus

This Privacy Policy may 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)

Third parties with whom we share your data

Period of storage

Consequences of not providing the data

When you make use of, or interact with our Website

a.When you click on “For more information andorder”

  • Full name

  • Phone

  • Email address

  • Provide further information on our services


 

  • Discuss a business opportunity

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. send you further information on our services in a B2B context)

3rd party platforms for the following purposes:


 

  • Directnic(hosting services)

  • GoDaddy(hosting services)

  • Microsoft(email server,Europe)

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

Cannot provide further information on our services


 

Cannot discuss a business opportunity

b.When you contact us (e.g. customer support, when you submit an inquiry, or leave us amessage)

  • Title

  • First name

  • Last name

  • Company

  • Email address

  • Address

  • City

  • State/Province

  • ZIP Code/PostalCode

  • Country

  • Any other data you decide to provide/supply

  • Process your request


 

  • Assist you with your inquiry

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. provide customer support).


 

Legitimate interest (e.g. respond to your inquiry)

3rd party platforms for the following purposes:


 

  • Directnic(hosting services)

  • GoDaddy(hosting services)

  • Microsoft(email server,Europe)

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

Cannot process your request


 

Cannot assist you and respond to your inquiry

When you attend a marketing event and provide Personal Data

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Data we collect

Why is the data collected and for what purposes?

Legal basis (GDPR only)

Third parties with whom we share your data

Period of storage

Consequences of not providing the data

  • Full name

  • Email address

  • Company name

  • Contact details

  • Business information

  • Any other data you decide to provide/supply

  • Establish a business connection or discussion

Legitimate interest (sendyouB2B marketing communications)

3rd party platforms for the following purposes:


 

  • TripleC(hosting services,Israel)

  • Microsoft(email server,Europe)

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

Cannot establish a business connection

  • Send marketing communications

Depending on the context, legitimate interest (e.g. B2B marketing) or the data subject has given consent to the processing ofhisorher personal data for one or more specific purposes(e.g. receiving marketing communications)

Cannot send you marketing communications

When you exchange business cards with us

  • Full name

  • Email address

  • Company name

  • Any other data you decide to provide/supply

  • Establish a business connection

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 (sendyouB2B marketing communications)

3rd party platforms for the following purposes:


 

  • TripleC(hosting services,Israel)

  • Microsoft(email server,Europe)

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.

Cannot establish a business connection

  • Send marketing communications.

Depending on the context, legitimate interest (e.g. B2B marketing) or the data subject has given consent to the processing of his or her personal data for one or more specific purposes(e.g. receiving marketing communications)

Cannot send you marketing communications

When we use the Personal Data of our customers

  • First name

  • Last name

  • Title

  • Phone number

  • Email address

  • Contact details/emails

  • Company-related information

  • Service-related information


 

Please note, if applicable, certain data is also regulated by a Data Processing Agreement.

  • Contact ourcustomers


 

  • Provide our services and products


 

  • Perform the relevant agreement


 

  • Send contract-related communications, invoices,etc.

Processingis necessary for the performance of a contract to which the data subject is a party.


 

Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).


 

Legitimate interest (e.g.sendyou contract-related communications or B2Bmarketing communications,if any)

3rd party platforms for the following purposes:


 

  • TripleC(hosting services,Israel)

  • Microsoft(email server,Europe)

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.

Cannot communicate with you


 

Cannot provide the services or products


 

Cannot perform the agreement


 

Can notsend contract-related communications

When we use the Personal Data of our suppliers

Data we collect

Why is the data collected and for what purposes?

Legal basis (GDPR only)

Third parties with whom we share your data

Period of storage

Consequences of not providing the data

  • First name

  • Last name

  • Title

  • Phone number

  • Email address

  • Contact details/emails

  • Company-related information

  • Service-related information


 

Please note, if applicable, certain data is also regulated by a Data Processing Agreement

  • Contact our service providers


 

  • Process the order of the services


 

  • Perform/execute the agreement


 

  • Send contract-related communications, invoices,etc.

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)

3rd party platforms for the following purposes:


 

  • TripleC(hosting services,Israel)

  • Microsoft(email server,Europe)

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

Cannot communicate with you


 

Cannot process the order of the services


 

Cannot perform the agreement


 

Can not send contract-related communications

When we process your job application

  • Full name

  • Email address

  • CV

  • Cover letter

  • Phone number

  • Any other data you decide to provide/supply

  • Process your job application


 

  • Assess the candidate


 

  • Communicate with you

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. a contract of employment).


 

Legitimate interest (e.g. to assess a candidate)

3rd party platforms for the following purposes:


 

  • Directnic(hosting services)

  • GoDaddy(hosting services)

  • Microsoft(email server,Europe)

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.

Cannot process your job application


 

Cannot assess your suitability as a candidate


 

Cannot communicat ewith you

2. HOW WE PROTECT AND STORE YOUR PERSONAL DATA

  1. 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.

  2. 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.

3. HOW WE SHARE YOUR PERSONAL DATA

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

  • 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.

  • 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.

  • 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 isdisclosed.

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONALDATA

  • Access from Israel is covered by Israel’s Adequacy Decision and involves no data transfer issues. 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.

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

  • Access from the United States is covered by the EU-U.S. Privacy Shield Framework. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data isdisclosed.

5. 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 is 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 amend 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 defence 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 top rofiling;

  • 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; and

  • 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@prodalim.com.Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to ful fil 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.

6. 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.

7. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Website may enable you to interact with or contain links to 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.

8. 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 analyse trends, administer the Website, track users’ movement around the Website, and gather demographic information.

9. 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@prodalim.com.