Privacy Statement

CONTROLUP WEBSITE PRIVACY POLICY

Last Updated: June 2018

This privacy policy (“ Privacy Policy ”) governs how we, ControlUp Technologies Ltd. and our affiliates (“ ControlUp ” “ we ”, “ our ” or “ us ”) use, collect and store information pertaining to you (“ User ”, “ you ”) in the following use cases:

  • When you make use of our website, https://www.controlup.com/ (“ Website ”);
  • When you attend a marketing event and provide Personal Data; and

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:

  1. What Information we Collect, Why we Collect it, and How it is Used;
  2. How we Protect and Store your Personal Data;
  3. How we share your Personal Data
  4. Additional Information Regarding Transfers of Personal Data
  5. Your Rights
  6. Use by Children
  7. How to Contact Us
  8. Links to and Interaction with Third Party Products
  9. California Privacy Rights
  10. Our California Do Not Track Notice
  11. Deletion of Content from California Residents

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 INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Use Case Data We Collect Why is the Data Collected and for What Purposes? Legal basis Third Parties with Whom we Share your Data Period of Storage Consequences of not Providing the Data
When you make use of our Website Cookies When you use our Website, we will collect and receive information collected from cookies implemented by third parties, in order to improve our Website and target you relevant with marketing campaigns on social media or by email.

For additional information about our cookie policy, please see here.

Consent
  • Google
  • Facebook
  • Twitter
  • LinkedIn
  • AWS
  • Salesforce
  • Marketo
3 rd party cookies are stored by default for 180 days unless deleted by the user

 

We will not be able to improve our Website or provide you with content and offers which may be of interest to you.
First name, last name, email address, company name (optional), country, phone number and the content of your request or inquiry. When you commence direct communications with us by sending us a request or inquiry via the Website (filling a web form), we collect this to respond to your request Necessary in order to take steps at your request prior to entering into a contract

Legitimate interest –Necessary to respond to your request inquiry

  • Marketo
  • Salesforce
  • Cirrus Insight
  • Outreach
For as long as it is reasonably necessary for us to adequately respond to your request but no longer than 24 months after the last communication by the user. We will not be able to respond to you request or inquiry.

You would not be able to download gated content assets and free utilities software pursuant to your request.

Name, email address When you commence direct communications with us via the chat on our Website, we collect this to respond to your request Necessary in order to take steps at your request prior to entering into a contract

Legitimate interest – take steps to respond to you inquiry.

  • Zendesk
  • Salesforce
For as long as is reasonably necessary for us to adequately respond to your request but no longer than 24 months after the last communication by the user. We will not be able to respond to you request or inquiry and provide you support
Name, email, you preferred job and your resume which you upload to the Website When you submit your resume for one of the positions offered on our Website. Necessary in order to take steps at your request prior to entering into a contract

Legitimate interest – get in touch with you with and assess whether you fit the job description.

G-drive 2 years We will not be able to assess whether you fit the job description or contact you in connection with you application.
When you attend a marketing event and provide Personal Data; First name, last name, email, telephone number When you provide us with Personal Information when attending, or registering to attend a trade show, conference or webinar Consent
  • Marketo
  • Salesforce
No longer than 24 months after the last communication by the user. We will not be able to get in touch with you.
  1. HOW WE PROTECT AND STORE YOUR INFORMATION

2.1 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.

2.2 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 INFORMATION

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.
  • 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 INFORMATION

We ensure transfers within the ControlUp group will be covered by an agreement entered into by members of the ControlUp 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 ControlUp group, for example to third parties who help provide our products and services, we will obtain 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 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 [ privacy@controlup.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 fulfill 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 for 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 initially 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 18, you may not use the Website, or provide any information to the Website without the involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

  1. 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@controlup.com .

  1. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS.

The Website may enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and 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 may collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

  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 Data to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@controlup.com . Please note that we are only required to respond to one request per customer each year.

  1. OUR CALIFORNIA DO NOT TRACK NOTICE

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 websites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the Website.

  1. 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 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.