NEXITE PRIVACY POLICY
Last Updated: November 29, 2020
In order to ensure transparency and give you more control over your Personal Information, this privacy policy
(“Privacy Policy”) governs how we, Nexite Ltd. (together, “Nexite” “we”, “our” or “us”) use, collect and store
Personal Data we collect or receive from or about you (“you”) such as in the following use cases:
(i)
When you browse or visit our website
(“Website”);
(ii)
When you make use of, or interact with, our Website
(iii)
When you contact us (e.g. customer support, need help, submit a request)
(iv)
When you attend a marketing event and/or we exchange business cards and you provide us with your
Personal Data
(v)
When we use the Personal Data of our customers (e.g. contact details)
(vi)
When we use the Personal Data of our resellers, distributors, agents and/or finders (e.g. contact
details)
(vii)
When we use the Personal Data of our service providers (e.g. contact details)
(viii)
When you interact with us on our social media profiles (e.g., LinkedIn)
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
and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that
can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is
a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the
legal basis in the table below is only relevant for GDPR-protected individuals.
Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your
rights to a remedy or means of enforcement.
Table of contents:
1.
What information we collect, why we collect it, and how it is used
2.
How we protect and retain your Personal Data
3.
How we share your Personal Data
4.
Additional information regarding transfers of Personal Data
5.
Your privacy rights
6.
Use by children
7.
Interaction with third party products
8.
Log files
9.
Analytic tools
10. Specific provisions applicable under California privacy law
11. Contact us
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the
latest version of this Privacy Policy. If we implement significant changes 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 INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Specific Personal
Data we collect
Why is the Personal
Data collected and
for what purposes?
Legal basis
(GDPR only, if
applicable)
Third parties with
whom we share
your Personal
Data
Consequences of not
providing the
Personal Data
When you browse or visit our Website
Cookies, analytic
tools and log files
For more
information, please
read our cookies
policy
●
To send you
marketing
communications
●
To measure your
interest in our
services and our
Website so we
can improve it
●
To analyze and
support our
Website
Consent
Legitimate
interest (e.g.,
essential
cookies)
Read more about
the purposes of
each cookie
Certain non-essential
Website features may
not be available
Read more about the
purposes of each
cookie
When you make use of, or interact with, our Website
When you contact us (e.g. customer support, need help, submit a request)
●
Full name
●
Email address
●
Phone number
●
Message /
comments
●
Any other
Personal
Information that
you decide to
provide/supply
us with
●
To process and
answer your
questions
●
To provide
support (e.g., to
solve problems)
●
To customize
your experience
Processing is
necessary for
the
performance of
a contract to
which the data
subject is party
or in order to
take steps at the
request of the
data subject
prior to entering
into a contract
Legitimate
interest (e.g., to
answer your
questions)
3
rd
party platforms
such as for the
following
purposes:
●
Google –
email provider
Cannot process and
answer your questions
Cannot provide
support (e.g., to solve
problems)
Cannot customize
your experience
●
Full name
●
Email address
●
To send you
marketing
communications
Consent
3
rd
party platforms
such as for the
following
purposes:
●
Google –
email provider
Cannot send you
marketing
communications
When you attend a marketing event and/or we exchange business cards and you provide us with your
Personal Data
●
Full name
●
Company name
●
Email address
●
Country
●
Any other data
you decide to
provide/supply
us with
●
To establish a
business
connection
●
To send
marketing
communications
Depending on
the context,
consent or
legitimate
interest (e.g.
send you more
information
about Nexite in
certain B2B
situations)
3
rd
party platforms
such as for the
following
purposes:
●
Google –
email provider
Cannot establish a
business connection
Cannot send
marketing
communications
When we use the Personal Data of our customers
●
Full name
●
Company name
●
Email address
●
Phone number
●
Country
●
Payment
details
●
Any other data
you decide to
provide/supply
us with
●
To provide our
products and
services
●
To perform the
relevant
agreement
●
To send you
contract-related
communications
Processing is
necessary for
the
performance of
a contract to
which our
customer is a
party.
Compliance with
a legal
obligation (e.g.
tax laws,
bookkeeping
laws, etc.).
