Privacy Policy

Privacy Policy – for End User Software License Agreement

Last update: January 8, 2019

Introduction

Carbyne Ltd. (“us“, “we”, “our” or “Company“) respect the privacy of our users (each, “you” or “User“) and are committed to protect the privacy of Users who access, download, install or register to our desktop, mobile or web application (VLR) (the “Application“), or any other online services we provide (collectively: the “Services“).The Company has prepared this Privacy Policy to outline our practices with respect to collecting, using and disclosing your Personal Information when you use the Services.

We do not sell or offer our Services to children. As such, our Services are design for adult user interaction. We do not intentionally collect Personal Information from children under the age of 16. If you are under 16, be sure to get your parent(s)/guardian(s) to read and discuss it with you. We will ask you relevant written justification(s) that you get the consent of your parent(s)/guardian(s) before giving any information or sending any materials to us.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using the Services, you (and your parent(s)/guardian(s), if applicable) agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to the Privacy Policy. If you (or your parent(s)/guardian(s), if applicable) do not agree with this Privacy Policy, please do not supply any Personal Information and do not use our Services.

In this Privacy Policy you will read about, among other things:

– Parents’/Guardians’ consent

– Data controller and data processor

– What type of Personal Information we collect

– Mobile analysis

– How we use your Personal Information

– With whom we share the Personal Information and for what purpose

– For how long we retain the Personal Information

– How we protect your Personal Information

– How to contact us

 

Parents’/Guardians’ consent 

If you are under 16, you will always need to get your parent(s)/guardian(s) permission before contacting and interacting with us.

We may need to check that your parent(s)/guardian(s) agree that you will use our Services. As part of this check, we may ask you for your parent’s/guardian’s contact details (e.g., email address or telephone number) so we can then contact them and obtain their consent.

We may also carry out checks to ensure that the contact details you have provided for your parent(s)/guardian(s) are your actual parent(s)/guardian(s). If we find out that you have given us fake details about your parent(s)/guardian(s) or if we do not get a reply from your parent(s)/guardian(s) within a reasonable time, we may be incapable to offer our Services to you.

Data controller and data processor

For the purposes relating to our Services (see our section “How we use your Personal Information”), the Company, as identified in Section “Information about Us”, is the data controller.

For the purposes relating to the emergency services available through our Application, the relevant body, entity, authority or service is the data controller. For this purpose, the Company is considered as a data processor. In this case, the processing of your Personal Information by the data controller, especially the videos, images and/or sounds that you may issue through your device, may be based on (i) the necessity to comply with legal obligation to which the data controller is subject, (ii) the necessity to protect the vital interests of a person, and/or (iii) the necessity to perform a task carried out in the public interest or in the exercise of official authority vested in the data controller.

What type of information we collect

We may collect two types of data and information from our Users.

The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website’s domain name from which you linked to the Services, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, online browsing, etc.).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information“).

 “Personal Information” or “Personal Data” includes information information that can be used to identify you as a natural person, directly or indirectly, in particular in combination with other information available to us such as an identification number, online identifier or one or more factors specific to your identity as a natural person.

Such information may include:

–  Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself : phone number, first and last name, home and work address, e-mail, age, gender. You may register to the Services through your social network account or directly through the Application. If you are under 16, we may also ask you for your parent’s/guardian’s contact details (e.g., email address or telephone number), so we can then contact them and obtain their consent. This collection of Personal Information relies on your acceptation of our Terms and Conditions when using our Services, which includes this Privacy Policy. 

*Registering through social network account: When you register or sign-in to the Services via your social network account (e.g., Facebook), we will have access to basic information from your social network account, such as your full name, email address, birthdate, profile picture, friends list, as well as any other information you made publicly available on such account or agreed to share with us. At all times, we will abide by the terms, conditions and restrictions of the social network platform.

