Last updated: July 6th, 2023.
PROJECT MAP LTD. – PRIVACY POLICY
1. Applicability.
1.1. This privacy policy (“PP“) explains how ProjectMap™ Ltd. (together with its affiliated companies, the “Company” or “Proggio”) collects, stores, uses, and shares, etc. Personal Data of you (“Customer“) in connection with the Service Offerings. This PP does not apply to any personal data that Proggio collects, processes and manages on behalf of Customers, submitted and/or uploaded to the Service Offerings (“Customer Data“). Proggio processes such Customer Data, in its position as a processor under the GDPR or as a service provider under the CCPA on behalf and under the instruction of the Customer subject to Proggio’s Data Processing Agreement provided upon request (“DPA”).
1.2. For the purpose of this PP “Personal Data” shall mean personal data or personal information, as applicable in the Applicable Data Protection Law (as defined below), or any other applicable data protection laws.
1.3. The PP is an integral part of the Company’s Customer Agreement which is available at https://app.proggio.com/terms (“TOU“, together with the PP and the DPA, the “Terms“).
1.4. By attempting to use or access, or by using or accessing the Service Offerings, Customer agrees to be bound by the Terms. If Customer does not agree with the Terms Customer must not use or access the Service Offerings.
1.5. The Company may amend this PP from time to time. If Company makes any changes to this PP that materially affect Company’s practices with regard to the personal data Company previously collected from Customer, Company will endeavor to provide Customer with notice in advance of such change by highlighting the change on the Service Offerings. Company will seek Customer’s prior consent to any material changes, if and where this is required by Applicable Data Protection Laws.
1.6. For the purposes of (i) the General Data Protection Regulation (2016/679) (“GDPR”), including any subordinate or implementing legislation, and (ii) the California Consumer Privacy Act of 2018, Cal. Civ. Code 1798.100 et seq. (“CCPA”), as applicable (collectively, the “Applicable Data Protection Laws“).
1.7. All capitalized terms used but not defined herein shall have the meaning ascribed to them in the Customer Agreement.
2. Collection of Personal Data.
2.1. Information provided by Customer.
Company collects any data Customer provides Company with via the Service Offerings, including but not limited to:
2.1.1. Customer’s contact details (e.g., name, email address, phone number);
2.1.2. Customer’s payment information, only when payment is done through the app (e.g. credit card or bank account information); alternate payment options available, please contact [email protected]
2.1.3. Customer password and other authentication and security credential information;
2.1.4. Any communication between Customer and the Company, e.g. emails, phone conversations, chat sessions.
2.1.5. It shall hereby be clarified that Customer is not under any legal obligation to submit personal data to Company. However, in case Customer chooses not to submit personal data to Company, Customer may not be able to become a Customer and/or use (all) the Service Offerings.
2.2. Information collected automatically.
Company automatically collects data when Customer visits, interacts with, or uses the Service Offerings, including but not limited to:
2.2.1. identifiers and information contained in cookies;
2.2.2. Customer’s settings preferences, backup information;
2.2.3. Uniform Resource Locators (URL) clickstream to, through, and from the Service Offerings;
2.2.4. content Customer viewed or searched for, page response times, and page interaction information (such as scrolling, clicks, and mouse-overs);
2.2.5. network and connection information, such as the Internet protocol (IP) address and information about Customer’s Internet service provider;
2.2.6. computer and device information, such as browser type and version, operating system, or time zone setting; the location of device.
2.3. Information collected by Third parties.
2.3.1. This PP does not apply to any content created, used, processed and/or stored by Customer when using the Service Offerings. Also, the PP does not apply to any products, services, websites, links or any other content that are offered by third parties. Customer is advised to check the applicable third party policies. Company has no control over such third parties’ privacy practices, or the technology used by such third parties. Each Customer is advised to thoroughly review such third parties’ privacy policies before making any use of such third party’s products and services.
2.3.2. Without derogating from the generality of the above, when clicking on certain social media links provided on the Site (e.g. Twitter) Customer will be transferred to Company’s site on such social media (“Social Media Site“). It shall hereby be clarified that such Social Media Site is governed by the terms of use and privacy policy of the respective social media and not by the Company.
