Last updated: January 13, 2020
“Personal Data” as used in this Policy means information relating to an identified or identifiable natural person.
We may change this Policy from time to time in order to keep you apprised of our data collection and use practices. We encourage you to regularly visit and review this Policy to stay informed of such practices.
Table of Contents
What information we collect and how we use it
A. Information you Provide
- 1.1 Account
- 1.2 Support Requests
- 1.3 Contacting Us
- 1.4 Newsletter or Marketing Sign Up
- 1.5 Surveys & Feedback
- 1.6 Business Contact Information
- 1.7 Applying for a Position
B. Information we Automatically Collect
- 1.8 Cookies
2. How (and with whom) we Share your Personal Data
- 2.1 Law Enforcement or Other Government Entities
- 2.2 With your Consent
- 2.3 Disputes
- 2.5 Mergers and Acquisitions
- 2.6 Affiliates
3. Your GDPR Rights
4. Transfers of Personal Data to other Countries outside the EU or EEA
5. Your California Privacy Rights
- 5.1 Disclosure of Direct Marketing Practices
- 5.2 Removal of Public Information
6. California Do Not Track Notice
7. Personal Data of Children
8. EasySend as a Processor
9. Our Contact Information
1 WHAT INFORMATION WE COLLECT AND HOW WE USE IT.
This section describes the ways in which we collect and receive information from outside our company and affiliates. It includes information on what Personal Data is collected, the purpose for which it is collected, the legal basis for the processing of the data, to whom it is transferred, and the period for which it is retained. This description may be supplemented by additional information in other parts of this Policy. For example, you may find for more information on third-parties to whom your information may be transferred, such as SalesForce, in Section 2 below.
A. Information you Provide
1.1 Support Requests.
If you contact us by email or phone to request support in connection with your use of the Platform or your Account, or if we contact you in connection with a support request, you will be asked for your full name, email address and a phone number. We use this information to verify your identity, identify the product or service which you have purchased, process your request and contact you regarding your request (or to answer your question). We may also store the details of the request in order to present this information to you as part of your account history, in order to display and contact you with information that is relevant to you in the future, and to assist you with further requests for support. We will also use the details of your request (including information about you) for our own review of our customer support and communication practices. The legal basis for our collection and use of information is the performance of our contract with you and our legitimate interest. Such information is transferred to and stored with SalesForce, a third-party customer resource manage service. We maintain Personal Data provided in connection with support requests until your Account is terminated and for a period of seven (7) years after termination.
1.2 Newsletter or Marketing Sign Up.
If you sign up to receive promotions, newsletters or other commercial or marketing communications from us on our Site, a landing page you may arrive at after clicking on an advertisement, or in a form we otherwise make available, you will be required to provide your email address so that we may send you such communications. The legal basis for our collection and use of information is your consent. Your email-address is transferred to and stored with SalesForce, a customer resource management service. You may request that we stop sending you such communications at any time, including by using the “unsubscribe” link at the bottom of e-mails we send. We retain the Personal Data you provide in connection with such communications for a period of seven (7) years after unsubscribing.
1.3 Requesting a Demonstration.
If you sign up to schedule or “Request a Demo” on our Site, a landing page you may arrive at after clicking on an advertisement, or in a form we otherwise make available, you will be asked to provide your name, email address, phone number, and additional information on your interest in EasySend and the problems you would like to solve. We will use such information to contact you regarding our products and services, schedule a demonstration and provide you with information relevant to you. The legal basis for our collection and use of information is your consent. Such information is transferred to and stored with SalesForce, a customer resource management service. We retain the Personal Data you provide in connection with such requests for a period of seven (7) years after unless you or the entity your represent becomes a customer of ours. In such case, such information will be linked with your Platform and Support Site account and we will use it to provide you with the Platform and support, and will be used as described in Section 1.4 (Business Contact Information) below.
1.4 Business Contact Information.
If you have provided us with your business card (including electronically), have sent us an e-mail which lists your contact information (for example as part of your e-mail signature), or have otherwise provided us with your business contact information, such as in a meeting or at an event hosted or attended by us, or if you have entered into an agreement with us to receive or provide products or services, we save your name, email address, company, position, phone number, address (“business contact information”) and use it to contact you in connection with our business or potential business relationship.
If you are or represent a customer, or purchase a subscription to our Platform, this information is linked with your Platform and Support Site account. We will use this information to set up your Platform account credentials (for the Platform “builder” and our Support Site), to contact you in connection with your Account, provide you with the Platform and support, display information relevant to you, verify your identity, or use it to prevent fraud or illegal behavior.
Where we have a contract with you (whether represent a customer or supplier of ours), the legal basis for our collection and use of such information is the performance of our obligations and exercising our rights under our contract with you. Otherwise, the legal basis for our collection and use of your business contact information is our legitimate interest.
