UPRIGHT PRIVACY POLICY

Last Updated: December 15, 2020

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

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. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals and the “Do Not Sell My Personal Information” mechanism(s) below are only relevant for CCPA-protected individuals.

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 data
  3. How we share your personal data
  4. Additional information regarding transfers of personal data
  5. Your privacy rights
  6. Use by children
  7. Interaction with third party products
  8. Log files
  9. Analytic tools
  10. Specific provisions applicable under California privacy law
  11. How to contact us

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

Specific personal data we collectSources (where we obtain the personal data from)Why is the personal data collected and for what purposes?Legal basis (GDPR only, if applicable)Third parties with whom we share your personal dataRetention periodConsequences of not providing the personal data
When you browse or visit our Website
Cookies, analytic tools and log files. For more information, please read our cookies policyDirectly from consumer’s device by using cookies or other tracking technologiesMarketing, advertising and analytics purposes.Consent“3rd party platforms such as for the following purposes:
Google Analytics
Facebook – Use of Facebook Pixel
For more information, please read our cookies policyCertain Website features may not be available. Read more about the purposes of each cookie here
When you make use of, or interact with, our Website
When your purchase our products and/or services
  • Email address
  • Full name
  • Shipping address
  • Phone number
  • Card number
  • Credit card details
  • Billing address
Directly from the consumer through our Website
  • To allow you to purchase our products / services
  • To allow you to receive the products / services that you purchased
  • To send you communications in connection with your purchase
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to deliver the products that you purchased)

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • Shopify – e-commerce shop
  • Segment – Customer data platform
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.

Cannot allow you to purchase our products / services

Cannot allow you to receive the products / services that you purchased

Cannot send you communications in connection with your purchase

  • Email address
  • Full name
Directly from the consumer through our WebsiteTo send you marketing communicationConsent
  • Google Analytics
  • Facebook – Use of Facebook Pixel
  • AWS – Storage
  • Klavio – Marketing email system
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.Cannot send you marketing communication
When you post a comment on a blog post
  • Full name
  • Email address
  • Any information that you decide to provide us
Directly from the consumer through our Website
  • To allow you to post a comment and react on a blog post
Legitimate interest (e.g., to allow you to comment on a blog post)

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • Segment – Customer data platform
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.Cannot post a comment and react on a blog post
  • Email address
  • Full name
Directly from the consumer through our Website
  • To send you marketing communication
Consent
  • Google Analytics
  • Facebook – Use of Facebook Pixel
  • AWS – Storage
  • Klavio – Marketing email system
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.Cannot send you marketing communication
When you write a customer review about out our products/services
  • Full name
  • Email address
  • Photos
  • Any information that you decide to provide us
Directly from the consumer through our Website
  • To allow you post a review about our products/services
Legitimate interest (e.g., to allow you to post a customer review)

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • Stamped.io – Feedback tool
  • Segment – Customer data platform
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention lawsCannot post a review about our services/products
  • Email address
  • Full name
Directly from the consumer through our Website
  • To send you marketing communication
Consent
  • Google Analytics
  • Facebook – Use of Facebook Pixel
  • AWS – Storage
  • Klavio – Marketing email system
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention lawsCannot send you marketing communication
When you subscribe to our newsletter
  • Email address
  • Full name
  • Any information that you decide to provide us
Directly from the consumer through our Website
  • To send you more information about Upright
  • To send you Upright’s updates, special deals and other materials
Consent

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • Klavio – Marketing email system
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.Cannot send you more information about Upright
Cannot send you Upright’s updates and other materials
When we process your job application
  • Full name
  • Email address
  • CV / cover letter
  • Any other information that you decide to provide/supply us
As applicable, (1) directly from you when you apply for a position through our website or social media accounts (e.g., LinkedIn) or (2) from a recruitment agency
  • To assess you as a candidate
  • To analyze your job application
  • To contact you in connection with your job application

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. to analyze your application)

3rd party platforms such as for the following purposes:

