1. The Data We Collect About You
When you use our Website or contact us through it, we may collect the following types of Personal Data on you:
- Identity Data includes your first and last name.
- Contact Data includes your email address and telephone number.
- Business Data includes your company name, industry and position.
- Location Data includes the country/region from which you access the Website.
- Usage Data includes information about how you use or interact with our Website (such as, when you entered the Website, how long you stayed on the Website and/or a specific page on the Website).
- Technical Data includes information on your internet connection (such as your IP address and internet service provider name), on the device and software that you are using to access the Website (e.g., your web browser type and computer operating system).
- Additional Inquiry Data includes additional information that you may provide when you contact us through the Website or when you sign up for any of our services.
We also collect, use and share aggregated data such as statistical data for any purpose. Such information does not reveal your identity and therefore is not considered Personal Data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature available through the Website.
Protecting the Privacy Rights of Third Parties
If you provide us any Personal Data relating to others, you must make sure that you have permission to do so.
2. How We Collect Your Personal Data
We use different methods to collect data from and about you including through:
- Direct interactions. When use the Website, contact us through our website, register to our newsletter, or otherwise provide your Personal Data directly to us, you will be asked to provide us with your Identity Data, Contact Data, Business Data and/or Location Data so that we can provide our services to you, respond to your questions or requests or otherwise contact you. You may also provide Additional Inquiry Data in such instances.
- Automated technologies or interactions. As you interact with our Website, we automatically collect the applicable Technical Data and Usage Data. We collect this data by using cookies, server logs, and other similar technologies.
- Third parties or publicly available sources. We may receive Technical Data and Usage Data about you from third parties, such as Usage Data and Technical Data that we may receive from analytics providers, and from advertising and marketing partners.
You are not legally obligated to provide any Personal Data to Cloozz. Any Personal Data that you choose to provide to Cloozz, is provided at your own free will.
3. How We Use Your Personal Data
We will only use your Personal Data when permitted by law. We will commonly use your Personal Data in the following circumstances:
- Where the processing is necessary in connection with the performance of any contract we have entered into with you or where it is necessary for taking steps at your request prior to entering a contract.
- Where the processing is necessary for our legitimate interests (or those of a third party), and such legitimate interests are not overridden by your interests, fundamental rights, or freedoms. Legitimate interest means our interest in managing and conducting our business.
- Where the processing is necessary for compliance with a legal or regulatory obligation.
- Where you have provided your consent for such processing. Such consent can be revoked at any time.
Purposes for Which We Use Your Personal Data
Below is a description of the ways we use your Personal Data. To the extent that the GDPR and/or UK GDPR apply, we have mentioned the legal bases we rely on to use your Personal Data, and identified what our legitimate interests are where appropriate:
- We use your Identity Data, Contact Data, Business Data and/or Location Data to enter into a contract or to perform a contract with you. We also use your Usage Data and Technical Data for the performance of a contract with you (to provide our services to you via the Website).
- We use your Usage Data, Technical Data, Location Data and Contact Data for marketing purposes, to deliver relevant and personalized content to you, send service messages (for example, for security purposes) and to measure or understand the effectiveness of our marketing efforts. We do so where it is necessary for our legitimate interests (to grow our business, to inform our marketing strategy and to maintain and secure the services); or if we have obtained your prior consent (where laws require consent for such communications).
- We use your Usage Data and Technical Data to improve our Website, services, marketing, customer relationships and experiences, including by personalizing and customizing our content. We do so where it is necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).
- In the event of a legal dispute between you (and/or a party on your behalf) to us (and/or a party on our behalf), we may use your Personal Data to the extent necessary in connection with handling such dispute. We do so where it is necessary for our legitimate interests (to defend and enforce our legal rights).
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.
You may receive marketing communications from us if you have requested information from us and you have not opted out of receiving marketing communications.
You can change your contact preferences at any time through your account or by sending us an email with your request to: firstname.lastname@example.org. If you wish to stop receiving marketing communications from us, you may ask us to stop sending you marketing communications at any time by following the opt-out link on any marketing message sent to you or by contacting us.
Cookies and Other Tracking Technologies
We automatically collect Personal Data through cookies and similar technologies when you interact with our Website. For additional information on how we use such technologies, please read our cookies policy, available here.