Business contact information of representatives of our customers and potential customers is transferred to and stored with SalesForce, a customer resource management service. Business contact information of representatives of our suppliers or potential suppliers is stored on DropBox, a file storage service provided by the Dropbox International Unlimited Company. We retain business contact information for a period of seven (7) years after the termination of any agreement we may have with you, in order to exercise any legal rights we may have in connection with the agreement or our relationship, or, if no such agreement was executed, for a period of seven (7) years from the time the information is received.
1.5 Applying for a Position.
When you apply for a position or otherwise make an inquiry regarding employment with us, including by filling out and submitting a “join our team” or similar form on our Site, sending us an email, or through a third party recruiting or human resources provider, we will (but are not obligated to) use the information you provide to contact you regarding your application or inquiry, to evaluate your experience, skills and suitability for a position, and to verify your identity and other information you provide, contact previous employers, and conduct background checks (to the extent legally permissible).
We may also share this information with affiliates which may have an opening for employment or with our third party recruiting or human resources providers who advise us and assist us in evaluating applicants and processing applications. We will save your name, phone number, email address, phone number, URL of your LinkedIn or other profile page you provide, information about the position for which you applied or inquired, your CV/resume and other documents or information you provide for a period of seven (7) years from the date you provide such information or, if later, the date we complete our review of your suitability for a position.
1.6 Contacting Us.
If you submit the “Contact us” form on the Site, we ask you to provide us with your full name, phone number, email address, and information regarding the nature of your inquiry. We will use the information you provide in order to respond to your request or inquiry. If your request is for support, we will use the information as described in Section 1.2 above. The legal basis for our receipt and use of such information is your consent. Such information is transferred to and stored with SalesForce, a customer resource management service. We retain such information for a period of seven (7) years, in order to respond to related requests you may make in the near future. If, after contacting us, you or the entity your represent, subsequently purchase a product or service, this information will be treated as “business contact information” as described above.
B. Information we Automatically Collect
2. How (and with whom) we Share your Personal Data
In addition to any methods or third parties with whom we may share your Personal Data described above, we share Personal Data in the following manner:
2.1 SalesForce. We use a third-party customer relationship management service known as “SalesForce” to manage our relationships with, customers’ and potential customers, including customer Accounts, communications (such as newsletters and marketing communications), and support requests. Other than Personal Data of our Suppliers, Personal Data you provide is transferred to SFDC Ireland Limited (“SalesForce”), a provider of the SalesForce service. We manage and control the information through our account with SalesForce. Our relationship with SalesForce is governed by a written agreement which includes a data processing obligation on the part of SalesForce in respect to how they handle Personal Data we provide to them.
2.2 Law Enforcement or Other Government Entities. Where required by law or government or court order, we will disclose Personal Data relating to you, but only to the extent we are required to do so by law.
2.3 With your Consent. In the event that you have requested or have consented to the transfer of Personal Data relating to you (such as by checking a box to signify your agreement) we will transfer Personal Data to the relevant third party.
2.4 Disputes. In case of any dispute with or concerning you, we may disclose Personal Data relating to you with our legal counsel, professional advisors and service providers, the relevant court or other tribunal and other third parties as needed in order to resolve the dispute, defend ourselves against any claims, or enforce our rights.
2.5 Mergers and Acquisitions. In the event that we, or a part of our business, are sold to a third party, or if we are merged with another entity, or in the event of bankruptcy or a similar event, we will transfer information about the relevant portions of our business as well as relevant customers and users, to the purchaser or the entity with which we are merged.
2.6 Affiliates. We share Personal Data with our affiliates, such as our U.S. affiliate, EasySend, Inc., who assist us in processing Personal Data and providing our Services.
3. Your GDPR Rights.
Subject to certain exceptions and exclusions, the following rights apply to individuals who are located in an EU member states or otherwise protected by the EU General Data Protection Regulation (“GDPR”), as further described below. If you are such a person, then:
- Right of Access. You may request that we confirm to you whether or not we store Personal Data about you and to receive a copy of the Personal Data we maintain about you and information about: (a) the purposes of the processing of the Personal Data; (b) the categories of Personal Data being processed; (c) the names of the recipients or the categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) if possible, the period we believe we will store the Personal Data, or the criteria we use to determine that period; (e) the sources of the Personal Data, if not collected from you; and (f) whether we use automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
- Right to Rectify. You may request that we correct any Personal Data about you that we maintain that is incorrect. Depending on the purpose for which the data is used, you may also request to complete incomplete Personal Data we maintain.
- Right to Erasure (“Right to be Forgotten”). You may request that we erase or suppress Personal Data that relates to you in the following cases: the data is no longer needed by us; the data was collected and is used on the basis of your consent and you withdraw that consent; when you have a right to object to our use of the data (as described below under, “Right to Object”); we are not lawfully processing the data; or we are otherwise required by law to delete the data. However, there may be circumstances in which we may retain your data or we may refuse your request, for example, when we review the data to defend ourselves or make legal claims or exercise are own rights. In addition, this right may not apply to the display or access of your Personal Data outside of the European Union.
