Privacy

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Cypago Security Ltd. (“Cypago”, “we”, “our” or “us”) use, collect and store personal information we collect or receive from or about you (“you”) such as in the following use cases:

1. When you browse or visit our website at https://cypagostg.wpengine.com/ (“Website”);
2. When you make use of, or interact with, our Website
   1. When you contact us
   2. When you register to our newsletter
3. When you sign up to Cypago’s platform (“Platform”)
   1. When you make use of our Platform
4. When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data
5. When we acquire your Personal Data from third-party sources (such as lead-generation companies)
6. When we use the Personal Data of our Customers (e.g. contact details)
7. When we use the Personal Data of our service providers (e.g. contact details)
8. 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 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.

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 Information
3. How we share your Personal Information
4. Your privacy rights
5. Use by children
6. Interaction with third party products
7. Log files
8. Analytic tools
9. Specific provisions applicable under California privacy law
10. How to contact us

Cypago provides a compliance automation solution to its customers. For the avoidance of doubt, for the purposes of this Privacy Policy, a “Customer” is an entity which has executed an agreement with Cypago. If you are an individual, using Cypago’s services as a result of our relationship with Customer (“Individual(s)“), please note that the Customer is the responsible party for obtaining the required consents and complying with any applicable laws or regulations. Accordingly, we encourage you to read the terms and conditions and privacy policies of the Customer.

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

Finally, please note that some of the abovementioned 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. “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

1. 2.1 Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Information. 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. 2.2 Retention of your Personal Information. Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that 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 Information or dealings.

3. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described above, we may share your personal data as follows:

1. 3.1. We will share your data with several categories of recipients, including, without limitation:
   1. 3.1.1. With multinational cloud providers for hosting purposes;
   2. 3.1.2. With multinational word press service providers in order to help us manage our website;
   3. 3.1.3. With email providers, marketing, CRM and other similar tools;
2. 3.2. We may use third party service providers to process your Personal Data for the purposes outlined above. We may also share Personal Data with our affiliated companies.
3. 3.3.To the extent necessary, with regulators, courts, banks 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, as well as for internal compliance procedures;
4. 3.4.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. 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; and/or
5. 3.5.Where you have provided your consent to us sharing or transferring your Personal Data.

4. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

1. 4.1. Rights: You can exercise your rights by contacting us at privacy@cypago.com. 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.
2. 4.2. Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@cypago.com. If you terminate your account, any association between your account and Personal Information we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

5. USE BY CHILDREN.

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any Personal Information to us without involvement of a parent or a guardian. In the event that we become aware that you provide Personal Information 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 privacy@cypago.com.

6. 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 information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

7. 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.

8. 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 Google 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 Google 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.

9. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

9. 9.1. 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 privacy@cypago.com. Please note that we are only required to respond to one request per customer each year.

9. 9.2. Our California Do Not Track Notice (Shine the Light):
   We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

10. 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@cypago.com.