NOOGATA TECHNOLOGIES LTD. PRIVACY POLICY (“Privacy Policy”)

This Privacy Policy details how your PII (as defined below) is collected via the Services (as defined below) and is used and processed by Noogata Technologies Ltd. (“Company“, “our“, “us” or “we“). IMPORTANT: BY USING AND/OR ACCESSING OUR WEBSITE AT Noogata.com OR THE PLATFORM OR SERVICES OR ANY SOLUTIONS, AND FEATURES PROVIDED THEREIN, OFFERED BY THE COMPANY OR ITS SUBSIDIARIES OR AFFILIATED COMPANIES (ALL OF THE FOREGOING COLLECTIVELY REFERRED TO AS THE “SERVICES“), YOU (“YOU“) GIVE YOUR CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND CONSENT THAT CERTAIN PII THAT YOU SUBMIT OR THAT IS PROCESSED, USED OR COLLECTED THROUGH THE SERVICES MAY BE PROCESSED, USED OR COLLECTED BY THE COMPANY AND ITS AFFILIATES IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY.

WE DEFINE “PII” TO MEAN ANY INFORMATION RELATING TO AN IDENTIFIED OR IDENTIFIABLE NATURAL PERSON; AN IDENTIFIABLE NATURAL PERSON IS ONE WHO CAN BE IDENTIFIED, DIRECTLY OR INDIRECTLY, IN PARTICULAR BY REFERENCE TO AN IDENTIFIER SUCH AS A NAME, AN IDENTIFICATION NUMBER, LOCATION DATA, AN ONLINE IDENTIFIER OR TO ONE OR MORE FACTORS SPECIFIC TO THE PHYSICAL, PHYSIOLOGICAL, GENETIC, MENTAL, ECONOMIC, CULTURAL OR SOCIAL IDENTITY OF THAT NATURAL PERSON.

YOU ARE NOT LEGALLY REQUIRED TO PROVIDE US WITH PII, HOWEVER, SOME OF THE SERVICES REQUIRE YOU TO DO SO PURSUANT TO THIS PRIVACY POLICY. IN THESE CASES, IF YOU CHOOSE TO WITHHOLD OR DELETE ANY PII REQUESTED BY US, IT MAY NOT BE POSSIBLE FOR YOU TO ACCESS CERTAIN SERVICES. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN PLEASE DO NOT USE THE SERVICES.

We recognize that privacy is important. This Privacy Policy applies to all of the software, services, information, tools, features, data and functionality available on the Services and covers how PII that the Company collects and receives, including in respect of any use of the Services, is treated. If you have any questions about this Privacy Policy, please feel free to contact us at: privacy@noogata.com .

Please also read the Noogata Technologies Ltd.’s Terms of Use at: https://www.noogata.com/terms-of-use/, which describe the terms under which you use our Services.

SUMMARY

PII We Collect. In order to provide and improve our Services, we may collect information you provide and other information as detailed below. In addition, we may collect your PII from third parties, your device location data, your user information, communications you send us and aggregate data. We also automatically collect and record PII through your use of the Services, such as your IP address, cookie information, type of browser and technical information regarding the method and nature of your use of the Services. At any time, you may opt-out from receiving newsletters and promotional communications from us.

How We Use Your PII. We use your PII for purposes such as providing you with, improving and operating our Services, to learn how to adjust and personalize your use of the Services, to understand the usage trends and preferences of our users, for marketing and customer relations purposes and in order to protect the Services from threatening activities.

Cookies and Web Beacons. We use cookies to collect the information described in this Privacy Policy, to manage and maintain the Services, and to track your use of the Services. We may also use web beacons.

Links. The Services may contain links to other services, sites and applications that are subject to their own privacy and data protection policies.

Children. We do not intend to collect PII from anyone we know to be under 18 years old. If you believe that we might have collected such information, please contact us.

PII Sharing. We grant access to your PII to our affiliates, agent representatives, and third party providers. In addition, we may share your PII if required for the provision, maintenance and improvement of the Services; to satisfy applicable law; when permitted by you; to prevent fraud or harm; to enforce agreements; for processing PII on our behalf; or in the event of a merger, acquisition or other structural change or form of sale of part or all of our assets.

