Seemplicity Security Ltd. – Privacy Policy

This privacy policy (“PP“) explains how Seemplicity Security Ltd. and its affiliates (“Seemplicity“) collect, use, store and share Personal Data of users (“User/s” and or “Subscriber/s”) in connection with the Seemplicity website available at www.seemplicity.io (the “Site”). For the purpose of this Privacy Policy “Personal Data” shall mean personal data or personal information pursuant to the Applicable Data Protection Law (as defined below).

APPLICABILITY.

The PP is an integral part of Seemplicity’s terms of use which are available at www.seemplicity.io/terms-of-use (“TOU“), together with the PP, and the terms of use, the “Terms“).
This PP is in effect as of the date set forth below.
Subscribers are not under any legal obligation to submit Personal Data to Seemplicity. However, in case Subscriber chooses not to submit Personal Data to Seemplicity, Subscriber might not be able to use the Site.
By attempting to use or access, or by using or accessing the Site, User agrees to be bound by the Terms. If Subscriber does not agree with the Terms Subscriber must not use or access the Site.
Seemplicity may change this PP from time to time, therefore Subscriber should check back periodically. Any changed PP will be effective from the date it is posted on Seemplicity’s Site. If Seemplicity makes any changes to this PP that materially affect Seemplicity’s practices with regard to the Personal Data Seemplicity previously collected from Subscriber, Seemplicity will endeavor to provide Subscriber with notice in advance of such change via email. Seemplicity will seek Subscriber’s prior consent to any material changes, if and where this is required by Applicable Data Protection Laws.
This Privacy Policy does not apply to any content processed and/or stored by Subscriber when using the Site.
Any capitalized terms which are not defined herein shall have the meaning assigned to them in the Seemplicity TOU.
For the purposes of this Privacy Policy “Applicable Data Protection Laws“ means (i) the General Data Protection Regulation (2016/679), including any subordinate or implementing legislation (“GDPR”); (ii) the California Consumer Privacy Act of 2018, Cal. Civ. Code 1798.100 et seq., including any subordinate or implementing legislation (“CCPA“), and/or (ii) Protection of Privacy Law 5741-1981 (Israel); and any rules or regulations that amend and/or replace any of the aforementioned Applicable Data Protection Laws.

PERSONAL DATA COLLECTED BY SEEMPLICITY.

Information provided by Subscriber.

Seemplicity collects any data Subscriber provides Seemplicity with, including but not limited to:

Subscriber’s contact details (e.g. name, surname, email address, phone number);
Any communication between Subscriber and Seemplicity, e.g. emails, phone conversations, chat sessions (except as indicated differently by Subscriber on the Site).

Information collected automatically.

Seemplicity automatically collects data when Subscriber visits, interacts with, or uses the Site, including but not limited to:

Identifiers and information contained in cookies;
Subscriber’s settings preferences, backup information;
Content Subscriber viewed or searched for, page response times, and page interaction information (such as scrolling, clicks, and mouse-overs);
Network and connection information, such as the Internet protocol (IP) address and information about Subscriber’s Internet service provider;
Device information, such as browser type and version, operating system, or time zone setting; location of the device.

PERSONAL DATA COLLECTED BY THIRD PARTIES.

This PP does not apply to any products, services, websites, links or any other content that are offered by third parties on the Site. Subscriber is advised to check the applicable third party agreements, and/or other third party policies. Seemplicity does not have any control over such third parties’ privacy practices, or the technology used by such third parties in order to collect any personal data. Each Subscriber is advised to thoroughly review such third parties’ privacy policies before making any use of such third party’s products and services.
Without derogating from the generality of the above, when clicking on certain social media links provided on the Site (e.g. Twitter, Facebook, LinkedIn) Subscriber will be transferred to Seemplicity’s sites on such social media (“Social Media Sites“). It shall hereby be clarified that such Social Media Sites are governed by the terms of use and privacy policy of the respective social media and not by Seemplicity.

COOKIES.