*Registering through the Application: When you register to the Services through the Application, we may collect from you the following information: full name, phone number, email address, profile picture, home and office address, birthdate, gender, your full contact list which is stored on your device, as well as any other information you agreed to share with us. Upon registering to the application you may provide information about disabilities or allergies. This information will be saved locally on your device and will not be accessed by us, though it may be provided to emergency services when you contact them using the Service. 

–  Voluntarily Information: We may collect information which you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports which you send to us. Please note that we may also collect complaints about you from other Users, which may include your Personal Information. This collection of Personal Information relies on your acceptation of our Terms and Conditions when using our Services, which includes this Privacy Policy. 

–  Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address) as well as other information which relates to your activity through the Services.

–  Background Mode Information: When you use the application to call an emergency service we may collect and process your location data and video to provide them to the emergency call center. You agree that we may access this data to provide it to the emergency service when you call an emergency service directly through your device’s dialer and/or contacts app (and not through our application).

For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.

Mobile analysis

We may use various tracking technologies or methods of web and mobile analysis (e.g., Mixpanel, etc.) to gather, store, and track certain Personal Information related with your access to and activity through the Services. This collection of Personal Information may be based on your consent, where required, and/or our legitimate interest to provide best quality service and experience to our Users, and to personalize our Services

How we use the information

We use and share Personal Information in the manners described in this Privacy Policy. In addition to the purposes listed above, the Personal Information we collect is used for the following purposes:

–  To set up your account and to provide the Services;

–  To use your parent’s/guardian’s contact details and obtain their consent to your use of the Services (if you are under 16);

–  To allow you to share and view content shared on the Services;

–  To identify and authenticate your access to certain features of the Services;

–  To send you relevant push notifications, which are based on different activities offered by the Services, such as: automatic SMS after a call, etc.

–  To communicate with you and to keep you informed of our latest updates;

–  To market our website, products and the Services;

–  To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests;

–  To support and troubleshoot the Services and to respond to your queries;

–  To investigate and resolve disputes in connection with your use of the Services;

–  To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and

–  To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

 With whom we share the information and for what purpose

We do not rent, sell, or share your Personal Information with third-parties except as described in this Privacy Policy.

We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers; (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) processing such information to assist us with our business operations; (iii) performing research, technical diagnostics, personalization and analytics; (iv) providing you with the emergency services available through our Application.

For the purposes described above, we may transfer your Personal Information outside the European Union or the Economic Area, provided that:

– The data transfer is carried out to country whose legal regime is deemed by the European Commission to provide for an “adequate” level of  personal data protection; and/or

– The data transfer is governed by a valid mechanism recognized as such by the European Commission (e.g. Standard Contractual Clause, Binding Corporate Rules, or the Privacy Shield framework).

We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

Third-party collection of information

Our Privacy Policy only addresses the use and processing of Personal Information we collect from you. To the extent that you disclose your Personal Information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the Personal Information you disclose to them.

You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

For how long we retain the information

We respect your privacy rights and therefore you may contact us at any time and request: (i) to access, delete, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted); or (ii) that we will cease any further use of your Personal Information (for example, you may ask that we will stop using or sharing your Personal Information with third-parties) or that we shall remove your Personal Information (subject to any other legal obligation that may require us to keep the information).

Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

We usually keep your Personal Information for the following retention periods:

– Personal Information relating to your account: 5 years following your last interaction with our Services;

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at contact@carbyne911.com

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.

Your rights

In accordance with the applicable data protection laws and regulations, you have the following rights regarding the processing of your Personal Information. These rights may be limited or restricted pursuant to applicable laws and regulations, in which case we will inform you of these limitations or restrictions.

You may exercise these rights by contacting us (see section “How to contact us” below).

These rights being purely personal, they may only be exercised by you. Please attach a copy of a valid ID document to your request; we will only retain that copy for the time necessary to verify your identify.