  • Gmail – Email
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws

Cannot assess you as a candidate

Cannot analyze your job application

Cannot contact you in connection with your job application

When you contact us (e.g. customer support, chatbox, partnership, media)
  • Full name
  • Email address
  • Any other information that you decide to provide us
Directly from the consumer through our Website
  • To receive and respond to your request
  • To customize your experience
  • To provide support

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to respond to your request)

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • Intercom – Support
  • Gmail – Email
  • Segment – Customer data platform
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention lawsCannot receive and respond to your request
Cannot customize your experience
Cannot provide support
  • Email address
  • Full name
Directly from the consumer through our Website
  • To send you marketing communication
Consent
  • Google Analytics
  • Facebook – Use of Facebook Pixel
  • AWS – Storage
  • Klavio – Marketing email system
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention lawsCannot send you marketing communication
When you make use of, or interact with, our App mobile software applications “UPRIGHT GO” or “UPRIGHT GO 2”
When you download our App, create an account and when you log in
  • Information about Upright Go device
  • Information about your phone (Model and OS version)
  • Full name
  • Email
  • Password
Directly from the consumer through the App
  • To allow you to download the App
  • To create an account on the App
  • To access our App and your account
  • To contact you with notifications about your device, use of the software and new features, as well as to let you know if we believe something was compromised.

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g., to allow you to create an account)”

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • Intercom – Support
  • Firebase – Analytics
  • Segment – Customer data platform
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.Cannot download the App
Cannot create an account
Cannot access your account
Cannot contact you with notifications about your device, use of the software and new features. Cannot let you know if we believe something was compromised.
When you create and customize your training plan
  • Gender
  • Weight
  • Height
  • Age
  • Photo (optional)
  • Approximate location
  • information relating to your use of the device, which includes the number of hours you sit and move each day, the pain levels you experience, your postures and progress
  • Information about your habits, work environment, fitness routines and training preferences
  • Back pain level and posture level (Mandatory information)
  • Any information that you decide to provide us
Directly from the consumer through the App
  • To provide our services
  • To create your training plan
  • To customize your training plan
  • To send you notifications about your training plan and your progress
Legitimate interest (e.g., to create your training plan)
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • Intercom – Support
  • Firebase – Analytics
  • Segment – Customer data platform
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention lawsCannot create your training plan
Cannot customize your training plan
Cannot send you notifications about your training plan and your progress
When you use Upright Go device sensors
  • Posture score
  • Movement level
  • Accelerometer values
  • Smooth angle
From the use of the Upright Go device sensors
  • To analyze your current posture and activity and to provide feedback to you
  • To understand your device level data, your posture score, your movement levels, and additional technical information including whether you slouched, sat at a smooth angle, had some training, and how you interacted with or  without vibrations

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to analyze your posture and provide feedback)

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • MongoDB Atlas – Cloud database service
  • PostgressTimescale – Cloud database service
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws

Cannot analyze your current posture and activity and provide feedback to you

Cannot understand your device level data, your posture score, your movement levels, and additional technical information including whether you slouched, sat at a smooth angle, had some training, and how you interacted with or  without vibrations

When you chat with us on the App
  • Full Name
  • Email address
  • Information about your use of Upright Go device sensors
  • Posture level and pain level
  • Any other information that you decide to provide us
Directly from the consumer through the App
  • To receive and respond to your request
  • To customize your experience
  • To provide support
Legitimate interest (e.g., to receive and respond to your request)

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • Intercom – Support
  • Segment – Customer data platform
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention lawsCannot receive and respond to your request
Cannot customize your experience
Cannot provide support
When you log in and make use of, or interact with, our Desktop application
  • Full name
  • Email address
  • Password
  • Posture and movement information
Directly from the consumer
  • To create an account on the App and to log in to the App
  • To provide our services to you

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g., to allow you to log in to the App)

3rd party platforms such as for the following purposes:

  • AWS – Storage
  • Segment – Customer data platform

Your full name, email address and password will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.