3. Cookies
3.1. To facilitate and customize the Customer’s experience of the Service Offerings and to track Customer’s use of the Service Offerings Company may utilize cookies and other industry standard technologies. A cookie is a small text file that is stored on a Customer’s computer for record-keeping purposes which contains information about that Customer. Most browsers automatically accept cookies, but Customer may be able to modify its browser settings to decline cookies. Please note that if Customer declines or deletes these cookies, some parts of the Service Offerings may not work properly.
3.2. By clicking on a link to a third-party website or service, a third party may transmit cookies to Customer. This PP does not cover the use of cookies by any third parties, and the Company is not responsible for such third parties’ privacy policies and practices.
4. The Company’s Use of Collected Information.
4.1. The Company processes Customer’s personal data to operate, provide, and improve the Service Offerings, including but not limited to:
4.1.1. creating and managing Customer profiles;
4.1.2. contacting Customer by the Company and communicating with Customer with respect to the Service Offerings, e.g. by phone call, sms, email, chat; responding to inquiries from Customer;
4.1.3. informing Customer about updates or offers;
4.1.4. personalizing the Service Offerings, i.e. identifying Customer’s interests and recommending offers that might be of interest to Customer;
4.1.5. marketing and promoting Company’s Service Offerings;
4.1.6. providing assistance and support;
4.1.7. fulfilling Customer requests; meeting contractual or legal obligations;
4.1.8. protecting Customers security, e.g. preventing and detecting fraud;
4.1.9. internal purposes, e.g. trouble shooting, data analysis, testing and statistical purposes.
4.2. The Company does not use any personal data other than as necessary to provide the Service Offerings.
4.3. The Company may ask for Customer’s consent to use Customer’s Personal Data for a specific purpose which will be provided to Customer.
4.4. In case Customer’s Personal Data contains third party personal data, Customer represents and warrants that it has obtained any consent required under the PP to the Company’s privacy practices set forth in the PP from such third party.
5. Sharing Customer’s Information
5.1. In the following cases Company discloses, without notification, personal data, any communications sent or received by each Customer, and any other information that Company has collected and/or was provided with:
5.1.1. Service Providers: The Company engages selected third-party companies and individuals as “Service Providers”, to perform services on the Company’s behalf or complementary to its own. These may include amongst others providers of: hosting and server location services, data and cyber security services, text analyzing services, billing and payment processing services, fraud detection, analytics, data optimization and marketing services, social and advertising networks, content, lead generating and data enrichment providers, email, and support and customer relation management systems. The Company’s Service Providers may have access to personal data, depending on each of their specific roles and purposes in the provision of the Service Offerings or other activities, and may only use the data as determined in the Company’s agreements with them.
5.1.2. Legal Compliance: The Company may disclose personal data in exectional cases, if required to do so by law according to its understanding of such law (including, but not limited to, in cases of court orders or subpoenas); to verify the information obtained by Company; to prevent or investigate suspected fraud, or any activity that Company believes may be illegal or may expose Company to legal liability; in case of potential threats to the physical safety of any person or property if Company believes that Customer’s information in any way relates to that threat; if Company believes that Customer’s conduct on or in connection with the Service Offerings is inappropriate and inconsistent with generally accepted norms of behavior; in addition, Company may be required to disclose Personal Data to relevant national, state and local law enforcement authorities, who may further disclose the Personal Data.
5.1.3. Merger: In the event that Company, or any of its businesses, are sold or disposed of, whether by merger, sale of assets or otherwise, Personal Data collected hereunder may be one of the assets sold or merged in connection with such transaction. Personal Data collected hereunder may also be disclosed in connection with a commercial transaction where Company or any of its businesses are seeking financing, investment, and support or funding.
5.2. The Company may share personal data in additional manners, pursuant to Customer’s explicit approval, or if the Company is legally obligated to do so, or if the Company has successfully rendered such data non-personal and anonymous.