Right of access

You may request access to your Personal Information that is processed by us. In this case, we will provide you with a copy of Personal Information we have relating to you, as well as with all mandatory information regarding processing of this Personal Information, namely:

– The categories of collected and processed Personal Information;

– The purposes of processing;

– The categories of data recipients;

– The data retention period(s);

– Information regarding your rights as data subject.

Right to data portability

For those of the processing activities described above which are based on your consent or on their necessity for performance of a contract to which you are a party, you also have a right to data portability.

This right differs from the right of access in that (i) it only covers Personal Information we collected from you and (ii) it allows you to obtain a copy of your Personal Information in a structured, machine-readable format.

The right to data portability also allows you to request transmission of such Personal Information to another data controller, at your own choice, to the extent that it is technically feasible.

Right to rectification

You have a right to request the rectification of your Personal Information, provided that such Personal Information is inaccurate, incomplete or outdated.

Right to erasure

You may request erasure of your Personal Information from us and our processors’ servers and files in the following cases:

– In case your Personal Information is no longer necessary for the purposes for which it has been collected and processed;

– In case you have withdrawn your consent (if consent was legally required) and there is no other legal basis for the processing;

– In case you have objected to the processing of your Personal Information (see section “Right to object to processing” below);

– In case the processing of your Personal Information is illicit;

– In case your Personal Information must be erased by us in order to comply with our legal obligations;

– In case you were a minor at the time of collection of your Personal Information through our Services.

If your Personal Information has been shared with third parties, we shall inform these third parties of your request for erasure, to the extent that it is feasible.

Right to object to processing

For those of the processing activities which are based either on:

– out or a third party’s legitimate interest, or

– performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller,

You have a right to object to such processing on grounds relating to your particular situation.

You also have an unconditional right to object to any processing activities which purpose is direct marketing.

Right to limitation of processing

You may request limitation of processing of your Personal Information in the following cases:

– In case you request rectification of your Personal Information, for the duration necessary to check that Personal Information;

– In case processing is illicit and you prefer to limit it rather than erasing the concerned Personal Information;

– In case you want us to retain your Personal Information in order for you to use it in the context of a judicial claim; or

– In case you have objected to the processing of your Personal Information by us, for the period necessary for us to assess the grounds relating to your particular situation.

We will in such case cease to process the concerned Personal Information and retain them for the appropriate duration.

Right to provide instructions relating to the use of your Personal Information after your death

If you are a French resident, you have a right to provide us with instructions relating to retention, erasure or communication of your Personal Information after your death.

Right to withdraw consent

For those of the processing activities which are based on your consent, you have a right to withdraw such consent at any time, without justification.

Right to lodge a complaint with a supervisory authority

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at contact@carbyne911.com.If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you have a right to lodge a complaint relating to the processing of your Personal Information by the Company with the competent supervisory authority in your country.

How we protect your information

We take great care in implementing and maintaining the security of the Services and your Personal Information. We employ industry standard procedures and policies to ensure the safety of your Personal Information, and prevent unauthorized use of any such Personal Information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at contact@carbyne911.com.

Corporate transaction

We may share information, including Personal Information, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.

Updates or amendments to the Privacy Policy

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our website (https://carbyne911.com/term-of-use-privacy-policy) or Application (as reflected in the “Last Revised” heading). In the event of a material change to the Privacy Policy, we will notify you through the Services or via email, or you may be notified within the Application. We encourage you to review this Privacy Policy regularly for any changes.

Your continued use of the Services, following the notification of such amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions regarding the Services or the information that we collect about you and how we use it, and for any request regarding your rights, please contact us at contact@carbyne911.com.

For any question relating to the emergency services available through our Application, or if you wish to contact the body, authority, service or other entity providing the emergency services, please directly contact such body, authority, service or other entity. If we receive a request relating to such emergency services, we will promptly transfer your request to the relevant body, authority, service or other entity, as relevant.  

Information about us

The details of the Company are as follows:

Carbyne Ltd.

94 Yigal Alon, Tel Aviv-Yafo, Israel

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