Posture and movement information are retained for as long as we need such information for analysis purposes. However, we will not further store such information once the analysis is done.

Cannot create an account on and log in to the App

Cannot provide our services to you

When we use the personal data of our service providers (e.g. contact details)
  • Full name
  • Email address
  • Phone number
  • Company name
  • Any other information that you decide to provide/supply us
Directly from the consumer
  • To contact our service providers
  • To perform the applicable agreement

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as for the following purposes:

  • Gmail – Email
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws

Cannot contact our service providers

Cannot perform the applicable agreement

When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, YouTube)
  • Full name
  • Email address
  • Any other data you decide to provide/supply
Directly from the consumer
  • To respond to your requests in our social media channels
Legitimate interest (e.g. respond to your requests in our social media channels)

3rd party platforms such as for the following purposes:

  • Google Analytics
  • Facebook – Use of Facebook Pixel
  • AWS – Storage
  • Klavio – Marketing email system
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention lawsCannot respond to your request in our social media channels
Cannot send you marketing communication
  • Full name
  • Email address
Directly from the consumer
  • To send you marketing communication
Consent

3rd party platforms such as for the following purposes:

  • Google Analytics
  • Facebook – Use of Facebook Pixel
  • AWS – Storage
  • Klavio – Marketing email system
Your personal data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention lawsCannot respond to your request in our social media channels
Cannot send you marketing communication

Finally, please note that some of the above mentioned 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. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. 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. Retention of your personal data. In addition to the retention periods mentioned 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. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookies policy.

3. HOW WE SHARE YOUR PERSONAL DATA

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

  1. With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
  2. To the extent necessary, with regulators, courts 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;
  3. 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;
  4. 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. Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

  1. Storage: AWS – Oregon – US
  2. Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here:
    https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
  3. External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data.

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

  1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to
    certain individuals (some of which only apply to individuals protected by the GDPR):
    • You have a right to access personal data held about you. Your right of access may 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 rectify any personal data we hold that is inaccurate or misleading;
    • You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
    • You have the right to object, to or to request restriction, of the processing;
    • You have 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 the right to withdraw your consent at any time. Please note that 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. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
    • You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
    • 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 or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
  2. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the CCPA:
    • You have the right to know what Personal Information is being collected about you. This includes the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell;
    • You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
    • You have the right to know whether your Personal Information is sold or disclosed and to whom;
    • You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
    • You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA;
    • 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 or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution. You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.
  3. You can exercise your rights by contacting us at [email protected]. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. 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.
  4. Deleting your account: Should you ever decide to delete your account, you may do so by emailing [email protected]. If you terminate your account, any association between your account and personal data 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.

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data 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 [email protected].

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

8. LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

9. 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/.
  • Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at
    https://firebase.google.com/terms/) shall also apply.
  • Mixpanel. We collect personal information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at , and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link:
    https://mixpanel.com/optout/.
  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at:
    https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms:
    http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

We reserve the right to remove or add new analytic tools.

10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

This Privacy Policy for California Residents supplements and is expressly made part of the information contained in this Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.

Our California Do Not Track Notice (Shine the Light): Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but 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 web sites when a consumer uses the Services.

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 information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

Sale of Personal Information: We do not sell (as such term is defined in the CCPA) the Personal Information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in our cookie policy.

Your Choices

  • You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any issue to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
  • Personal Information collected in the last 12 months it is described above in Section 1. If you have further questions with respect the collection, use, disclosure or sale of your personal information, please make your request by contacting us to
    [email protected].
  • Your privacy rights: Please see Section 5 above.
  • Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK” to [email protected]. Please note that the email must come from the email account you wish to block.
  • Non-Discrimination: If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. However, note that some features of our website, our products and/or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:
    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
    • However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

11. HOW TO 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 [email protected].

Data controller:
Upright Technologies. LTD
Shoken 23, Tel Aviv, 6653208,
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