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Cloozz Ltd. – Website Privacy Policy

Cloozz Ltd. – Website Privacy Policy

Cloozz Ltd. (referred to as the “Company”, “we”, “us” or “our” in this Privacy Policy) respects your privacy and is committed to protecting your Personal Data. “Personal Data” means any information about an individual from which that person can be identified. 

This Privacy Policy (“Privacy Policy”) is designed to inform you as to how we handle your Personal Data in connection with your visit to our website https://www.cloozz.com   (“Website”) and notify you about your privacy rights and how the law protects such rights. Capitalized terms used but not otherwise defined in this Privacy Policy shall have the meanings ascribed to such terms in the Terms of Use.

To the extent that the European General Data Protection Regulation (“GDPR”) or the United Kingdom General Data Protection Regulation (“UK GDPR”) apply to Personal Data that we process in accordance with this Privacy Policy, we usually act as a “data controller” with respect to such processing. 

We encourage you to read this Privacy Policy carefully and to regularly check this page to review any changes we might make to the terms of this Privacy Policy. This Privacy Policy supplements other policies we may provide as part of our interactions with you or policies you may have received from other controllers and is not intended to override such policies. 

 

1. The Data We Collect About You 

When you use our Website or contact us through it, we may collect the following types of Personal Data on you:

  • Identity Data includes your first and last name. 
  • Contact Data includes your email address and telephone number. 
  • Business Data includes your company name, industry and position. 
  • Location Data includes the country/region from which you access the Website. 
  • Usage Data includes information about how you use or interact with our Website (such as, when you entered the Website, how long you stayed on the Website and/or a specific page on the Website). 
  • Technical Data includes information on your internet connection (such as your IP address and internet service provider name), on the device and software that you are using to access the Website (e.g., your web browser type and computer operating system). 
  • Additional Inquiry Data includes additional information that you may provide when you contact us through the Website or when you sign up for any of our services.

We also collect, use and share aggregated data such as statistical data for any purpose. Such information does not reveal your identity and therefore is not considered Personal Data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature available through the Website.

Protecting the Privacy Rights of Third Parties

If you provide us any Personal Data relating to others, you must make sure that you have permission to do so. 

 

2. How We Collect Your Personal Data 

 We use different methods to collect data from and about you including through: 

  • Direct interactions. When use the Website, contact us through our website, register to our newsletter, or otherwise provide your Personal Data directly to us, you will be asked to provide us with your Identity Data, Contact Data, Business Data and/or Location Data so that we can provide our services to you, respond to your questions or requests or otherwise contact you. You may also provide Additional Inquiry Data in such instances. 
  • Automated technologies or interactions. As you interact with our Website, we automatically collect the applicable Technical Data and Usage Data. We collect this data by using cookies, server logs, and other similar technologies. 
  • Third parties or publicly available sources. We may receive Technical Data and Usage Data about you from third parties, such as Usage Data and Technical Data that we may receive from analytics providers, and from advertising and marketing partners. 

You are not legally obligated to provide any Personal Data to Cloozz. Any Personal Data that you choose to provide to Cloozz, is provided at your own free will.

 

3. How We Use Your Personal Data   

We will only use your Personal Data when permitted by law. We will commonly use your Personal Data in the following circumstances:

  • Where the processing is necessary in connection with the performance of any contract we have entered into with you or where it is necessary for taking steps at your request prior to entering a contract.  
  • Where the processing is necessary for our legitimate interests (or those of a third party), and such legitimate interests are not overridden by your interests, fundamental rights, or freedoms. Legitimate interest means our interest in managing and conducting our business. 
  • Where the processing is necessary for compliance with a legal or regulatory obligation.
  • Where you have provided your consent for such processing. Such consent can be revoked at any time. 