5.3. When Company shares Customer’s Personal Data with third parties as specified above, Company requires such recipients to agree to only use the Personal Data Company shares with them in accordance with this PP and Company’s contractual specifications and for no other purpose than those determined by Company in line with this PP.
5.4. It is clarified that Company is under no obligation to exercise its rights hereunder and shall not incur any liability with such exercise or lack of exercise of its rights.
6. Advertisement
6.1. Company may also send Customer advertisements, as such term is defined in the Media Law (Bezeq and Broadcasting), 1982.
6.2. Customer can opt out of receiving such advertisement emails and sms from the Company at any time by unsubscribing using the unsubscribe link within each email or sms, or emailing Company to have Customer’s contact information removed from Company’s email list or registration database.
7. Security
Company has taken appropriate technical and organizational measures to protect any Customer Personal Data from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. Customer should be aware, however, that no data security measures can guarantee 100% security.
8. Customers in the European Economic Area (EEA)
8.1. Legal Basis for Processing of Personal Data
Company will only process Customer’s personal data if it has one or more of the following legal bases for doing so:
8.1.1. Contractual Necessity: processing of personal data is necessary to enter into a contract with Customer, to perform Company’s contractual obligations to Customer under the TOU, to provide the Service Offerings, to respond to requests from Customer, or to provide Customer with customer support;
8.1.2. Legitimate Interest: Company has a legitimate interest to process Customer’s personal data;
8.1.3. Legal Obligation: processing of Customer’s personal data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
8.1.4. Consent: processing of Customer’s personal data with Customer’s consent.
8.2. Customer’s Rights regarding Personal Data
8.2.1. Subject to Applicable Data Protection Laws, Customer has certain rights with respect to Customer’s Personal Data, including the following:
8.2.2. Customer may ask whether Company holds personal data about Customer and request copies of such personal data and information about how it is processed;
8.2.3. Customer may request that inaccurate personal data is corrected;
8.2.4. Customer may request the deletion of certain personal data;
8.2.5. Customer may request Company to cease or restrict the processing of personal data where the processing is inappropriate;
8.2.6. When Customer consents to processing Customer’s personal data for a specified purpose by Company, Customer may withdraw Customer’s consent at any time, and Company will stop any further processing of Customer’s data for that purpose.
8.2.7. In certain circumstances, Company may not be able to fully comply with Customer’s request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, Company will still respond to notify Customer of such a decision.
8.2.8. Customer can exercise Customer’s rights of access, rectification, erasure, restriction, objection, and data portability by contacting Company at [email protected]. In some cases, Company may need Customer to provide Company with additional information, which may include personal data, if necessary to verify Customer’s identity and the nature of Customer’s request.
8.3. Transfer of Customer’s Personal Data outside of the EEA
8.3.1. Company currently stores Customer data in Company’s data centers located in Western Europe and the US.
9. Customers in California, USA.
9.1. Company will at all times comply with all Applicable Data Protection Laws (including the CCPA) and only process Personal Data on Customer’s behalf.
9.2. Company will (i) not collect, retain, use, or disclose Personal Data for any purpose other than for the specific purposes set out in the Company terms of use and the Data Processing Agreement between Company and Customer; (ii) not sell Personal Data (as defined under the CCPA); and (iii) put in place appropriate technical and organizational measures to protect Personal Data against unauthorized or unlawful processing or accidental destruction, loss or damage.
10. International Storage.
Each Customer is advised to be aware that Personal Data that the Company collects might be transferred to, processed and stored outside of Customer’s jurisdiction, and that data protection laws in such jurisdiction where the information is collected stored and/or processed may differ from Customer’s jurisdiction. Each Customer hereby gives Customer’s consent to such transfer, processing and storage of Customer’s Personal Data outside its jurisdiction.
11. Personal Data of Children
11.1. The Company’s Service Offerings are not intended for children. Children under the age of 18, may use the Service Offerings only with the involvement of a parent or guardian.
12. Questions Regarding Customer’s Personal Data?
12.1. If Customer has any questions about this PP or Company’s data practices in general, Customer may contact Company using the following information: [email protected]