To facilitate and customize the User’s experience of the Site and to track User’s use of the Site, Seemplicity may utilize cookies and other industry standard technologies . A cookie is a small text file that is stored on a User’s computer for record-keeping purposes which contains information about that User. Most browsers automatically accept cookies, but Usermay be able to modify its browser settings to decline cookies. Please note that if User declines or deletes these cookies, some parts of the Site may not work properly.
By clicking on a link to a third-party website or service on the Site, a third party may also transmit cookies to User. This PP does not cover the use of cookies by any third parties, and Seemplicity is not responsible for such third parties’ privacy policies and practices.
Without derogating from the foregoing, please note that Seemplicity may use analytic tools such as Google Analytics. Please click on www.google.com/policies/privacy/partners/ in order to find out how Google Analytics collects and processes data.

SEEMPLICITY’S USE OF PERSONAL DATA.

SEEMPLICITY processes Subscriber’s Personal Data to operate, provide, and improve the Site, including but not limited to:
1. creating and managing Subscriber Accounts;
2. contacting Subscriber by Seemplicity and communicating with Subscriber with respect to the Site, e.g. by phone, email; responding inquiries from Subscriber;
3. informing Subscriber about updates or offers;
4. personalizing the Site, i.e. identifying Subscriber’s interests and recommending offers that might be of interest to Subscriber;
5. marketing and promoting the Site;
6. providing assistance and support;
7. fulfilling Subscriber requests; meeting contractual or legal obligations;
8. protecting Subscribers security, e.g. preventing and detecting fraud;
9. internal purposes, e.g. trouble shooting, data analysis, testing and statistical purposes.
Except as provided herein, Seemplicity does not use any Personal Data other than as necessary to provide the Site, without obtaining Subscriber’s prior consent.
Seemplicity may ask for Subscriber’s consent to use Subscriber’s Personal Data for a specific purpose which will be provided to Subscriber.
In case Subscriber’s Personal Data contains third party personal data, Subscriber represents and warrants that it has obtained any consent required under the PP to Seemplicity’s privacy practices set forth in the PP from such third party.

SHARING PERSONAL DATA OF SUBSCRIBER.

Seemplicity may be required to retain or disclose personal information in order to:
1. comply with applicable laws or regulations;
2. comply with a court order, subpoena or other legal process;
3. respond to a lawful request by a government authority, law enforcement agency or similar government body (whether situated in Subscriber’s jurisdiction or elsewhere);
4. engage with third-party service providers and/or sub-contractors which provide services for Seemplicity’s business operations, a list of which can be received upon request;
5. disclose to third parties aggregated or de-identified information about Subscribers for marketing, advertising, research, or other purposes;
6. disclose and/or transfer data to another entity if Seemplicity is acquired by or merged with another Seemplicity, if Seemplicity sells or transfer a business unit or assets to another Seemplicity, as part of a bankruptcy proceeding, or as part of any other similar business transfer;
7. Seemplicity believes release is appropriate to comply with the law, enforce or apply Seemplicity’s terms and other agreements, or protect the rights, property, or security of Seemplicity, Subscribers, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
When Seemplicity shares Subscriber’s data with third parties as specified above, Seemplicity makes reasonable efforts to require such recipients to agree to only use the personal data Seemplicity shares with them in accordance with this Privacy Policy and Seemplicity’s contractual specifications and for no other purpose than those determined by Seemplicity in line with this PP.

Direct Marketing and Advertisement.

Seemplicity may provide Subscribers with direct marketing, as such term is defined in the Israeli Privacy Protection Law, 1981.
Seemplicity may also send Subscribers advertisements, as such term is defined in the Israeli Media Law (Bezeq and Broadcasting), 1982.
Subscriber can opt out of receiving these direct marketing and/or advertisements from Seemplicity at any time by unsubscribing using the unsubscribe link within each communication, or emailing Seemplicity at unsubscribe@seemplicity.io to have Subscriber’s contact information removed from Seemplicity ‘s email list.