Purposes for Which We Use Your Personal Data  

Below is a description of the ways we use your Personal Data. To the extent that the GDPR and/or UK GDPR apply, we have mentioned the legal bases we rely on to use your Personal Data, and identified what our legitimate interests are where appropriate:

  • We use your Identity Data, Contact Data, Business Data and/or Location Data to enter into a contract or to perform a contract with you. We also use your Usage Data and Technical Data for the performance of a contract with you (to provide our services to you via the Website).
  • We use your Contact Data and Additional Inquiry Data to respond to your requests or questions and to manage our relationship with you, including by notifying you about changes to our terms of use or Privacy Policy. We do so for the performance of a contract with you, if it is necessary to comply with a legal obligation or if it is necessary for our legitimate interests.
  • We use your Usage Data, Technical Data, Location Data and Contact Data for marketing purposes, to deliver relevant and personalized content to you, send service messages (for example, for security purposes) and to measure or understand the effectiveness of our marketing efforts. We do so where it is necessary for our legitimate interests (to grow our business, to inform our marketing strategy and to maintain and secure the services); or if we have obtained your prior consent (where laws require consent for such communications). 
  • We use your Usage Data and Technical Data to improve our Website, services, marketing, customer relationships and experiences, including by personalizing and customizing our content. We do so where it is necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).
  • In the event of a legal dispute between you (and/or a party on your behalf) to us (and/or a party on our behalf), we may use your Personal Data to the extent necessary in connection with handling such dispute. We do so where it is necessary for our legitimate interests (to defend and enforce our legal rights).
  • We may also use your Personal Data as: (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms of use, to maintain security of the Website and prevent fraudulent or illegal activity; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates. We do so based on our legitimate interest (to defend and enforce our legal rights and to protect and ensure the continuous operation of our Website).

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. 

Promotional Offers 

You may receive marketing communications from us if you have requested information from us and you have not opted out of receiving marketing communications. 

You can change your contact preferences at any time through your account or by sending us an email with your request to: help@cloozz.com. If you wish to stop receiving marketing communications from us, you may ask us to stop sending you marketing communications at any time by following the opt-out link on any marketing message sent to you or by contacting us.

Cookies and Other Tracking Technologies 

We automatically collect Personal Data through cookies and similar technologies when you interact with our Website. For additional information on how we use such technologies, please read our cookies policy, available here. 

In addition, our website may use Google Analytics (or similar service providers) to collect information about the use of our Website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our Website, what pages they visit, and what other websites they have used before coming to our Website. We use the information we get from Google Analytics to analyze traffic, remarket our products and services to users, improve our marketing, advertising, and to improve our Website. We have enabled Google Analytics advertising features such as remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. For more information on how Google collects and processes your data, visit https://www.google.com/policies/privacy/partners/ . Google provides website visitors the ability to prevent their data from being used by Google Analytics. For more information see: https://tools.google.com/dlpage/gaoptout 

We may also use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors. 

Third parties may use cookies, web beacons, and other storage technologies to collect or receive information from our Website and elsewhere on the internet, and use that information to provide measurement services and target ads. 

Third-Party Links 

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or interacting with such content may allow your data to be shared with the relevant third-party. We do not control these third-party websites and are not responsible for their privacy statements; we therefore recommend that you read the privacy policy of every websites you visit.

 

4. Sharing Your Personal Data with Third Parties

We share Personal Data with third party service providers that provide us services in connection with the purposes listed above. 

For example, we may share your applicable Identity Data, Contact Data, Usage Data and Technical Data with web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Website. For additional information, please see the description above in the section titled Cookies and Other Tracking Technologies. 

We may also share your Personal Data with legal and regulatory authorities to the extent required by applicable law our professional advisors (e.g. lawyers, accountants) to the extent necessary for the provision of their services to us; and third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire. 

 

5. Minors

In order to use the Website, you must be at least 18 years of age or older, if otherwise required by the laws of the country you reside in. Our Website is not designed for use by anyone under the age of 18 and we do not knowingly collect Personal Data from children under the age of 18.

