XPLG PRIVACY POLICY

Last Updated 12 /03/2019

This is the privacy policy (“Privacy Policy”) that governs how we, XpoLog Ltd. (“XpoLog”, “XPLG”, “we”, “our” or “us”), use Personal Data (defined below) that we collect, receive and store about individuals in connection with the following cases:

  • When you make use of our website, http://wiki.xpolog.com and https://www.xpolog.com and xplg.com   and https://support.xpolog.com, and any other website that we operate (each, together with its sub-domains and content, the “Website”);
  • when you request a Demo or a Free Trial of our software;
  • When you use the Contact us option or engage our Online Chat;
  • When you Purchase our products/software
  • When you subscribe for our Blog, Newsletters, Surveys and Promotions;
  • When you participate in one of our Webinars;
  • When you Submit your resume through the career applications;
  • When we acquire your Personal Data from third-party sources (such as lead-generation);

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Table of contents:

  • What Data we Collect, Why we Collect it, and How it is Used;
  • How we Protect and Store your Personal Data;
  • How we share your Personal Data
  • Additional Information Regarding Transfers of Personal Data
  • Your Rights
  • Use by Children
  • Publicly Available Information
  • US Privacy Provisions
  • How to Contact Us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below.  If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

  1. WHAT DATA WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

 

Data We Collect

 

Why is the data collected and for what purposes?

 

Legal basisThird Parties with whom we Share your DataPeriod of Storage

 

Consequences of not providing the data?

 

Account Creation /Demo/Free Trial
·         Full Name

·         Phone Number

·         Company

·         Email Address

When you choose to create an account on our Website, or when you submit a request for a demo/free trial of our software.Necessary to perform a contract or take steps, at your request, to enter into a contract.We do not share your data, nevertheless we keep it on services (processors) for our internal use.24 monthsInability to create an account and provide you with our services
Contact Us and Online Chat                            
·         Name

·         Phone Number

·         Email Address

Following up on a Contact Us request submitted by you.Necessary to perform a contract or take steps, at your request, to enter into a contract.We do not share your data, nevertheless we keep it on services (processors) for our internal use.24 monthsInability to Follow up and respond to your inquiry.
Share With Others                                           
·         Name

·         User ID

·         Email

In order to share services we provide with acquaintances of our customers.Necessary to share information with local partners that can assist with custom tailored needs of customers.With partners as cited in our business partner list.24 monthsInability to approach other users with service offers they may be interested in.
Purchases                                                         
·         Credit card number

·         Related Account

·         Billing information

·         Invoice related information

·         Other data required to process the order

·         Technical information

If you choose to make a purchase through our Website, we will require certain information as described herein in order to complete the transaction between us.Necessary to perform a contract or take steps, at your request, to enter into a contract.Billing service provider.24 monthsInability complete the purchase process
Blogs, Newsletters, Surveys and Promotions    
·         Name

·         Email

·         Contact details

To enable marketing and sales communications with youOur legitimate interests, where we have a relevant and appropriate relationship with you, or, if no such relationship exists, consent.None24 monthsWe will be unable to provide information about new and existing services, helpful advice, offers, etc.
Cookies
·         Web server cookiesOur site and online services we use may use cookies to identify returning browser and track web usage patterns.Needed to track and optimize our marketing effort and conversion optimization in order to maintain high quality of content.3rd party online line service like Google, Hubspot, Smoove, Mailchimp, and other online marketing services.3 monthsWe will be unable to optimize messaging and services and you may see the same marketing materials without context. We may ask same questions repeatedly.
Careers applications
·         Name

·         Email Address

·         Resume

·         Contact informarion

Necessary to perform a contract or take steps to enter into an employment contract with you.Necessary to perform a contract or take steps, at your request, to enter into a contract.None12 monthsWe will not be able to contact you in relation to your application

 

  1. HOW WE PROTECT AND STORE YOUR PERSONAL DATA

 

  • Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. 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. If you have any questions about security on the Website, you can contact us at security@xplg.com
  • Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, 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.
  1. HOW WE SHARE YOUR PERSONAL DATA

 

In addition to the recipients described in Section 1, we may share your information as follows:

  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. 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 or assign Personal Data in connection with the foregoing events; and
  • Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

 

We ensure transfers within the Xpolog group will be covered by an agreement entered into by members of the Xpolog group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to;

 

Where we transfer your Personal Data outside of Xpolog, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.

Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or

 

Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

  1. YOUR RIGHTS

 

The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR:

  • You have a right to access information held about you. Your right of access is 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 amend any Personal Data we hold that it is inaccurate or misleading. You may submit an access/rectification request by sending an email to support@xpolog.com.
  • You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
  • The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
  • 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 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. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
  • The right to withdraw your consent. Please note that t 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.
  • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

You can exercise your rights by contacting us at support@xplg.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly 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 your identity and for security purposes, before disclosing the Personal Data requested to you. 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.

  1. USE BY CHILDREN

 

We do not offer our products or services for use by children. If you are under 16, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

  1. PUBLICLY AVAILABLE INFORMATION

 

Any content that you post on or via the Website (“User Submissions”) may be publicly available to other Website users, and may also be accessed and used by people off the Website. The notices and tools that we provide on the Website are intended to inform you which information will be made publicly available. If you publish your contact information in any User Submissions, you may receive unsolicited messages from other users of the Website or the public. We, therefore, encourage you only to post information that you are sure you want to be accessible to anyone.

  1. US PRIVACY PROVISIONS.
  • California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@xplg.com .Please note that we are only required to respond to one request per customer each year.
  • We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We allow third parties, such as companies mentioned in section 1 of this privacy policy, which provide us with analytics tools, to collect personal data about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.
  • If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Data you have publicly posted. If you wish to remove such content or Personal Data and you specify which content or Personal Data you wish to be removed, we will do so in accordance with applicable law.  Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

 

  1. HOW TO 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@xplg.com

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