Privacy Policy

This Privacy Policy (“Policy“) governs the data collection, processing and usage made by Republix Ltd. (the “Company”, “Republix” or “us”, “our”, “we”) through the use of our website at www.cellosign.com (the “Website”) or through the use of the Platform. This Policy concerns the data we collect from individuals who access and use the Website (“Visitors”) and users of our products, including the Cellosign Platform and App (“Platform” and “User”) (Visitors and Users together “you” or “your“).

This Policy constitutes an integral part of any other agreement between you and the Company, including the Terms and Conditions available at https://cellosign.com/terms-conditions/ (“Terms”). Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms.

The privacy of your data is at our outmost importance and hence we handle your data carefully in accordance and compliance with the applicable data privacy regulation. Please note that you are not obliged to provide us with any personal data (as defined below), and we do not request you to do so. However you shall be aware that your avoidance of providing us with some personal data may not allow us to provide you with our services.

If you have any questions about this Policy, please contact us at: info@cellosign.com.

Amendments
We reserve the right to periodically amend or revise the Policy, which will immediately affect the implementation of the revised Policy on our website. The last revision date will be reflected in the “Last Updated” heading located at the top of the Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you periodically review this Policy to ensure that you understand our privacy practices and check for any amendments.

Who are we and Contacting Us
RepubliX Ltd.
Kibutz Kefar Szold, pob180, Israel

HQ:
HaTa’as St 20 Kfar Saba, Israel

North Office:
Tel Hai St 98 Qiryat Shemona, Israel

Email: service@cellosign.com

Questions, comments, requests and complaints regarding this Policy and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently

Role of the Parties
Under the EU General Data Protection Regulation (Regulation 2016/679) (“GDPR”), we act as the Data Controller of our Website Visitors data. Also, we are the Data Controller of our admin Users, who has an admin account in the Platform or App.

In the event you are a User (i.e., if you use the Platform or App for filing a form with information requested by one of our customers), we merely act as a Data Processor on behalf of the form creator who is a customer of our services, including the Platform and App. The for creator decides independently what data will be collected and requested in the form. Also, we do not use that data for our purposes and shortly after receiving it, we transfer it to the form creator and delete it from our systems. If you have any questions or inquiries regarding the Personal Data collected in such form, please contact the relevant data controller. 

Collection of Non-Personal Data
We may collect aggregated, non-personal and non-identifiable information which may be made available or gathered via your use of our website (“Non-Personal Data“). We are not aware of the identity of the individual from which the Non-Personal Data is collected.

Also, we may sometimes process and anonymize or aggregate personal data and identifiable information in a manner that shall create a new set of data that will be Non-Personal Data. Such a new data set can no longer be associated with any identified person.

Non-Personal Data may be used by us without limitation and for any purpose, including for commercial, research, or statistical purposes, without further notice to you.

Collection of Personal Data
During your interaction with the Website, Platform and App we will collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data”). This may include online identifiers, first and last name, email address, phone number, resume, cover letters, country, company’s name and additional information you decide to share with us, subject to applicable law.

In case you will provide us with your Personal Data, we may manage it under a “Customer Ticket” in one of our systems in accordance with terms of this Policy.

If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

You are under no legal obligation to provide us with any such data. However, sometimes, if you choose to not share your data with us, we may not be able to provide you with our services to its full extent.

Processing of Personal Data – Purposes and Lawful Basis
We have included in the table below information about which data is processed, how we process and use your data and the lawful basis for which we do so subject to the GDPR.Cookies and other tracking and monitoring technologies

