Privacy Policy

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: [email protected] 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: [email protected].

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: [email protected]. 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:
[email protected] 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.

Hailo Privacy Notice for Candidates

This privacy notice (the “Notice”) describes the ways that Hailo Technologies Ltd. and its affiliates (collectively, “Company”, “we”, “us”, “our”), collects and uses your Personal Data as a candidate (“you” or “candidate”). We work with data processors to whom we have instructed to collect, store and process Personal Data on our behalf for the purposes of facilitating, assessing and operating your candidacy and recruitment process at the Company, for example, Comeet, as a recruiting and applicant tracking platform (“Platform”) in order to handle your personal data as a candidate. It also describes the rights and options available to you with respect to your personal data.

We may have an additional privacy notice(s) explaining our own specific privacy practices related to your personal data (“Company Notice”).

If you have any questions related to your personal data, please contact us at [email protected] with a copy to [email protected] .

1. PERSONAL DATA PROCESSED

We receive Personal Data about you as a candidate for positions at the Company, such as: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes or any other documents submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Company about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy (collectively, “Personal Data”). If you submit your candidacy by email, or online, then you are the main source of Personal Data. Your personal data can also originate from other sources, such as LinkedIn profile, recruitment agencies, headhunters and referrals.

2. HOW YOUR PERSONAL DATA IS USED. LEGAL BASIS.

We will use your personal data in accordance with our Company Notice (if any is made available to you), including to evaluate and consider you as a candidate for positions, in accordance with its processes and policies for evaluating employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and interviews, amongst others.

The lawful bases we rely on for processing personal information are (if applicable to us under privacy law):

You gave us your consent to the processing of your personal data (for one or more specific purposes);
Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
Processing is necessary for the purposes of our legitimate interests; and/or
Processing is necessary for compliance with a legal obligation to which we are subject.

If you have questions about these uses, please contact us.

3. WHO WILL PROCESS YOUR DATA

We may share your Personal Data with our service providers and vendors who assist us to collect, process and store your personal data as further described in our Company Notice, including, without limitation, Comeet (who provides us with the Platform) in the context of your candidacy. These companies are authorized to use your personal data as necessary to provide these services or as otherwise authorized by us.
Personal Data may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by us, directly).
We may share your general recruitment status with third parties who submitted your candidacy to us.
If your details are submitted to the Company by a third-party (such as an employee of the Company or a recruiting agency), the Company can give the third-party access to your name, photo and some of the general recruitment status.
If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company to which you are applying, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link.
The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Company and to provide feedback to third-parties who submit candidates to the Company regarding their submission.
If we are required to disclose your Personal Data by a judicial, governmental and/or regulatory authority 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.
If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events.
In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

If you wish to receive further information, please contact us.

4. SECURITY AND DATA RETENTION

Retention. We will retain your Personal Data for as long as we need it to assess you as a candidate or as long as we have a valid legal basis. In accordance with our internal data retention policies and practices, we can decide whether to keep your personal data, delete it or pseudonymize/anonymize it.
Security. We implement industry standard measures to reduce the risks of damage, loss, unauthorized access, or use, of your Personal Data. Despite these measures, Company cannot provide absolute information security or eliminate all risks associated with Personal Data, and security breaches may happen. If there are any questions about our security practices, please contact us.

5. INTERNATIONAL DATA TRANSFERS

We host your personal data in connection with our use of the Platform either in Europe, in the US, in Israel or in countries deemed as providing an adequate level of data protection.

6. YOUR RIGHTS

Your rights may vary, depending on the applicable law. These rights may not be available in certain jurisdictions and/or may be subject to certain derogations or limitations. You may have the following rights:

To ask us to receive a copy of your Personal Data that is stored on our servers, including the Platform;
to update, correct and/or delete your Personal Data;
to request the restriction of processing concerning your Personal Data or to object the processing of your Personal Data;
to request to obtain a copy of your Personal Data in a structured, commonly used and machine-readable format;
If we rely on consent, please note that you have the right to withdraw consent at any time; and/or
to lodge a complaint with a supervisory authority.

If you wish to exercise any of these rights, please contact us. If you choose to exercise any of your rights, we will handle these requests in accordance with applicable law but please note that exercise of some of those rights may have some consequences in your application as a candidate.

7. MINORS

We do not intend to collect personal data of children. If you have reason to suspect that personal data pertaining to children under the age of 16 is collected, you are kindly requested to immediately report it to us. If you have questions regarding children’s personal data contact us.

8. CHANGES TO THIS PRIVACY NOTICE

From time to time, we may change or update this Notice. If we do so, we will make efforts to notify you of such changes by any means.

9. CONTACT US

You may send requests, responses, questions and complaints by contacting us using the information provided below.

Hailo Technologies Ltd., 82 Yigal Alon St. Tel Aviv-Yaffo Israel, 6789124, [email protected] with a copy to [email protected].

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Privacy Policy

Hailo Privacy Notice for Candidates