LINKURY PRIVACY POLICY

[Last Revised: June 26, 2018]

Linkury Ltd ("Company", "we", "us" or "our") recognizes the importance of your privacy and we take this issue very seriously. To this end, we have designed this Privacy Policy to enable you to clearly understand our privacy practices while you ("you" or "user") are accessing or browsing our website available at: https://www.linkury.com/ ("Site") and the Services available therein (as defined in our Terms of Use. We have included below information about which data is collected, how we process and use your data, but before we would like to explain the basis on which we do so:

  1. Where you sign up for any of our Services, we process your personal data in order to perform our contract with you;
  2. If we have a legitimate interest in processing data, such as for direct marketing or online identifiers; or
  3. We will also process your personal data where you have provided us with consent to do so.

For more details regarding the terms and conditions for use of the Site, please read our Terms of Use ("Terms"), a current copy of which is available at Terms of Use. This Privacy Policy is an integral part of the Terms.

Types of Information We Collect

The first type of information is non-identifiable information which may be made available or gathered via your use of the Site or the Services ("Non-Personal Data"). We are not aware of the identity of the user from which the Non-Personal Data was collected.

The Non-Personal Data which is being collected may include your aggregated usage information and technical information transmitted by your device, including, type of browser, the type of the user's device and technical information pertaining to the user's device, language preferences, time stamps, clicks and visited pages, search logs, the operating system, utilized internet service provider and other similar information.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Data"). Personal Data voluntarily provided by you (e.g., email address, etc.) as well as your Internet Protocol ("IP") addresses. Note that IPs are considered "Personal Data" in many jurisdictions (such as the EEA), thus, the Company treats IPs as such and complies with applicable laws.

In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

The table below details the information we collect, why we collect it and how we use it:

Type of Information

How Do We Use It?

If you contact us through any means of communication available in our Services you will be required to provide us with your name and a valid email address.

We collect this information in order to perform our contract with you, meaning, in the event you contact us through the Site, or through any other means of communication, we will use your contact details and save your contact history with us in order to respond to your inquiry, provide you with support, assistance or any other service requested by you.

In the event you are interested in joining our team, and submit your CV, you will be requested to provide us your name, email address, and CV.

Your provision of Personal Data in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal data concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.

IP and technical Non-Personal Data

We use the IPs , as well as technical Non-Personal Data for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Site and Services and the way in which we offer them; (ii) enhancing the experience with the Services; (iv) our legitimate interests of auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the Site and Services; (v) perform research, for analytical and statistical purposes, to improve our Site and Services.

How We Collect Information

Depending on the nature of your interaction with the Site and Services, the Company may collect information as follows: (i) Automatically – the Company collects information automatically transmitted from the device or through the use of Cookies (as detailed below); (ii) Provided by you voluntarily – meaning, if and when you choose to provide us with information such as through contact us communications, etc.

Cookies

When you access or use the Site, or interact with our Services, we assign your device with a log file, a cookie (session or persistent), web beacons or other related technologies, to collect Non-Personal Data with respect to your activity in connection with our Service.

A "cookie" is a small piece of information that a website assign to your device while you are viewing a web site. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and for analytic purposes. You can find more information about cookies at www.allaboutcookies.org .

Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited. For more information about your controls in this regard, you may review the following links:

Our service providers ("Service Providers") may also use cookies, scripts or web beacons for the purpose of tracking and analyzing your use, all as detailed below:

Google Analytics. This cookie is placed in order to track and analyze the use of our Services, for internal purposes and to collect information about your online usage activities across our Site which might include your IP address. To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend you review Google's policies located at: www.google.com/policies/privacy/partners. We also encourage you to review the Google Analytics' currently available opt-outs for the web tool available at: https://tools.google.com/dlpage/gaoptout/.

Sharing Your Data with Third Parties

We will not share any Personal Data collected from you with third parties except in the following events:

    1. Authorized Disclosures. We may disclose your Personal Data to third parties when you consent to a particular disclosure of your Personal Data. Please note that once we share your information with another company, that information becomes subject to the other company's privacy practices.
    2. Compelled Disclosures. We will share your information, solely to the extent needed to comply with any applicable law or permitted by it, regulation, legal process or governmental request (e.g., pursuant to law enforcement inquiries, subpoenas or court orders), or when we believe, in good faith, it is required in order to enforce our policies (including our policies and agreements) including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues. In addition, we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
    3. Service Providers. We may disclose Personal Data to our service providers so that they can perform requested services on our behalf. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services (e.g., direct marketing services).
    4. Business Transfers.We may share Personal Data, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
    5. Online Identifiers. We may share IPs collected by us (as detailed above), for the purpose of operating and improving our business, providing the Services, as well as to detect fraud, security or technical issues in connection with the Site.

