1. INTRODUCTION AND GENERAL BACKGROUND
1.1 Click-INS Ltd. ("
Click-Ins",
"
we", "
our", or "
us") presents this privacy policy, as may be amended from time to time (the "
Privacy Policy") in order to provide our website user ("
User", "
you" or "
your") information about Click-INS’s privacy and data protection practices in relation to personal data that is collected, used and/or otherwise processed by Click-INS and/or third parties acting on its behalf, through its website
www.click-ins.com (the "
Website").
1.2 The Website presents Click-INS’s activities and services. Please note that a separate privacy policy applies to our Services and is provided to individuals using our Services prior to processing their data.
1.3 When accessing, browsing and using the Website, you may be required to provide Click-INS with personal data about yourself that is protected by law. As a result, Click-INS, as data controller, has implemented appropriate security measures in order to protect your personal data.
1.5 If you have questions or concerns regarding this Privacy Policy, please contact us at:
support@click-ins.comPLEASE SEE OUR FULL PRIVACY POLICY BELOW IN ORDER TO BETTER UNDERSTAND OUR PRACTICES IN DETAIL.
2. WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU?
2.1 Definition. When we use the term “personal data” in this Privacy Policy, we mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly.
2.2 Collection of personal data – General provisions. We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any personal data when you use the Website, and the provision of it is solely based on your free will.
2.3 Personal data that you provide us with. We process the following categories of personal data directly from you through the Website:
2.3.1 Identification data (i.e., full name, country)
2.3.1 Identification data (i.e., full name, country)
2.3.2 Contact details (i.e., email address)
2.3.4 Any data related to your exchanges with Click-INS to contact us or request a demo (e.g., date, area of subject and content of your exchanges with Click-INS' staff)
The provision of certain types of personal data may be necessary or optional, depending on your requests. Mandatory data will be marked as such at the moment of collection of your personal data. If you refuse to provide mandatory data, Click-INS may not be able to process your request (e.g., provision of a demo, reply to your contact request).
2.4 Personal data that we collect automatically from you. Each time you visit our Website we may automatically collect the following data through cookies and other tracking technologies:
2.4.1 Internet or other electronic network activity information (e.g., Internet protocol (IP) address; date and time of the visit; time and length of visits to certain pages; page interaction information, such as scrolling, clicks, and mouse-overs; methods used to browse away from the page; traffic data; location).
These cookies are used to enhance your browsing experience, serve personalized ads or content, and analyze our traffic. For more information on cookies, please see our Website Cookie Policy. Link to the Page 3. FOR WHAT PURPOSES DO WE USE YOUR PERSONAL DATA?
Managing your demo request
Managing your contact requests
Improving the Website and your user experience
Supporting and enhancing data security measures of the Website
Pre-litigation or litigation management
Compliance with legal and regulatory obligations
Example of use of personal data
- to schedule a demonstration of our services with our staff
- to potentially purchase our services
- to answer your questions
- to respond to inquiries
- to contact you if necessary
- to monitor and analyze your use of the Website
- to develop, customize and improve the Website
- research and further development, analysis and statistics
- to prevent and mitigate the risks of fraud, error or any illegal or prohibited activity
- technical administration and troubleshooting of the Website
- to diagnose and repair Website errors, and, in cases of abuse, track and mitigate the abuse
- to manage any dispute or litigation involving you with respect to the Website
- to establish, protect, or exercise our legal rights
- to defend against legal claims
- to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights
- to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities
- to process your requests to exercise your rights
To take steps prior to entering into a contract
Legitimate interest of Click-INS in managing the contact requests sent to it
Legitimate interest of Click-INS to improve its Website and User’s experience
Legitimate interest of Click-INS to secure its Website and User’s experience
Legitimate interest of Click-INS in defending its rights and interests
Legal and regulatory obligations to which Click-INS is subject
4. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
4.1 We will share your personal data with third parties, as detailed below:
4.1.1 Service Providers, including analysis services and performance measurement services. We will share personal data to perform services on our behalf or complementary to our own, depending on each of their specific roles, for operational, commercial and technical purposes related to the management of the Website and its services.
4.1.2 Governmental, Administrative or Judiciary Authorities. We may disclose personal data in case of a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
4.1.3 Corporate Transactions. We may share personal data in connection with any proposed or actual financing, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
4.1.4 Lawyers and Interested Parties. We will share personal data exclusively in case of management of possible disputes and other legal matters where appropriate.
5. HOW IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE OF YOUR COUNTRY?
5.1 General provisions. We may store or process your personal data in several jurisdictions other than the country of your jurisdiction. In some jurisdictions, the level of protection of your personal data may be lower than in the country of your jurisdiction.
5.2 EEA Transfers. When we transfer personal data from within the European Economic Area ("EEA") to countries or international organizations that are based outside the EEA, the transfer takes place on the basis of an adequacy decision by the European Commission, or in the absence of an adequacy decision, other legally permitted safeguards under the GDPR.
5.3 Israeli Transfers. When we transfer personal data from the State of Israel to a third country outside Israel, the transfer takes place on the basis of: (i) a country declared as offering equivalent level of protection by the Israeli Privacy Protection Authority; (ii) another approved transfer mechanism under the Israeli regulations; or (iii) your consent to transfer your personal data to other jurisdictions, understanding that in some countries the level of protection may be lower than in Israel.
