Privacy Policy – Hailo

Privacy Policy

HAILO WEBSITE PRIVAY POLICY

Last Revised: August 2019

1. INTRODUCTION
Hailo Technologies Ltd., an Israeli private limited company, having its principal place of
business at 94 Yigal Alon St, Tel Aviv, 6789139 Israel (“Hailo“, “We“, “us” or “our),
welcomes you to our owned and operated website, at: https://hailo.ai/ (“Website“).

This Website Privacy Policy (the “Website Privacy Policy“) applies to: (i) the use of Hailo’s
owned and operated Website; (ii) our marketing activities including, registrations as part of
webinars, conference events, emails etc.; and (iii) any other product or activity that links or
otherwise references to this privacy policy (collectively, the “Marketing Platforms“).

Hailo are fully committed to protect the privacy of the visitors and/or users of our Marketing
Platforms (collectively, the “Visitors” or “Customers“, referred as “you” or “your“), in
compliance with applicable privacy and personal data laws and regulations.
This Website Privacy Policy is intended to describe our practices regarding the personal
information we may collect from you or to which we may have access, when you use or
interact with the Marketing Platforms, and the manner in which we may use such
information, and the choices and rights available to you.

2. YOUR CONSENT
PLEASE READ CAREFULLY THIS PRIVACY POLICY BEFORE ACCESSING AND USING OUR
MARKETING PLATFORMS. BY ACCESSING OR USING OUR MARKETING PLATFORM YOU ARE
ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DISAGREE TO ANY
TERM PROVIDED HEREIN, DO NOT ACCESS OR USE THE MARKETING PLATFORM.

PLEASE NOTE: YOU ARE NOT OBLIGATED BY LAW TO PROVIDE US WITH ANY PERSONAL
INFORMATION. HENCE, YOU HEREBY ACKNOWLEDGE AND AGREE THAT YOU ARE
PROVIDING US WITH PERSONAL INFORMATION AT YOUR OWN FREE WILL, FOR THE
PURPOSES DESCRIBED IN SECTION 4 BELOW, AND THAT WE MAY RETAIN SUCH PERSONAL
INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND ANY APPLICABLE LAWS
AND REGULATIONS.

3. INFORMATION WE COLLECT
We may collect several types of data and information from and about our Customers and/or
Visitors. In this section, we describe the categories of information which we may collect, and
the applicable circumstances under which such collection is performed.

3.1. First – What is Personal Information?
Personal information refers to individually identifiable information, namely 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
private or sensitive nature information, relating to an identified or identifiable natural
person. Identification of an individual includes association of such individual with a
persistent identifier such as a name, an identification number, persistent cookie
identifier etc.

Personal information does not include information that has been anonymized or
aggregated so that it can no longer be used to identify a specific natural person.

3.2. We collect personal information from you when you use or interact with our Marketing Platforms
We collect personal information from you and any devices (including mobile
devices) you use when you: use, interact or access our Marketing Platforms, register
for an account with us, provide us information on a web form or other text field
within our Website, update or add information to your account, or through
correspondence you and we conduct with each other.
More specifically we collect and use the following categories and types of
information in the following respective circumstances:

→ Personal information Visitors and Customers provide us actively and voluntarily when they use or interact with our Marketing Platform:

      • Contact information such as Customers and/or Visitors name, company
        number, signing person name and position, industry, topic of interest, email
        and physical addresses, and telephone number, all when such Customers
        and/or Visitors fill-in our online form or register for an account with us or
        when they update their account details.
      • When you voluntarily share information with us. For example, when you
        register to one of our events, submit your CV, or when send us free-text
        requests through our online forms, e.g. when you request to receive certain
        content (e.g. research and white papers) that we may share with You.
      • The contents of Customers and/or Visitors interaction with our customer
        support which may include text/video/audio recording and transcripts of
        such communications.
      • Information we are required or authorized by applicable national laws to
        require Customers and/or Visitors to provide us in order to authenticate or
        identify them or to verify the information we have collected or otherwise
        provide them with our Marketing Platforms.