Type of Data Purpose of Processing Lawful Basis Processing Actions
Contact Details & Contact History:
If you voluntarily contact through any means of communication, we make available (for example, through a “Contact Us” page in the Website, by filling up any form on the Website, by sending us an email, or any other request or notification) you may be required to provide us with certain information such as your name, company name and type, phone number, and email address.		 Your contact details, relevant company details, and contact history with us will be processed in our system (including third party systems, e.g., our email, CRM), in order to provide you with the support you have requested or response to your inquiry, as well as in the event we find it applicable (e.g., in the event of future claim). In case you are approaching us as an actual customer of our services for support purposes we will process your data for the performance of the contract with us.
In other cases, or where we retain your data just as part of our records, the lawful basis for processing your data will be our legitimate interest.
Perform our contract with you.		 We are collecting your data, transmitting it to our system and storing it in it (including third party systems, e.g., our email, CRM), and responding to you by email or any other means of contact provided by you. We also keep record of all our correspondence with you.
Request a Demo:
If you are interested in scheduling a demo, you will be required to provide your name, company name and email. Further, after contacting you and subject to your sole discretion we may collect additional data such as you Company name, position, etc.		 We will use this information for the purpose of providing you with the services that you requested. After addressing your inquiry we will retain a record of our communications under our legitimate interest.
Perform our contract with you.		 Storage of your information in our systems and using it for contacting you. After completion of the inquiry we will keep record of our communication with you as part of our business records.
While using the Platform or App as an account owner:
If you are a customer of any of our services or acting on behalf of such a customer, we may provide you with a user account to the Platform and App management dashboard. We will collect your name, email, phone, company name, username and password, and usage data of the Platform and App including dates and times of use, IP. Mobile device identifiers, usage preferences, etc.		 We will use that data to allow you to use the Platform and App. Such processing is part of our legitimate interests as a commercial business, or in some cases and where applicable under law, such as third party’s cookies usage, subject to your consent. We will store your data, analyze it and use it to allow you t use the Platform or App, keep log data regarding your usage and use preferences, etc.
Online identifiers and other Technical Data:
When you interact with our website, we may collect certain online identifiers, including your IP address and Advertising ID.
We may also collect technical Non-Personal Data transmitted from your device (e.g., language used, type of operating system, type of device, etc.) and approximate geographical location (country).		 We use this data for our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing, and improving the website and how we offer it; (ii) enhancing your experience; (iii) auditing and tracking usage statistics and traffic flow; and (iv) protecting the security of the website, as well as our and third parties’ rights (subject to applicable law requirements). Where the processing of your data is based upon your consent, you always have the right to withdraw your consent. Collection of data, aggregation and statistical analysis, report generation, record keeping and storage.

Cookies and other tracking and monitoring technologies

Our Website and App may include tracking and analysis technologies such as cookies and pixels (collectively: “Cookies”). These technologies are used for the purpose of gathering some information automatically, by ourselves or by third party service providers on our behalf.

We may use various types of Cookies:

  • Essential – which are necessary for the site to work properly (usually appears under our name/cookie tag);
  • Functional – designated to save your settings on the website – your language preference or other view preferences;
  • Targeting – used to collect information from you to help us improve our products and services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies);
  • Social networks – Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts;
  • Analytics – give us aggregated and statistical information to improve the website and further developing it (e.g., Google analytics, Google Firebase Catalytic, etc.);
  • Third-party services used by us – an external service which provides us with services which allow us to provide you with the services.

The data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.

Also, Cookies data is sometimes collected through third-party service providers, e.g., Google and Facebook. In those cases, your Cookies data might be transferred to those third parties, which might use it, as a “joint controller” or “Co-Controller” of the data, i.e., the data is also “owned” and processed by those third parties under their terms and conditions. Under those terms and conditions and the direct accounts or subscriptions you have with those third parties, your Personal Data might be linked to other data collected by the relevant third party and processed in its systems, for its purposes, and under its management. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies in our website might be linked to other data Facebook collects and might be used by Facebook per the independent agreements between you and Facebook.

Your Choices Regarding Cookies

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser, or use the designated Cookies Management Tool installed in the Website.

However, if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

For the Chrome web browser, please visit this page from Google

For the Internet Explorer web browser, please visit this page from Microsoft

For the Firefox web browser, please visit this page from Mozilla

For the Safari web browser, please visit this page from Apple

For any other web browser, please visit your web browser’s official web pages.

Where Can You Find More Information About Cookies?