Legitimate
interest (e.g.
send you
contract-related
communications
)
3
rd
party platforms
such as for the
following
purposes:
●
Google –
email provider
Cannot communicate
with you
Cannot provide the
services
Cannot perform the
agreement
●
Full name
●
Email address
●
To send you
marketing
communications
Consent
3
rd
party platforms
such as for the
following
purposes:
●
Google –
email provider
Cannot send you
marketing
communications
When we use Personal Data of our resellers, distributors, agents and/or finders
●
Full name
●
Email address
●
Phone number
●
Company name
●
Job position
●
Phone number
●
Any other data
you decide to
provide/supply
us with
●
To contact our
resellers,
distribution,
agents and/or
finders
●
To
perform/execute
the agreement
Processing is
necessary for
the
performance of
a contract to
which the data
subject is party
or in order to
take steps at the
request of the
data subject
prior to entering
into a contract
Legitimate
interest (e.g.
perform the
contract, send
contract-related
communications
)
3
rd
party platforms
such as for the
following
purposes:
●
Google –
email provider
Cannot communicate
with you
Cannot perform the
agreement
●
Full name
●
Email address
●
To send you
marketing
communications
Consent
3
rd
party platforms
such as for the
following
purposes:
●
Google –
email provider
Cannot send you
marketing
communications
When we use the Personal Data of our service providers
●
Full name
●
Email address
●
Company name
●
Job position
●
Phone number
●
Any other data
you decide to
provide/supply
us with
●
To contact our
service providers
●
To
perform/execute
the agreement
Processing is
necessary for
the
performance of
a contract to
which the data
subject is party
or in order to
take steps at the
request of the
data subject
prior to entering
into a contract
Legitimate
interest (e.g.
perform the
contract, send
contract-related
communications
)
3
rd
party platforms
such as for the
following
purposes:
●
Google –
email provider
Cannot communicate
with you
Cannot perform the
agreement
When you interact with us on our social media profiles
●
Full name
●
Email address
●
Any other data
you decide to
provide/supply
us with
●
To answer your
questions
Depending on
the context,
consent or
legitimate
interest (e.g.
send you more
information
about Nexite in
certain B2B
situations)
3
rd
party platforms
such as for the
following
purposes:
●
LinkedIn –
Social media
platform
Cannot answer your
questions
Finally, please note that some of the above mentioned 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).
2.
HOW WE PROTECT AND RETAIN YOUR INFORMATION
2.1. Security. We have implemented appropriate 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.
2.2. Retention of your Personal Data. In addition to the retention periods mentioned 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. Regarding
retention of cookies, you can read more in our
3.
HOW WE SHARE YOUR PERSONAL DATA
In addition to the recipients described above, we may share your Personal Data as follows:
3.1. With our business partners with whom we jointly offer products or services. We may also share Personal
Data with our affiliated companies.
3.2. 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;
3.3. 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;
3.4. 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
3.5. 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).
If you want to receive the list of the current recipients of your Personal Data, please make your request by
contacting us to info@nexite.io.
4.
ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
4.1. Storage: Blue Host – website hosting and Google Cloud.
4.2. Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision
regarding
Israel.
You
can
read
more
here:
4.3. External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties
who provide us with services), we will obtain contractual commitments from them to protect your
Personal Data.
5.
YOUR PRIVACY RIGHTS.
5.1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to
certain individuals (some of which only apply to individuals protected by the GDPR):
o
You 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;
o
You have the right to request that we rectify any Personal Data we hold that is inaccurate or
misleading;
o
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;
o
You have the right to object, to or to request restriction, of the processing;
o
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;
o
You have the right to object to profiling;
o
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;
o
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;
o
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.
5.2. You can exercise your rights by contacting us at info@nexite.io. 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.
6.
USE BY CHILDREN
We do not offer our products or services for use by children and, therefore, we do not knowingly collect
Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of
eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the
purposes of the GDPR, we do not intend to offer information society services directly to children. In the event
that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the
right to delete it. If you believe that we might have any such information, please contact us at info@nexite.io.
7.
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 Service.
8.
LOG FILES
We use log files. We use such information to analyze trends, administer the Website, track users’ movement
around the Website, and gather demographic information.
9.
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
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
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/.
We reserve the right to remove or add new analytic tools.
10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
10.1. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California
residents to request certain information regarding our disclosure of Personal Information to third parties
for their direct marketing purposes. To make such a request, please send an email to info@nexite.io.
Please note that we are only required to respond to one request per customer each year.
10.2. Our California Do Not Track Notice (Shine the Light): 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.
10.3.
Deletion Of Content From California Residents: 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 Information you have publicly posted. To remove, please send an email to info@nexite.io.
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 Information you
have posted and that there may be circumstances in which the law does not require us to enable removal
of content.
11. 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 info@nexite.io.
***