April 2024
This Privacy Policy (this “Privacy Policy”) outlines how Hailo Technologies Ltd. and its subsidiaries (together “Hailo,” “we,” “us,” or “our”) collect, use, and disclose information that is provided to us, as well as the choices you may have with respect to such information.
Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Website Terms of Use (the “Site Terms of Use”) which this Privacy Policy is incorporated thereto by reference. This Privacy Policy supplements and shall be read in conjunction with our Site Terms of Use and our Cookie Policy (the “Cookie Policy”), and may be amended from time to time by additional privacy statements, terms or notices provided to you.
This Privacy Policy applies to information that is shared through accessing and using the Hailo website(s), located at https://hailo.ai/, https://community.hailo.ai/ and any of their subdomains (each, a “Website” and collectively, the “Websites”), any use of our artificial intelligence processors and their associated software (the “Solution”), and any services provided by Hailo related to the Websites (the Websites and Solution, shall be collectively regarded herein as the “Services”).
This Privacy Policy governs and is intended to describe our practices regarding information (including Personal Data as defined below) that we may collect from or about you when you use or access the Services, the ways in which we may use such information, and the choices and rights available to you.
Users of our Services (referred to, unless otherwise specifically indicated, as “Users” or “you” collectively) may include (i) individuals who use our Solution in their capacity as employees or other personnel of our business customers (our business customers are hereafter a “Customer”) including individuals identifying as a Customer “admin” users or a Customer’s end-users, using or accessing the Services on a Customer’s behalf (each, a “Customer End-User”); (ii) visitors of the website (each, a “Visitor”); and (iii) Candidate(s) (as defined below).
IMPORTANT NOTE: where we process Personal Data of or about Customer End-Users, we do so on behalf of and under the instruction of the respective Customer (where such a Customer may be your employer, or other corporation on behalf of which you perform services, or otherwise are using our Service), Hailo does so in our capacity as a “data processor” on behalf of such a Customer. See below for more information about our practices as a data processor and the impact on your Personal Data in our possession.
The provisions of this Privacy Policy as they relate to Hailo’s independent privacy and data processing activities as a “data controller” – with respect to Users who are Visitors or Candidates – do not apply to the processing of Personal Data of Customer End-Users. If you are using our Services (including the Solution) as a Customer End-User, or if you otherwise have any questions or requests regarding Customer End-Users’ Personal Data, please contact the Customer on behalf of which you use the Solution (usually this will be your employer or corporation for which you provide a service).
PLEASE READ THIS PRIVACY POLICY BEFORE ACCESSING AND/OR USING OUR SERVICES OR ANY PART/COMPONENT THEREOF. BY ACCESSING OR USING THE SERVICES OR ANY PART/COMPONENT THEREOF, YOU AGREE TO THE TERMS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA (AS DEFINED BELOW). IF YOU DISAGREE WITH ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SERVICES.
PLEASE NOTE: YOU ARE NOT OBLIGATED BY LAW TO PROVIDE US WITH ANY PERSONAL DATA. YOU HEREBY ACKNOWLEDGE AND AGREE THAT YOU ARE PROVIDING US WITH PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY AT YOUR OWN FREE WILL. YOU HEREBY AGREE THAT WE MAY COLLECT AND USE SUCH PERSONAL DATA PURSUANT TO THIS PRIVACY POLICY AND ANY APPLICABLE LAWS AND REGULATIONS.
TO THE EXTENT THAT YOU PROVIDE US WITH ANY PERSONAL DATA RELATED TO ANY THIRD PARTY OR ANY OTHER PERSON OR ENTITY THAT IS NOT YOU, INCLUDING INFORMATION RELATED TO ANY OF YOUR PERSONNEL, COLLEAGUES OR CUSTOMERS, YOU ARE SOLELY RESPONSIBLE FOR RECEIVING AND HEREBY REPRESENT THAT YOU HAVE AND UNDERTAKE THAT YOU SHALL HAVE AT ALL TIMES, MAINTAINED AND RECEIVED, THE CONSENT, AUTHORITY, PERMISSION AND APPROVAL OF SUCH PERSONS OR ENTITY AND PROVIDED THEM WITH SUFFICIENT DISCLOSURES, TO ALLOW HAILO TO ACCESS, STORE, COLLECT, ANALYZE AND PROCESS SUCH PERSONAL DATA AS DETAILED HEREIN.
We collect both personal data, and non-personal data. “Personal Data” is information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of a private or sensitive nature relating to an identified or identifiable natural person. Identification of an individual also includes the association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc. Personal Data does not include information that has been anonymized or aggregated, provided however that such information can no longer be used to identify a specific natural person.
“Non-Personal Data” is collected without particular reference to the identity of the applicable User from or about whom such information was collected and is available to us while such User is using the Services. Non-personal Information which is being collected consists of technical, behavioral and aggregated information, and may contain the activity of the User on our Website, type of operating system, User’s ‘click-stream’ on the Website, type of browser and keyboards features, User demographics, traffic patterns, etc.
Most of the information that we collect when you use or access our Services is Non-Personal Data, however we collect and process different types of Personal Data through the respective methods of collection discussed below.
If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g., through a contact form.
In the course of accessing or otherwise using our Services, we receive your Personal Data through the following sources:
Please review the “USING COOKIES AND OTHER TRACKING TECHNOLOGIES” section below to learn more about how we use cookies and other tracking technologies.
We also analyze and use the Personal Data that we collect on an anonymized or aggregated basis for product development, to analyze the performance of our Services, to troubleshoot and to improve and optimize the Services and to ensure the best User experience for our users as a whole.