SECURITY.

Seemplicity has taken appropriate technical and organisational measures to protect the information Seemplicity collects about Subscriber from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. Subscriber should be aware, however, that no data security measures can guarantee 100% security.

SUBSCRIBERS IN THE EUROPEAN ECONOMIC AREA (EEA).

Legal Basis for Processing of Personal Data

Seemplicity will only process Subscriber’s Personal Data if it has one or more of the following legal bases for doing so:

Contractual Necessity: processing of Personal Data is necessary to enter into a contract with Subscriber, to perform Seemplicity ‘s contractual obligations to Subscriber under the TOU, to provide the Site, to respond to requests from Subscriber, or to provide Subscriber with customer support;
Legitimate Interest: Seemplicity has a legitimate interest to process Subscriber’s Personal Data;
Legal Obligation: processing of Subscriber’s Personal Data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
Consent: processing of Subscriber’s Personal Data with Subscriber’s consent.

Subscriber’s Rights regarding Personal Data
1. Subject to applicable law, Subscriber has certain rights with respect to Subscriber’s Personal Data, including the following:
  1. 9.2.1.1.Subscriber may ask whether Seemplicity holds Personal Data about Subscriber and request copies of such Personal Data and information about how it is processed;
  2. 9.2.1.2.Subscriber may request that inaccurate Personal Data is corrected;
  3. 9.2.1.3.Subscriber may request the deletion of certain Personal Data;
  4. 9.2.1.4.Subscriber may request Seemplicity to cease or restrict the processing of Personal Data where the processing is inappropriate;
  5. 9.2.1.5.When Subscriber consents to processing Subscriber’s Personal Data for a specified purpose by Seemplicity, Subscriber may withdraw Subscriber’s consent at any time, and Seemplicity will stop any further processing of Subscriber’s data for that purpose.
2. In certain circumstances, Seemplicity may not be able to fully comply with Subscriber’s request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, Seemplicity will still respond to notify Subscriber of such a decision.
3. Subscriber can exercise Subscriber’s rights of access, rectification, erasure, restriction, objection, and data portability by contacting Seemplicity at privacy@seemplicity.io. In some cases, Seemplicity may need Subscriber to provide Seemplicity with additional information, which may include Personal Data, if necessary to verify Subscriber’s identity and the nature of Subscriber’s request.
Transfer of Subscriber’s Personal Data outside of the EEA

Seemplicity currently stores Personal Data of EEA citizens in datacenters in Frankfurt, Germany, and does not transfer such Personal Data outside the EEA.

SUBSCRIBERS IN CALIFORNIA, USA.

To CCPA is applicable the following shall apply:

10.1.Seemplicity will only process Personal Data on Subscriber’s behalf.
10.2.Seemplicity will (i) not collect, retain, use, or disclose Personal Data for any purpose other than for the specific purposes set out in the Privacy Policy, or any other agreement between Seemplicity and Subscriber; (ii) not sell Personal Information (as defined under the CCPA); and (iii) put in place appropriate technical and organizational measures to protect Personal Data against unauthorized or unlawful processing or accidental destruction, loss or damage.

INTERNATIONAL STORAGE.

Each Subscriber is advised to be aware that personal data Seemplicity collects may be transferred to, processed and stored outside Subscriber’s jurisdiction, and that data protection laws in the jurisdiction where the information is collected stored and/or processed may differ from Subscriber’s jurisdiction. Each Subscriber hereby gives Subscriber’s consent to this transfer, processing and storage of Subscriber’s information outside its jurisdiction.

PERSONAL DATA OF CHILDREN

The Site is not intended for children. Children under 18 years of age, may use the Site only with the involvement of a parent or guardian.

QUESTIONS REGARDING SUBSCRIBER’S PERSONAL DATA?

If Subscriber has any questions about this Privacy Policy or Seemplicity’s data practices in general, please contact us using the following information:

Email: privacy@seemplicity.io

Last update: March 13, 2022