PII Security. We follow generally accepted industry standards to protect against unauthorized access, alteration, disclosure or destruction of your PII, however we cannot guarantee its absolute security. We keep your PII only for as long as reasonably necessary to fulfill a legitimate business need or to comply with any applicable legal or ethical reporting or document retention requirements.

Data Integrity. We process PII only for the purposes for which it was collected and take reasonable steps to ensure that the PII we process is accurate, complete and current. However, we depend on you to rectify your PII when necessary.

Your Rights. At any time, you may contact us and request to exercise your rights in accordance with applicable law. For more details see Section 8 below.

Enforcement. We will cooperate with the appropriate regulatory authorities to resolve any formal written complaints regarding processing of PII that cannot be resolved between us and the complaining individual.

Consent to Processing and Transferring of PII. Your PII may be stored and processed in a country outside the country of your residence or from which you access the Services. Transfers of your PII outside the European Economic Area will comply with applicable laws.

California Residents. California residents have specific rights under the California Consumer Privacy Act. For more details, see Section 12 below.

Do Not Track Notices. We do not respond to Do Not Track signals.

PII We Collect and How We Use It. In order to provide and improve our Services, for product development, to understand the usage trends and preferences of our users, for marketing and customer relations purposes, or for our business purposes, such as audits, security, compliance with applicable laws and regulations, enforcement of the relevant end user license agreement or customer agreement or other legal rights, we may collect and process PII, including the following types of PII:

1.1. Information You Provide. For some of the features of the Services we ask you to provide PII, including: full name, email address, job title, place of employment, username, password and address.

1.2. Third Parties. We sometimes supplement the information that you provide with information that is received from third parties. If you interact with any social media or other third party platform (such as Facebook, Instagram, Twitter, LinkedIn, Google) we may receive information from the respective platforms.

1.3. Location Data. We collect GPS and other location data from all of our hardware units, such as the physical location of your device (if you have permitted your location-aware device to transmit location data). When you take and upload photos through the Services we collect location data. We may use your location to also learn how to adjust and personalize your use of the Services. 

1.4. User Information. When you use our Services, we may automatically receive and record information from your device, documents and browser, including without limitation information and statistics about your online status, your IP address, internet service provider, search history, type of browser, browser ID, device ID, cookie information, regional and language settings and software and hardware attributes, network status (WiFi/ cellular carrier), and operating system information. Our systems may automatically record and store technical information regarding the method and nature of your use of the Services, including without limitation which pages or widgets of the Services you viewed, exit and entrance pages, videos you watched, impressions, the number of views they get and any actions you make in the Services, and your use time. We use your IP address to help with server problem diagnosis and to administer the Services. An IP address is a numeric code that identifies your device on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups to determine which domain you are coming from (i.e.: aol.com, yourcompany.com) to more accurately gauge our users’ demographics. We use all of the PII that we collect to understand the usage trends and preferences of our users.

1.5. User communications. When you send an email or other communication to the Company, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. We may send you push notifications to send you news and updates related emails and notifications in respect of the Services. We may also send you newsletters and promotional communications if you joined our mailing list, you may opt-out of this service at any time by submitting a request at the following link: privacy@noogata.com .

1.6. Aggregate and Analytical Data. In an ongoing effort to better understand and serve the customers of the Services, we often conduct research on our customer demographics, interests and behavior, use of the Services, and other statistics, based on the PII and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you or any other individual personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.

2. Cookies and Web Beacons. In order to collect or use the data described herein, we may use temporary cookies that remain on your device’s cookies file for a limited period of time. We may also use persistent cookies that remain on your device’s cookies file until the cookies are removed via your browser’s settings, in order to manage and maintain the Services, record your use of the Services and content you may have gained access to and to understand the usage trends and preferences of our users . Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your device. Cookies do not damage your device. Most browsers enable you to block cookies but you may not be able to use some features on the Services if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not). We may also use web beacons via the Services to collect information. Web beacons or “gifs”, are electronic images that may be used in our Services or in our emails. We use web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon. We may also use third party technologies, such as cookies and web beacons and various third party providers to process and analyze your PII, including without limitation tracking your use of the Services and elsewhere on the internet. (e.g. Google Analytics) under the following terms and conditions: http://www.google.com/policies/privacy/partners/;

3. Links. Links to third party services, widgets, features, sites and applications may be provided by the Company as a convenience to our users. The Company is not responsible for the privacy practices of other sites and applications and you visit them at your own risk. This Privacy Policy applies solely to PII collected or used by us.