- Right to Restrict Processing. You may request that we restrict our use or processing of your Personal Data if: you claim the Personal Data is inaccurate, during the time we investigate your claim; our processing of the Personal Data was unlawful; we no longer require the Personal Data; we processed the Personal Data for our legitimate interests and you object to this use (as you are permitted to do under Article 21(1) of the GDPR), during the time that we investigate whether our legitimate interests override your request. However, there may be circumstances in which we are legally entitled to refuse your request.
- Right to Data Portability. You may request that we provide you with your Personal Data that we process based on your consent or to fulfill a contract with you or that we process using automated means, in a structured, commonly used and machine-readable format, and to transfer your Personal Data to another entity or have us transfer it directly to such entity.
- Right to Object. You may, based on reasons specifically relating to you, object to our processing of your Personal Data, when: (i) the data is used for our legitimate interests and our interests in processing the data does not override your interests, rights and freedoms and we do not require use of the data for the establishment, exercise or defense of our legal claims or rights; and (ii) we use the data for direct marketing purposes or profiling for direct marketing purposes.
- Right to Object to Automated Decision Making. You may request that you not to be subject to a decision based solely on automated processing, including profiling, when the decision produces legal effects concerning you or significantly affects you.
- Right to Withdraw Consent. Where we process Personal Data relating to you based on your consent (such as by clicking a checkbox adjacent to a statement of consent), you may withdraw your consent and request that we cease using your Personal Data for the purpose for which you have your consent, or altogether, depending on the situation.
- Right to Make a Complaint. You may file a complaint regarding our practices with the data protection authority in your place of habitual residence, place or work, or the place of the alleged infringement. For a list of data protection authorities in the European Economic Area, please see here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
You can exercise your rights that apply to us by contacting us by email at firstname.lastname@example.org.
We may be permitted by law (including the GDPR and local national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order to comply with your request, including information needed to locate the information requested or to verify your identity or the legality of your request. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.
Furthermore, the above rights apply in respect of Personal Data we have collected and maintain about such individuals on our own behalf (i.e., as the “controller”), for information about how you may exercise such rights (and whether they may be exercised) when we process and maintain such information on behalf of a third party (i.e., as a “processor”), please see Section 10 (EasySend as Processor) below.
4. Transfers of Personal Data to other Countries outside the EU or EEA
We transfer Personal Data we receive in or from the European Union (and other locations) to the following countries outside the EU and European Economic Area:
- Israel, where we are located. As of the date of this Policy, the European Commission has determined that the State of Israel adequately protects Personal Data. (A list of countries which the European Commission has determined to adequately protect Personal Data can be found, as of the date of this Policy, here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).
- The United States, where our US affiliate, EasySend Inc., is located as well as where SalesForce and DropBox store information on our behalf. The transfer of data to each of these entities is subject agreements which include the obligations with respect to the processing of Personal Data in the form approved by the EU Commission. Furthermore, as of the date of this Policy, both SalesForce and Dropbox certify compliance with the US-EU Privacy Shield Framework for the protection of Personal Data.
If you are an individual protected by the GDPR, you may contact us in order to obtain additional information regarding the basis for the transfer of Personal Data relating to you to countries outside the European Economic Area. Please note that information or copies of documents we may provide to you in connection with such requests may be limited or redacted in order to protect the rights of third parties or to comply with contractual obligations we may have (such as obligations of confidentiality).
5. California Do Not Track Notice.
We do not track individuals’ online activities over time and across third-party websites or online services (though we do receive information about the webpage you visited prior to access the our websites, products and services such as our Site, the Platform, Support Site, and advertisement landing pages). We do not permit third-parties to track individuals’ online activities on our Site, unless it is part of a service provided to us (i.e., SalesForce). We do not respond to Web browser “do not track” signals or similar mechanisms.
6. Personal Data of Children.
Our Services are not intended for, and we do not knowingly collect Personal Data from persons under the age of eighteen (18). If you believe that a person under the age of eighteen (18) has provided us with Personal Data, or if we have received the Personal Data of such person, please contact us at email@example.com.
7. EasySend as a Processor
This Policy applies to our collection, receipt and handling of Personal Data on our own behalf and for our own purposes, in the capacity of what is often described as a “controller” or “data controller” (“Controller”). It does not apply to our receipt of Personal Data from, and the processing of such information on behalf of, a third party, such as when we provide them with a service, we do so as what is often described as a “processor” (“Processor”).
8. Our Contact Information
For inquiries regarding this Policy, you may contact us as follows:
18 Yosef Karo Street
Tel Aviv, Israel