6. HOW LONG DO WE STORE YOUR PERSONAL DATA FOR?
6.1 We retain personal data for as long as we deem it is necessary in order to maintain our relationship with you and provide you with our Website, as required by applicable laws and/or to fulfill our legitimate interests.
6.2 Other circumstances in which we will retain your personal data for longer periods of time include:
6.2.1 where we are required to do so in accordance with legal and regulatory requirements, or
6.2.2 for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or
6.2.3 if we reasonably believe there is a prospect of litigation.
6.3 Please note that except as required by applicable law, we will not be obligated to retain your personal data for a particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.
7. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
7.1 We endeavor to maintain appropriate technical and organizational measures to protect personal data in particular, against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
7.2 However, although we make every effort to protect the personal data which you provide to us or we generate, we cannot completely ensure the security of any personal data you transmit to us over the internet or guarantee that this personal data will not be accessed, disclosed, altered, or destroyed.
7.3 If you have found a vulnerability or would like to report a security incident, you may send an email to
support@click-ins.com8. WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL DATA?
8.1 General Provisions for all Jurisdictions
8.1.1 Please note that you may have certain rights regarding the manner of collection, processing, and usage of your personal data pursuant to applicable privacy and data protection laws.
8.1.2 You may have all or some of the following rights depending on your jurisdiction, and, in most cases, you can exercise them free of charge. At any time, you may contact us at:
support@click-ins.com. We will consider all such requests and provide our response within a reasonable period and in any event within any time period required by applicable privacy and data protection laws.
8.1.3 When you ask us to exercise any of your rights under this Privacy Policy and the applicable privacy and data protection laws, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data which is related to others that you are not authorized to receive, and to ask you questions to understand better the nature and scope of data that you request.
8.1.4 We may redact from the data we will make available to you any personal data related to others. In addition, we may delete your personal data without further notice if we are required to by applicable privacy and data protection laws.
8.2 Data Rights for Israeli Users. If you are based in Israel, you are entitled to request us to:
8.2.1 Review and access your personal data that we process;
8.2.2 Update, amendment, and deletion of personal data which is incomplete, incorrect, outdated or unclear.
8.3 EEA Users. If you are based in the EEA, you have the following rights:
8.3.1 You have the right to access your personal data in order to obtain clear, transparent and understandable information on how we process your personal data and on your rights (as provided in this Privacy Policy), as well as a copy of your personal data.
8.3.2 You have the right to rectify your personal data in case your personal data is obsolete, inaccurate or incomplete.
8.3.3 You have the right to object the processing of your personal data when the processing is based on Click-INS’ legitimate interest. We will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g., legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims.
8.3.4 In certain circumstances under GDPR, you have the right to restrict the processing of some of your personal data during a limited period of time.
8.3.5 You have the right to withdraw your consent when it has been obtained and processing is based on consent.
8.3.6 In certain circumstances under GDPR, you have the right to request data portability, meaning that you can receive the personal data originally provided by you in a structured and commonly used format or that you can request the transfer of the personal data you provided to another data controller. This right applies only if it fulfils certain conditions under GDPR.
8.3.7 In certain circumstances under GDPR, you have the right to delete your personal data (also known as the right to be forgotten).
8.3.8 If applicable, you may request not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect concerning you or similarly significantly affects you and if automated processing is used.
8.3.9 You have the right to
lodge a complaint with your national data protection authority where we are based. If you have a complaint about how we use your personal data, we will always prefer you to contact us first. If you are unsure which data protection authority to contact, please contact us at
support@click-ins.com.
9. WHAT IS OUR POLICY REGARDING MINORS?
9.1 The Website is not intended for use by minors and we do not knowingly collect and process personal data relating to minors.
9.2 If these age requirements are not met, you are required to avoid using the Website. We will discard any personal data we receive from a minor immediately upon discovering that such a user shared personal data with us.
10. DOES THIS PRIVACY POLICY APPLY TO THIRD PARTY LINKS?
10.1 You may, during your use of the Website, access links to or other websites operated by third parties.
10.2 Please note that this Privacy Policy only applies to personal data that we (or third parties on our behalf) collect from or about you on the Website only and we cannot be responsible for personal data collected and stored by third parties.
10.3 Third party websites, have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal data to these websites.
10.4 We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.
11. SOCIAL MEDIA WIDGETS
11.1 Our Website includes social media feature, i.e., LinkedIn™ button. This feature will collect your IP address and which page you are visiting on our Website. They will also set a cookie to enable the feature to function properly.
11.2 Social media feature is hosted by a third party. Your interactions with this feature are governed by the privacy policy of the company, social media platform or third-party service, providing it.
12. CHANGES TO THIS PRIVACY POLICY
12.1 This Privacy Policy may change from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page. Each version of this Privacy Policy will be identified by its effective date, which you can find at the top of this Privacy Policy. The new Privacy Policy will be effective from the date mentioned at the top page of the new Privacy Policy.
12.2 We strongly encourage you to review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.
13. HOW TO CONTACT US?
If you have any comments or questions regarding this privacy policy or the information practices in connection with the Website, please contact us at
support@click-ins.com.
