COMPANY INFORMATION

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them). 

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• HOW WE PROTECT AND RETAIN YOUR INFORMATION

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1. Security. We have implemented technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised 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 above, please note that 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. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies, you can read more in our cookie policy.     

 

•  HOW WE SHARE YOUR PERSONAL DATA 

 

In addition to the recipients described above, we may share your Personal Data as follows:

 

1. With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies. 

2. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

3. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;

4. 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, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or 

5. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

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If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us at privacy@SafeUP.co.

 

• ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA 

 

1. Storage: We store the Personal Data with the following storing companies: AWS (Ireland), HubSpot (Germany), Intercom (USA), Twilio (USA), MicroPay (Israel), CometChat (USA).
    

2. Internal transfers: If applicable, transfers within the SafeUP group will be covered by an internal processing agreement entered into by members of the SafeUP group (an intra-group data 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.
    

3. External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. When SafeUP engages in such transfers of personal information, where required by law, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. SafeUP also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR. 

 

• YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

 

• Rights: The following rights (which may be subject to certain exemptions or derogations) may apply to certain individuals (some of which only apply to individuals protected by the GDPR) where required by law:

  • You may have a right to access Personal Data held about you. Your right of access may 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 rectify any Personal Data we hold that is inaccurate or misleading;

  • You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;

  • You have the right to object, to or to request restriction, of the processing;

  • You have 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 to profiling;

  • You have the right to withdraw your consent at any time. 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. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

  • You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;

  • You have the right to request the review of decisions taken exclusively based on automated processing if these decisions could affect your data subject rights;

  • Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

  • 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 or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
     

• You can exercise your rights by contacting us at privacy@SafeUP.co. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. 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. 
   

• Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@SafeUP.com. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public. 

 

• SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

  • This Supplemental Privacy Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”).  The CCPA provides California residents with the right to know what categories of personal information SafeUP has collected about them, and whether SafeUP disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “What Information We Collect, Why We Collect it, And How It Is Used” above, respectively. 

  • “Sales” of Personal Information under the CCPA

  • For purposes of the CCPA, SafeUP does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age, as the term “sell” is commonly understood.  That said, we do share information with third-party advertisers for the purpose of promoting our Services.  To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your information shared by disabling third-party cookies on your device, or by contacting us at privacy@safeup.co.

  • Additional Privacy Rights for California Residents

    • Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.​

  • Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.  To designate an authorized agent, please contact us as set forth at privacy@safeup.co and provide written authorization signed by you and your designated agent.​

  • Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
    If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us in privacy@safeup.co. We will process such requests in accordance with applicable laws.

  • Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

  • California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

  • Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly viewable portions of the Services by contacting us directly in privacy@safeup.co  or logging into their account and removing the content or information using our self-service tools.
     

• USE BY CHILDREN
  
  We do not offer the App to children under the age of 13. When we intend to collect Personal Data from or about children between the ages of 13 and 16 (inclusive), we take additional steps to protect children's privacy, including, without limitation, limiting our collection of Personal Data from children to no more than is reasonably necessary to participate in an online activity; giving parents access or the ability to request access to Personal Data we have collected from their children and the ability to request that the Personal Data be changed or deleted. We will obtain consent from the parents/legal guardian to this Privacy Policy for children between the ages of 13 and 16 (other than in the US and Canada). Where the parent/ legal guardian does not provide consent within seven days of receiving the consent request, SafeUP deletes all Personal Data received from or about the child. For additional information about our practices regarding children's Personal Data, please read SafeUP's Teenager's Privacy Policy available at www.safeup.co/teenage-privacy-policy.
   

• INTERACTION WITH THIRD PARTY PRODUCTS
  
  We enable you to interact with third party websites, mobile software applications and products or 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 can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications.  Providing personal information to third-party websites or applications is at your own risk.
   

• LOG FILES
  
  We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website and the apps, and gather demographic information.
   

• ANALYTIC TOOLS

  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. ​

  • Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply. 

  • Mixpanel. We collect Personal Information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.

  • AppsFlyer. We use a tool called “AppsFlyer”, a mobile attribution and marketing analytics platform to understand the use of our services. AppsFlyer is exposed to the following data: (i) unique identifiers and technical data, such as IP address, User agent, IDFA (Identifier For Advertisers) or Android ID (in Android devices); and (ii) technical data regarding your operating system, device attributes and settings, applications, advertising opt-out signals, Google Advertiser ID, in-app events, device motion parameters and carrier. The use of this data allows us to analyze our campaigns and performance, as well as your habits and characteristics. For example, the data AppsFlyer receives includes downloads, impressions, clicks and installations of their mobile applications, mobile device use and data regarding in-app events. AppsFlyer’s terms of use (available at https://www.appsflyer.com/terms-of-use/) and privacy policy (available at https://www.appsflyer.com/privacy-policy/) also apply to the use of AppsFlyer.     

  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

  • Google API. Our website and platform uses Google API in order to ensure that our users are trustworthy (for example don’t have a criminal record), convert IP to location and log in to our back office. For further details please see the Google API terms of service at https://developers.google.com/terms and the Google privacy policy at https://policies.google.com/privacy

We reserve the right to remove or add new analytic tools.

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• 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@SafeUP.co.

  • Data controller: SafeUP Ltd.     

  • DPO: Tally Bachar