If you are a parent or legal guardian and have concerns about your child’s privacy, or if you believe that your child may have provided us with their Personal Data, please contact us using the Contact Details below. When you approach us as a parent or legal guardian, we may request that you provide certain information needed to confirm your identity, in order to prevent malicious removal of account information. 

 

6. International Transfers  

We may transfer your Personal Data to countries outside of the country in which you reside (including outside of the European Economic Area (EEA) or the United Kingdom (UK)), that do not necessarily provide the same level of data protection as the country in which you reside and are not recognized by the European Commission and/or the applicable UK authority as providing an adequate level of data protection.

Our international transfers of Personal Data are done for the performance of a contract or implementation of pre-contractual relations with you, based on your consent, or subject to safeguards that ensure the protection of your Personal Data, such as standard contractual clauses approved by the European Commission and/or the applicable UK authority (when the transfer is outside of the EEA or the UK).

 

7. Data Security  

We have put in place security measures intended to prevent your Personal Data from accidental or unlawful loss, use, alteration or disclosure. We also maintain reasonable technical and physical safeguards to protect your Personal Data. Unfortunately, we cannot guarantee against the loss or misuse of your Personal Data or secure data transmission over the Internet because of its nature.

 

8. Data Retention 

We retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for legal or reporting requirements. 

In order to determine the appropriate retention period for Personal Data, we consider the following criteria: the volume, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Personal Data, the purposes for which we collect and process Personal Data, the timeframe during which we may require such Personal Data in connection with potential litigation, and applicable legal requirements.

 

9. Your Rights

Certain privacy laws, including the GDPR and UK GDPR, provide users with rights related to their Personal Data. To the extent that such laws apply to your Personal Data, you may have the following rights:

  • Request access. This means that you may receive a copy of the Personal Data we hold about you.
  • Request correction. This means that you may ask us to correct or complete inaccurate or incomplete data that we hold about you. 
  • Request erasure. This means that you may ask us to delete or remove Personal Data that we hold about you. If we are unable to comply with such request, we will notify you of the specific legal reasons for our decision. 
  • Object to processing. This means that you may object to the processing of your Personal Data where it is used for direct marketing purposes, or where we are relying on a legitimate interest and you feel that such interest is overridden by your rights and freedoms.
  • Request restriction of processing. This means that you may ask us to suspend the processing of your Personal Data if you believe that such data is inaccurate, if our processing is unlawful or if we no longer need to process such data for a particular purpose, but you need us to continue to hold the data.
  • Data Portability. This means that you may request that we transfer your Personal Data to you or to a third party. This right applies where we have obtained and processed the data from you based on your consent or where we used the information to perform a contract with you.
  • Withdraw consent at any time. This means that you may withdraw your consent where we are processing your Personal Data based on your consent.

If you wish to exercise any of the rights set out above, please contact us help@cloozz.com. 

What We May Need From You  

When you approach us with a request to exercise one of your rights, we may request that you provide us with information needed to confirm your identity as a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it. 

Time Limit to Respond  

We try to respond to all legitimate requests within one month or less, if required by law. Where it takes us more than one month to respond (for example, where your request is particularly complicated or where you have made a number of requests) we will notify you and keep you updated.

 

10. Accessibility

If you have a disability and would like to access this policy in an alternative format, please contact us via our Contact Details listed below.

 

11. Contact Details  

If you have any questions or concerns, please contact us at: 

Email: help@cloozz.com 

Postal address: ‎7 Rival St., Tel Aviv, Israel 

You have the right to make a complaint at any time to data protection authorities. We would, however, appreciate the chance to address your concerns before you approach a data protection authority, so please contact us in the first instance.

 

12. Changes to this Privacy Policy 

We reserve the right to change this Privacy Policy at any time. If we do so, we will post an updated version of this Privacy Policy so that our users and customers are always aware of what information we collect, use, and disclose. Your continued use of our Website and services after any change to this Privacy Policy will constitute your acceptance of such change.

 

This version was last updated on January 25th, 2024.