→ Personal information we automatically obtain when Customers and/or Visitors use or interact with our Marketing Platforms:

      • This is information we obtain through the Marketing Platforms when
        Customers and/or Visitors access or interact with the Marketing Platforms,
        which is derived, learned, or detected as a result of such access and/or
        interaction.
      • We perform such automatic collection through use of cookies, web beacons,
        unique identifiers, and similar technologies which allow us to collect
        information about the pages and screens you view, the links you click, and
        other actions you take when using our Marketing Platforms, within our
        advertising or email content.

Keep in mind – Most devices allow you to control or disable the use of certain
collectable information including location services, in the device's settings menu. For
further information, You may refer to Section ‎9 .

3.3. Personal information collected from other sources

We may collect personal information concerning you, from third parties who have assured us that they have obtained your consent for such provision of information.
For example, we may collect and use demographic and other information that is
publicly available in an applicable jurisdiction, additional contact information,
credit/check information, and information from credit bureaus, as allowed by
applicable national laws.

Please Note – While most of the information we collect from you is not Personal
Information, we acknowledge that under certain jurisdictions the data we do receive when a
Customer and/or Visitor are using the Marketing Platform may be deemed personal data as
it is associated with a Technical Identifier, and therefore, where applicable, will be treated as
such.
You have the rights to choose how we collect and use your Information. See “Your Rights” at
section ‎12 below for more information.

4. THE PURPOSES

4.1 Legal basis for collecting and processing of Personal Information:
We collect, process and use your information for the purposes described in this Website
Privacy Policy, based at least on one of the following legal grounds:

      •  When performing an agreement with: Your information may be processed on the
        basis that such processing is necessary for the establishment and performance of
        our contractual engagements with you. Under such engagement we shall provide
        Customers and Visitors with the Marketing Platforms, maintain and improve our
        Marketing Platforms, develop new services and features for our Customers and
        Visitors.
      • Legitimate interests: We process your information for our legitimate interests while
        applying appropriate safeguards that protect your privacy. This means that we
        process information for reasons such as detecting, preventing, or otherwise
        addressing fraud, abuse, security, usability, functionality or technical issues with our
        Marketing Platforms, protecting against harm to the rights, property or safety of our
        properties, or  our users, or the public as required or permitted by law; enforcing
        legal claims, including investigation of potential violations of this Privacy Policy; in
        order to comply and/or fulfil our obligation under applicable laws, regulation,
        guidelines, industry standards and contractual requirements, legal process,
        subpoena or governmental request, as well as our TOU.
      • With consent: We ask for your agreement to process your information for specific
        purposes and you have the right to withdraw your consent at any time. For example,
        we ask for your consent to send you our marketing offers and communications.

We use personal information for the following purposes:

      • To process your inquiries and to respond to your requests. For example, when you
        contact us to learn more about our products or services or when you request to
        receive certain materials from us (e.g. white papers, research papers, product and
        services information). Additionally, if you submit your CV, we use it to evaluate your
        candidacy (including by assessing your qualifications and skills).
      • To send you information related to our services and products that we believe may
        interest you, such as newsletters or product and service updates. Such
        communications will be sent to you when you have chosen to receive such
        communication or when we have a legitimate interest to market our products and
        services. In any event, you will always be able to opt-out of receiving such
        communications. Opting out may be done either directly in the communication
        received or through the ways described in the instructions in the “Your Rights”
        section, at section 12 below.
      • To understand how you have used our Marketing Platforms and to customize them
        in accordance with your interests and past actions and choices. We do this based on
        our legitimate interest to operate our Marketing Platforms, diagnose any problems
        with the Marketing Platforms and to improve the Marketing Platforms and your
        experience when navigating through them.
      • In our legitimate interest to prevent fraud or harm to us or to any third party, and
        ensure the security of our network and services.
      • Where it is necessary for Hailo to comply with its legal obligations and to exercise
        and enforce its legal rights.
      • We may use certain third-party marketing and advertising networks to help us
        market our products on our own Website and on third party websites (e.g. re-
        marketing ads across the Internet by Google).