In addition, our website may use Google Analytics (or similar service providers) to collect information about the use of our Website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our Website, what pages they visit, and what other websites they have used before coming to our Website. We use the information we get from Google Analytics to analyze traffic, remarket our products and services to users, improve our marketing, advertising, and to improve our Website. We have enabled Google Analytics advertising features such as remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. For more information on how Google collects and processes your data, visit https://www.google.com/policies/privacy/partners/ . Google provides website visitors the ability to prevent their data from being used by Google Analytics. For more information see: https://tools.google.com/dlpage/gaoptout
We may also use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors.
4. Sharing Your Personal Data with Third Parties
We share Personal Data with third party service providers that provide us services in connection with the purposes listed above.
For example, we may share your applicable Identity Data, Contact Data, Usage Data and Technical Data with web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Website. For additional information, please see the description above in the section titled Cookies and Other Tracking Technologies.
We may also share your Personal Data with legal and regulatory authorities to the extent required by applicable law our professional advisors (e.g. lawyers, accountants) to the extent necessary for the provision of their services to us; and third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire.
In order to use the Website, you must be at least 18 years of age or older, if otherwise required by the laws of the country you reside in. Our Website is not designed for use by anyone under the age of 18 and we do not knowingly collect Personal Data from children under the age of 18.
If you are a parent or legal guardian and have concerns about your child’s privacy, or if you believe that your child may have provided us with their Personal Data, please contact us using the Contact Details below. When you approach us as a parent or legal guardian, we may request that you provide certain information needed to confirm your identity, in order to prevent malicious removal of account information.
6. International Transfers
We may transfer your Personal Data to countries outside of the country in which you reside (including outside of the European Economic Area (EEA) or the United Kingdom (UK)), that do not necessarily provide the same level of data protection as the country in which you reside and are not recognized by the European Commission and/or the applicable UK authority as providing an adequate level of data protection.
Our international transfers of Personal Data are done for the performance of a contract or implementation of pre-contractual relations with you, based on your consent, or subject to safeguards that ensure the protection of your Personal Data, such as standard contractual clauses approved by the European Commission and/or the applicable UK authority (when the transfer is outside of the EEA or the UK).
7. Data Security
We have put in place security measures intended to prevent your Personal Data from accidental or unlawful loss, use, alteration or disclosure. We also maintain reasonable technical and physical safeguards to protect your Personal Data. Unfortunately, we cannot guarantee against the loss or misuse of your Personal Data or secure data transmission over the Internet because of its nature.
8. Data Retention
We retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for legal or reporting requirements.
In order to determine the appropriate retention period for Personal Data, we consider the following criteria: the volume, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Personal Data, the purposes for which we collect and process Personal Data, the timeframe during which we may require such Personal Data in connection with potential litigation, and applicable legal requirements.
9. Your Rights
Certain privacy laws, including the GDPR and UK GDPR, provide users with rights related to their Personal Data. To the extent that such laws apply to your Personal Data, you may have the following rights:
- Request access. This means that you may receive a copy of the Personal Data we hold about you.
- Request correction. This means that you may ask us to correct or complete inaccurate or incomplete data that we hold about you.
- Request erasure. This means that you may ask us to delete or remove Personal Data that we hold about you. If we are unable to comply with such request, we will notify you of the specific legal reasons for our decision.
- Object to processing. This means that you may object to the processing of your Personal Data where it is used for direct marketing purposes, or where we are relying on a legitimate interest and you feel that such interest is overridden by your rights and freedoms.
- Request restriction of processing. This means that you may ask us to suspend the processing of your Personal Data if you believe that such data is inaccurate, if our processing is unlawful or if we no longer need to process such data for a particular purpose, but you need us to continue to hold the data.
- Data Portability. This means that you may request that we transfer your Personal Data to you or to a third party. This right applies where we have obtained and processed the data from you based on your consent or where we used the information to perform a contract with you.
- Withdraw consent at any time. This means that you may withdraw your consent where we are processing your Personal Data based on your consent.
If you wish to exercise any of the rights set out above, please contact us email@example.com.
What We May Need From You
When you approach us with a request to exercise one of your rights, we may request that you provide us with information needed to confirm your identity as a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it.
Time Limit to Respond
We try to respond to all legitimate requests within one month or less, if required by law. Where it takes us more than one month to respond (for example, where your request is particularly complicated or where you have made a number of requests) we will notify you and keep you updated.
If you have a disability and would like to access this policy in an alternative format, please contact us via our Contact Details listed below.
11. Contact Details
If you have any questions or concerns, please contact us at:
Postal address: 7 Rival St., Tel Aviv, Israel
You have the right to make a complaint at any time to data protection authorities. We would, however, appreciate the chance to address your concerns before you approach a data protection authority, so please contact us in the first instance.
This version was last updated on January 25th, 2024.