Regarding Non-Personal Information. We may share aggregate or Non-Personal Data with business partners and other third parties in accordance with the terms of this Privacy Policy. We may store Non-Personal and Personal Information on our servers or our cloud servers, use or share Non-Personal Information in any of the above circumstances, as well as for the purpose of providing and improving our Service, aggregate statistics, marketing and conduct business and marketing analysis, and enhance your experience with the Services.

Third Party Site and Services

The Services may link to third party non-Company websites, platforms, content and resources ("Third Party Services"). The Third-Party Services are not reviewed by us. The Company cannot control the treatment of your information by such third parties, and the privacy practices of third parties likely differ from those described in this Privacy Policy. We encourage you to carefully read the privacy policies and terms of use of those third parties. The Company is not responsible for the Third-Party Services or their privacy and data collection practices, and in no event shall the company be liable to anyone for any damage arising from or occasioned by the access or use of the Third-Party Services

Users' Rights

The right to obtain a copy, delete, revise or transfer the data collected, and object to collection

Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Information that we hold (which might be different in each jurisdiction) such as;

  1. you may request to access your Personal Data that we hold;
  2. you may request the rectification of your Personal Data that we hold;
  3. you may request the erasure of your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data);
  4. you may request to restrict processing of your Personal Data;
  5. you may object to processing of your Personal Data by us;
  6. you may request to exercise your right of data portability;
  7. you may exercise your right to file a complaint to a supervisory authority in your jurisdiction; and,
  8. you have the right to withdraw consent.

If you wish to be provided with more information, or you would like to exercise your rights, or in the event that you have any additional complaints about your privacy rights, please initially contact us at: support@linkury.com or contact our Data Protection Officer at: dpo@linkury.com. Please note that you have the right at any time to contact your local data protection authority.

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, however not more than one (1) month, unless otherwise required or permitted under applicable law.

Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

Opt-Out right

You may opt-out of the data collection, sharing process and advertising services related to our Site, as follows:

  1. you may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set, by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using (we have included some useful links in the "Cookies" section above)
  2. you may contact us (as detailed below), and we will make best efforts to assist you;

For How Long We Retain the Information We Collect

Unless we are instructed otherwise by users, we retain the Non-Personal Information, we collect for as long as needed to provide the Service and to comply with our legal obligations, resolve disputes and enforce our agreements. Further, we retain the Personal Data, we collect for as long as legally permissible, in accordance with applicable laws.

Data Security

Your privacy is very important to the Company and therefore we are committed to protecting your Personal Data from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards, for more information, please review our Information Security Policy. The Personal Data collected by the Company is stored in the Google Big Query Cloud servers, for more information regarding the data security provided by Google, please see: https://cloud.google.com/security/.

The Company seeks to minimize the amount of data that it stores on its servers in the first place. If you feel that your privacy was treated not in accordance with our policy, or if any person attempted gain unauthorized access to the Personal Information please contact us at: support@linkury.com.

Further, in the event of a data incident, in which we discover your Personal Data may be at risk, then we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).

Children's Privacy

You represent and warrant that you are (i) at least thirteen (13) years of age if you are located in the US; (ii) at least sixteen (16) years of age if you are located in the EU; or (iii) if you are located in any other GEO you are above the age defined as "child" under applicable laws in your jurisdiction (collectively "Child" or "Children"). If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children. If we later obtain actual knowledge that a user is considered as a Child under applicable law, we will take steps to immediately delete its Personal Data. We request that such individuals do not provide Personal Data through the Services.

If you become aware or have any reason to believe that a Child has shared any information with us, please contact us and we will take reasonable steps to ensure that such information is immediately deleted from our files.

Transfer of Data

We may store or process your information in the United States or in other countries. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your Personal Data.

Do Not Track Disclosure

The Site does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.

Changes to The Policy

We reserve the right to periodically amend or revise this Privacy Policy from time to time, at our sole discretion. The most recent version of the Privacy Policy will always be posted on the Site. If we do make any changes, the updated date at the top of the Privacy Policy will be reflected in the "Last Revised" heading. If we make any material changes, that will substantially affect the data collection by us, we will make best efforts to provide a notification. We encourage you to review this Privacy Policy periodically to ensure that you understand how we collect, use and share information through the Site. Any changes to the Privacy Policy will become effective immediately upon the display of the revised Privacy Policy. Your continued use of the Site following the display of such revised Privacy Policy, constitutes your acknowledgement and of such amendments.

Contact Us

If you have any questions or comments about this Privacy Policy, please write to us at:

Linkury Ltd.

Israel office: 14 Shenkar Street, Herzliya, Israel 46733.

US office: 244 5th avenue, Suite C12, New York, NY 10001, USA.

You can also contact us via email at: support@linkury.com

Data Protection Officer

If you have any requests regarding the data collected under this Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@linkury.com

Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.