5. TO WHOM WE SHARE PERSONAL INFORMATION?
We may share your personal information with third parties (or otherwise allow them access
to it) only in the following manners and instances:

5.1. Third Party Services:

We are partnering with a number of selected service providers, whose services and
solutions complement, facilitate and enhance our own. These include hosting,
database and server co-location services (e.g., Google Cloud or AWS), data analytics
services (e.g. Google Analytics), e-mail and text message distribution and monitoring
services (e.g. Gmail), payment processors and analytics (e.g. PayPal), advertising,
affiliation and related analytics services (e.g. Facebook, LinkedIn, Twitter, Google),
research and development services (consultants hired by Hailo), customer support
services, and our business, legal and financial advisors (collectively, “Third Party Service Providers“).

Such Third Party Service Providers may receive or otherwise have access to your
personal information through your use of our Marketing Platforms, depending on
each of their particular roles and purposes in facilitating and enhancing the Marketing
Platforms, and may only use your personal information for such purposes. Such
disclosure or access is strictly subject to the recipient's or user's undertaking of
confidentiality and appropriate safeguards obligations, the prevention of any
independent right to use your personal information except as required to help us to
provide the Marketing Platform and subject to applicable law. We remain responsible
and liable for any personal information processing done by Third Party Service Providers on our behalf, except for such Third Party Service Providers with whom you
have a direct contractual relationship.

5.2. Governmental/Law Enforcement Agencies and Legal Requests or Duties:

We may disclose or otherwise allow access to personal information pursuant to a legal
requirement or request, such as a subpoena, search warrant or court order, or in
compliance with applicable laws and regulations. Such disclosure or access may occur
with or without notice to the data subject or the Customer, if we have a good faith
belief that we are legally required to do so, or that disclosure is appropriate in
connection with efforts to investigate, prevent, or take action regarding actual or
suspected illegal activity, fraud, or other wrongdoing.

5.3. Protecting Rights and Safety:

We may share your personal information with others, with or without notice to you, if
we believe in good faith that this will help protect the rights, property or personal
safety of our Company, any of our Customers and Visitors, or any members of the
general public.

5.4. Our Affiliated Companies:

We may share personal information internally within our family of companies, for the
purposes described in this Website Privacy Policy. In addition, should we or any of our
affiliates undergo any change in control, including by means of merger, acquisition or
purchase of substantially all of our assets, your personal information may be shared
with the parties involved in such event. If we believe that such change in control
might materially affect your personal information then stored with us, we will notify
you of this event and the choices you may have via e-mail and/or prominent notice on
our Marketing Platforms.

For the removal of doubt, we may share Personal Information in additional manners,
pursuant to the applicable relevant approval, or if we are legally obligated to do so.
Additionally, we may transfer, share or otherwise use non-personal information in our
sole discretion and without the need for further approval.

6. DIRECT MARKETING
By providing us with your e-mail address or any other contact information Customers and
Visitors hereby agree that Hailo may use your contact details for the purpose of informing
you of our events, products and services offered by us and to send you newsletters or
marketing materials. You may withdraw your consent by sending a written notice to by
email to the following address: contact@hailo.ai or by opting out by clicking the
“unsubscribe” button. Please note that we may notify you (through any of the means
available to us) of changes or updates to our platforms and our other services, payment
issues, service maintenance, etc., and you will not be able to opt-out of receiving such
service messages.

7. MINORS
Hailo does not knowingly collect or process personal data from or with respect to children
under the age of 18, and you must be 18 years of age or older in order to contact us through

our Marketing Platforms. If you are a parent or legal guardian and believe that your child
under the age of 18 has submitted his or her personal data or other data without your
consent, permission, or authorization – please let us know immediately, and we will
promptly act to remove your child’s data from our database, cease the use of such data and
inform any other party we suspect to have access to such data to do the same.