We may share your Personal Data with third parties (or otherwise allow them access to it) only in the following manners and instances:
Hailo welcomes all qualified candidates (“Candidates”) to apply to any of the open positions posted on our Website, Facebook, LinkedIn, or other social networking platforms, by sending us their contact details, name and CV, LinkedIn profile, your Portfolio and any additional information you voluntarily provide us via your personal note, cover letter or similar documents (“Candidate Information”). We are committed to keeping Candidate Information private and use it solely for our internal recruitment purposes (including for identifying Candidates, evaluating their applications, making hiring and employment decisions, and contacting Candidates by phone or in writing).
Please note that Hailo may retain Candidate Information submitted to it even after the applied position has been filled or closed for a reasonable time period. This is done so we could re-consider Candidates for other positions and opportunities at Hailo; so, we could use their Candidate Information as reference for future applications submitted by them; and in case the Candidate is hired, for additional employment and business purposes related to their work. If you previously submitted your Candidate Information to Hailo, and now wish to access it, update it or have it deleted from our systems, please contact us at [email protected].
Information regarding the Users may be maintained, processed, and stored by us and our authorized affiliates and Service Providers in the EU. Where Hailo processes Personal Data on behalf of a Customer (including without limitation, Personal Data of Customer End-Users), such Personal Data will be processed in the locations as permitted and required by the Customer (as further described below).
While the data protection laws in the above jurisdictions may be different than the laws of your residence or current location, please know that we, our affiliates, and our Service Providers that store or process your Personal Data on our behalf, are each committed to keep it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in our respective jurisdictions.
Specifically, each of our third party Service Providers which store or process your Personal Data have either:
By providing your Personal Data, you expressly consent to the place of storage and transfer described above, including transfers outside of the jurisdiction in which the information was provided.
We retain the Personal Data we collect or receive from you for as long as needed in order to provide the Services and as otherwise necessary to comply with applicable laws and regulations.
If you withdraw your consent to us processing your Personal Data, including by deleting your account, we will delete your Personal Data from our systems (except to the extent such data in whole or in part is required to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our affiliates), except where we process your information as a Processor on behalf of our Customer (such as your employer is a Customer who makes use of our Services, in which case data retention is subject to such Customer’s instructions).
We take great care in implementing and maintaining the security of the Services and of your Personal Data. We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use or disclosure of your Personal Data. Your Personal Data is stored on secure servers and is not publicly available. We limit access of your Personal Data only to those employees, third-party Service Providers or other partners on a “need to know” basis, and strictly in order to enable us to perform our agreement with you.
Despite these measures, Hailo cannot provide absolute information security or eliminate all risks associated with Personal Data, and security breaches may happen. If there are any questions about security, please contact us at [email protected].
If for any reason you wish to exercise any rights to which you are entitled, you may do so by contacting us at [email protected]. When handling these requests, we may ask for additional information to confirm your identity and your request.
The rights which you may be able to exercise may include, but are not limited to, the following:
To accept this Privacy Policy and use our Services, Users must be over eighteen (18) years of age. Therefore, we do not knowingly collect Personal Data from individuals under the age of eighteen (18) and we do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that individuals under the age of eighteen are not using the Services.
If you believe that we might have any information from or about an individual under the age of eighteen (18), please contact us at [email protected]. Should it come to our attention that a person under the age of eighteen (18) is using the Services, we may prohibit and block such User from using the Services and will make all efforts to promptly delete any Personal Data with respect to such User.
If you are submitting any Personal Data pertaining to any minor to the Services, you hereby represent and warrant that you have received all the necessary legal consents or approvals or that you are the parent or legal guardian and have the actual authority and legal right to upload, submit, disclose or otherwise share such Personal Data and/or any other form of sensitive information, on the minor’s behalf.
Under various privacy, data protection or similar laws, regulations, or additional legal frameworks, such as the GDPR or the CCPA, two separate roles for parties involved in the processing Personal Data typically apply:
Hailo is the “data controller” of its Visitors and Candidates’ Personal Data, as detailed above. Accordingly, we assume the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this Privacy Policy.
Hailo is the “data processor” of personal data contained in Customer End-Users’ Personal Data, as submitted or otherwise provided to us by our Customers and/or Customer End-Users. We process such data on behalf of our Customer (who, in turn, is the “data controller” of such data) and in accordance with its reasonable instructions, and our commercial agreements with such Customer.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in any Personal data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the Customer. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Customer End-Users and other individuals whose data they process through the Services (and accordingly, if you are a Customer End-User or other individual whose Personal Data was provided to us in connection with Customer’s use of the Services, Hailo does not provide to you the rights set forth in Section 10 above).
If you would like to make any requests or queries regarding personal data we process as a data processor on our Customer’s behalf, including accessing, correcting, or deleting your data, please contact the Customer and/or an applicable Customer End-User directly.
This Privacy Policy is subject to changes from time to time, at our sole discretion. The most current version will always be posted on our Services (as reflected in the “Last Revised” heading). You are advised to check for updates regularly.
We will provide notice of substantial changes of this Privacy Policy on the homepage of the Website and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided to us. Such substantial changes will take effect seven (7) days after such notice was provided on our Services or sent by e-mail. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.
If you wish to exercise your rights or receive more information regarding our privacy protection practices, please contact us using the details provided below:
Hailo Technologies Ltd.
82 Yigal Alon Rd. Tel Aviv-Yaffo, Israel, 6789124