You can learn more about cookies and the following third-party websites:

 

Sharing Data with Third Parties

We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:

  • Legal Requirement: We will share your information in this situation only if we are required to do so to comply with any applicable law, regulation, legal process, or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);
  • Policy Enforcement: We will share your information, solely to the extent needed to (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
  • Company’s Rights: We will share your information to establish or exercise our rights, to prevent harm to our rights, property, or safety, and to defend ourselves against legal claims, when necessary, subject to applicable law;
  • Third Party Rights: We will share your information, solely to the extent needed to prevent harm to the rights of our Visitors, yourself, or any third party’s rights, property, or safety;
  • Business Purpose: we may disclose your personal information to a third-party for a business purpose, as detailed above.
  • Service Providers: we share your information with third parties that perform services on our behalf (e.g. customer service, tracking, servers, service functionality, marketing, and support, etc.) these third parties may be located in different jurisdictions.
  • Corporate Transaction: we may share your information 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 Policy;
  • Authorized Disclosures: we may disclose your information to third-parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices.

Also note that every time you use the Platform or App for to fill a form, the data collected in such form will be transferred to the form creator, as the Data Controller of such data.

Regarding Non-Personal Data, we may share or aggregate Non-Personal Data with Business Partners and other third parties in accordance with the terms of this Policy. We may store Non-Personal Data and Personal Data on, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving the Website, Platform and App as detailed above. Furthermore, we reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

Your rights under Privacy Protection laws

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information. Data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to send or “port” your Personal Data; The right to file a complaint with a supervisory authority in your jurisdiction;  The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination, etc.

If you wish to exercise any of your rights, please contact us through the means of contact detailed above. Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

In addition to your rights detailed above, you may opt-out of data collection and sharing process made through cookies. 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. For more information about cookies and your controls in this regard, please review your browser settings as well as our Cookie Policy.

In addition, you have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we will appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us in the first instance.

Data Retention

Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable. Basically, and as a minimum, that means that your data will be retained as long as you have an Account in our systems and use our Services.

Also, and after the termination of your Account, we may keep some of your Personal Data as a Visitor or User of our Services extended periods for protecting our legal interests or under any safety or other legal requirements.

As for Cookies data and technical marketing data, usually the data will be retained in an identified manner for periods of 14-36 months, subject to the relevant system. However, note that as explained before, once you delete the Cookies from your computer or otherwise restrict the use of cookies, we will have no linkage between your identity and your Cookies data (yet, the third-party provider may have such data relating to you, under the separate terms between you and any such third party, e.g., Facebook’s terms of use as a Visitor of Facebook).

Recruitment data will be retained up to 7 years after the last recruitment activity, for allowing to protect ourselves from any potential legal suit, in accordance with Israel’s statute of limitations.

Please note that where we act as a Data Processor on behalf of an account owner, the retention periods are under the sole discretion of the account owner, as the Data Controller.

Data Processing Location

We may store or process your Personal Data in a variety of countries, including the United States.

Any transfer of data that originates in the European Union (“EU”) to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR, e.g.:

  • transfer to a country that is recognized as providing an adequate level of legal protection;
  • transfer under a proper agreement containing the Standard Contractual Clauses published and authorized by the relevant EU authorities;
  • where we can be satisfied those alternative arrangements are in place to protect your privacy rights through the use of any other mechanism under the GDPR.

It is important to note that we are headquartered in Israel, a country that the European Data Protection Board considers offering an adequate level of Personal Data protection regulation.

Suppose you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent. In that case, your consent to this Privacy Policy includes your express consent for such transfer of your data.

Security & Data Transfer

We take great care in implementing physical, technical, and administrative security measures that we believe comply with applicable regulation and industry standards for securing your personal data. However, unfortunately, the transmission of information online cannot be 100% secure. As such, we cannot guarantee the full security of data transmitted via the Website, Platform and App and any use of any of it is done at your own risk.

As we may use third party service providers and our website uses third party cookies as described above, your Personal Data might be processed in other territories outside your jurisdiction. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer, in accordance with applicable law. You may exercise your rights, where applicable, to receive information on such a transfer mechanism.

CHILDREN PRIVACY AND DATA

The Website, Platform and App are not intended for individuals under the age of eighteen (18). Accordingly, we do not use the website to knowingly solicit data from or market to children as defined under applicable law (e.g. thirteen (13) regarding US individuals and sixteen (16) regarding European Economic Area (“EEA”) individuals). We request that such individuals do not provide Personal Data. If you become aware or have any reason to believe that a child has shared any Personal Data with us, please contact us through the means of contact detailed above.

Last updated: April 28, 2022