8. INFORMATION SECURITY
We take a great care in implementing and maintaining the security of the Website and the
Marketing Platforms.  Hailo employs industry standard procedures to ensure the safety of
Personal Information and prevent unauthorized use of any such information (such as
Firewall). However, we do not and cannot guarantee that unauthorized access will never
occur.
If you have any questions regarding the security of our Marketing Platforms, please feel free
to contact us by sending us an email to: contact@hailo.ai.

9. THIRD PARTY SERVICES, COOKIES AND OTHER TRACKING TECHNOLOGIES
To learn more about our use of third party services, cookies and other tracking technologies,
please refer to our Cookies Policy.

10. INFORMATION STORAGE AND RETENTION
Personal information regarding the Customers and Visitors will be maintained, processed
and stored by us and our authorized affiliates and service providers in Israel and as
necessary, in other territories in secured cloud storage, provided by our third party service
provider.
While the data protection laws in the above jurisdictions may be different than the laws of
your residence or location, please know that we, our affiliates and our service providers that
store or process your personal information on our behalf are each committed to keep it
protected and secured, pursuant to this Website Privacy Policy and industry standards,
regardless of any lesser legal requirements that may apply in their jurisdiction.
Specifically, each of our services providers who stores or processes your personal
information either, (i) assured us that it provides adequate safeguards to protect your rights
to privacy, or (ii) holds and processes such information on our behalf in a jurisdiction which
has been determined to ensure an adequate level protection by the EU Commission which if
in the US, includes certification under the EU-US Privacy shield framework.
You hereby accept the transfer and storage of information as described above.

11. MODIFICATIONS TO THIS POLICY
Hailo may amend this Website Privacy Policy at any time, provided that in the event of a
material change we shall provide notice on this page and/or a note near the link to this page.
The updates shall apply immediately for new Information collected or provided as of the day
of the update and following thirty (30) days for any Information collected or provided to
Hailo prior to the update date. If you do not agree to the terms of the new policy you are
requested to contact the Legal Department using the contact details listed in Section 12
below. We encourage you to periodically review this page for any updates.

12. YOUR RIGHTS: UPDATING, OBTAINING A COPY OF, DELETING OR WITHDRAWAL OF
CONSENT FOR PROCESSING OF, PERSONAL INFORMATION
If the law applicable to you grants you such rights, you may ask to access, correct, or delete
your personal information that is stored in our systems or that we otherwise control. You
may also ask for our confirmation as to whether we process your personal information, or
ask to withdraw any consent you have previously provided to us in connection with our use
and processing of your personal information.
Subject to the limitations in law, you may request that we update, correct, or delete
inaccurate or outdated information. You may also request that we suspend the use of any
Personal Information the accuracy of which you contest while we verify the status of that
data.
Subject the limitations in law, you may also be entitled to obtain the personal information
you directly provided us in a structured, commonly used, and machine-readable format and
may have the right to transmit such data to another party.
If for any reason you wish to modify or delete your Personal Information you can do so by
sending us an email to: contact@hailo.ai. We will make reasonable efforts to modify
or delete any such Personal Information pursuant to any applicable privacy laws.
Note that unless you instruct us otherwise we may retain your personal information for a
period for as long as reasonably needed to provide the Marketing Platforms and/or as legally
required.
To find out whether these rights apply to you and on any other privacy related matter, you
can contact your local data protection authority if you have concerns regarding your rights
under local law.

13. HAVE ANY QUESTIONS?
If you have any questions or concerning this Website Privacy Policy, you are welcome to fill-
in our online contact form at: https://hailo.ai/contact-us/, send us an e-mail to:
contact@hailo.ai or contact us by physical mail to: Hailo Technologies Ltd., 94 Yigal
Alon St, Tel Aviv, 6789139 Israel. We will make an effort to reply within a reasonable
timeframe.
By contacting us, and accessing the Marketing Platforms, you warrant and agree that you
are free to do so, and that you are not providing us with information which violates any third
party intellectual or privacy rights.