4. Children. If you are a child under the age of 18, you must obtain parental consent prior to using our Services. The Company will not knowingly contact or engage with children under the age of 18 without said parental consent and do not intentionally gather, collect/use or share PII from children under the age of 18. If you have reason to believe that a child has provided us with their PII, please contact us at the address provided above and we will endeavor to delete that PII from our databases.

5. PII Sharing. As part of providing the Services, our affiliates, agents, representatives and third party providers may have access to your PII in the following circumstances: (a) when we process PII on behalf of our business customers, we share that information with them, in which event except for de-identified and aggregate information, which we control, we are merely the processors of your PII on behalf of our business customers who collect and process your PII. We require them to do so in accordance with applicable laws, but we do not control their actions and therefore you are advised to review their privacy policies; (b) as required for the provision, maintenance and improvement of the Services; (c) when permitted by you; (d) if we become involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of our assets, whether to a foreign, local, public or private entity; (e) to satisfy applicable law or prevention of fraud, harm, security or technical issues, to enforce applicable agreements and/or their terms, including investigation of potential violations thereof or in response to a court order, judicial or administrative subpoena or warrant, or to otherwise cooperate with law enforcement investigations; (f) to ensure security and for purposes of debugging; and/or (g) to our affiliates or other trusted businesses or persons, agents, third party service providers, subcontractors and representatives for the purpose of processing PII on our behalf in Israel and/or abroad. We require that these parties agree to process such PII based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

6. PII Security and Retention. We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. We retain your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

TO THE EXTENT THAT WE IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, WE SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.

7. Data Integrity. The Company processes PII only for the purposes for which it was collected or used and in accordance with this Privacy Policy or any applicable service agreements. We review our data collection, usage, storage and processing practices to ensure that we only collect, use, store and process the PII needed to provide or improve our Services. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this Privacy Policy is interpreted as an obligation to store PII, and we may, at our own discretion, delete or avoid from recording and storing any and all information.

8. Your Rights.

8.1. Right of Access and Rectification. You have the right to know what PII we collect about you and to ensure that such data is accurate and relevant for the purposes for which we collected it. We allow our users the option to access and obtain a copy of their PII and to rectify such PII if it is not accurate, complete or updated. However we may first ask you to provide us certain credentials to permit us to identify your PII.

8.2. Right to Delete PII or Restrict Processing. You have the right to delete your PII or restrict its processing. We may postpone or deny your request if your PII is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.

8.3. Right to Withdraw Consent. You have the right to withdraw your consent to the processing of your PII. Exercising this right will not affect the lawfulness of processing your PII based on your consent before its withdrawal.

8.4. Right of Data Portability. Where technically feasible, you have the right to ask to transfer your PII in accordance with your right to data portability.

You may exercise the above rights by sending a request to privacy@noogata.com.

8.5. Right to Lodge Complaint. You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your PII.

9. Enforcement. The Company regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of PII by contacting us at the address as provided above. When we receive formal written complaints it is the Company’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between the Company and an individual.

10. Changes to This Privacy Policy. The Company may update this Privacy Policy. We will notify you about significant changes in the way we treat PII by sending a notice to the primary email address specified in your account or by placing a prominent notice on the Services. We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices.

11. Consent to Processing. By providing any PII to us pursuant to this Privacy Policy, all users, including, without limitation, users in the United States, Israel and member states of the European Union, fully understand and unambiguously consent to this Privacy Policy and to the collection, usage, and/or processing of such PII abroad. The server on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access the Services and may be outside your country of residence. Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country and may be transferred outside of the European Economic Area (EEA). If there is a transfer of your PII outside the EEA we will, in the absence of an EC Adequacy decision relevant to the destination country or to the transfer, seek to rely on appropriate safeguards such as appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm) or other measures. By submitting your PII through the Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your PII as described in this Privacy Policy.

12. California Residents. California residents have specific rights under the CCPA. For more information and to exercise your rights, please see the Privacy Notice for California Residents at the following link: https://www.noogata.com/privacy-notice-for-california-residents/.

13. Do Not Track Notices. You are also advised that Company does not respond to “Do Not Track” signals.

14. Questions. If you have any questions about this Privacy Policy or concerns about the way we process your PII, please contact us at privacy@noogata.com.

 

Last Date Updated: July 27, 2023