Last update: January 20, 2022

Introduction

Carbyne Ltd. and its affiliates (“us”, “we”, “our” or “Company”) respect your privacy and are committed to protecting the privacy of your personal information.  With this in mind, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of personal information you provide to us, including personal information you submit to us on our website or personal information we receive when you access online services we provide (collectively: the “Services”). Personal information is information that can be used to identify an individual either directly or indirectly.

This Privacy Policy outlines our practices with respect to collecting, using and disclosing your personal information.  

If you (or your parent(s)/guardian(s), if applicable) do not agree with this Privacy Policy, please do not supply any personal information.

Collection and Use of Information

We may use your personal information to 1) provide and improve the Services and to administer your use of the Services; 2) run our business, such as to perform our contract obligations and to comply with legal and regulatory requirements; and 3) grow our business, such as marketing to our business contacts. We may collect the following information from you in the following circumstances:

Account Information:

When you sign-up and register to the Services, you will be asked to provide us with certain details about yourself: phone number, first and last name, home and work address, e-mail, age, gender. If you are under 16, we will also ask you for your parent’s/guardian’s contact details (e.g., email address or telephone number), so we can contact them and obtain their consent to collect your personal information. 

Information collected if you register through social network account: 

When you register or sign-in to the Services via your social network account (e.g., Facebook), we have access to basic information from your social network account, such as your full name, email address, birthdate, profile picture, friends list, as well as any other information you made publicly available on such account or agreed to share with us. 

Voluntarily provided Information: 

We may collect information which you provide us voluntarily. For instance, when you communicate with us via email, through our website, or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports which you send to us. If we receive complaints about you, these complaints may include your personal information. 

Information Sent by Your Mobile Device:

We collect certain information that your mobile device sends, like a unique identifier (e.g., MAC address), geolocation data, IP address, user settings, and the operating system of your device, as well as information about your use of the Services.

Background Mode Information: 

When you call an emergency service our Services may collect and process your location data and video to provide them to the emergency call center. You agree that we may access this data to provide it to the emergency service when you call an emergency service directly through your device’s dialer and/or contacts app.

Information Related to Use of the Services: 

Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), whether or not you submit a Request. Log Data may include information such as the type of device you use, the type of browser and operating system your device uses, language preference, access time and the website’s domain name from which you linked to the Services. We use Log Data which has been anonymized and aggregated to administer and enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, etc.).

Information Collected Using Cookies and other Web Technologies:

Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.

“Cookies” are small text files that are placed on your hard drive by a Web server when you access our website. We may use both session Cookies and persistent Cookies to identify that you have logged in to the website and to tell us how and when you interact with our website. We may also use Cookies to monitor aggregate usage and web traffic routing on our website and to customize and improve our website. Unlike persistent Cookies, session Cookies are deleted when you log off from the website and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the website. Some third-party service providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.

“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our website for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our website, to monitor how many visitors view our website, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

Mobile analysis:

We may use various tracking technologies or methods of web and mobile analysis (e.g., Mixpanel, etc.) to gather, store, and track certain personal information related with your access to and activity through the Services. This collection of personal information may be based on your consent, where required, and/or our legitimate interest to provide best quality service and experience to our customers, and to personalize our Services.

Information that We Share with Third Parties

We will not rent, sell, or share any personal information that we have collected from or regarding you except as described below:

Sharing Aggregated, Anonymized, Deidentified, or Otherwise Non-Personal Data

We may share personal data that has been aggregated, deidentified, or otherwise anonymized and thus does not directly or indirectly identify individuals and that cannot, with reasonable efforts, resources, and technologies, be used to reidentify any individual.  Such aggregated, anonymized, deidentified, or otherwise not re-identifiable information is not personal data within the scope of this Privacy Policy or applicable privacy laws.

Information Shared with Our Service Providers and affiliates:

We may engage external auditors or advisors and other third-party services providers to work with us to administer and provide the website and/or Services and to respond to your requests. We also share such information with our subsidiaries and affiliates. These third-party service providers have access to your personal information only for the purpose of performing services on our behalf. 

Information Disclosed in Connection with Business Transactions:

We may disclose information about customers and prospective customers to a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any of our business, assets, or stock, including in connection with bankruptcy or similar proceedings. 

Information Disclosed for Our Protection and the Protection of Others:

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

Additional Disclosures:

In addition to the purposes listed in this Privacy Policy, we may share personal information with our third parties (such as our providers and contractors) for any of the following purposes: (i) storing or processing personal information on our behalf (e.g., cloud computing service providers); (ii) processing such information to assist us with our business operations; (iii) performing research, technical diagnostics, personalization and analytics; (iv) providing you with the emergency services available through our Services.

For the purposes described above, we may transfer your personal information outside the European Union or the Economic Area, provided that:

The data transfer is carried out to country whose legal regime is deemed by the European Commission to provide for an “adequate” level of personal data protection; and/or

The data transfer is governed by a valid mechanism recognized as such by the European Commission (e.g. Standard Contractual Clause).

We may also disclose personal information or any information you submitted to us (such as via our website or the Services) if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our customers, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

The Security of Your Information

We take great care in implementing and maintaining the security of the Services and your personal information. We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your personal information) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Links to Other Sites

Our website may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We are not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

International Transfer

Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your personal information to us, we may transfer your personal information to the United States and process it there.

Children’s Privacy

We do not sell or offer our Services to children. As such, our Services are designed for adult user interaction. We do not intentionally collect personal information from children under the age of 16. If you are under 16, we require the written consent of your parent(s)/guardian(s) before we collect any of your personal information or offer you the Services.

Data Retention

We respect your privacy rights and therefore you may contact us at any time and request: (i) to access, delete, change or update any personal information relating to you (for example, if you believe that your personal information is incorrect, you may ask to have it corrected or deleted); or (ii) that we will cease any further use of your personal information (for example, you may ask that we will stop using or sharing your personal information with third-parties) or that we shall remove your personal information (subject to any other legal obligation that may require us to keep the information).

Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

If you wish to raise a complaint on how we have handled your personal information, please contact us directly at [email protected].

If you are not satisfied with our response or believe we are collecting or processing your personal information not in accordance with the laws, you can complain to the applicable data protection authority.

Rights of California Residents

Scope of this Privacy Notice

This privacy notice describes the Personal Information we collect or process about California residents in connection with the Services, how we use, share, and protect that personal information, and what your rights are concerning Personal Information that we collect or process.

In this Rights of California Residents section of this Privacy Policy, “Personal Information” has the same meaning as under the California Consumer Privacy Act (CCPA), California Civil Code Section 1798.83 (which is amended by the California Privacy Rights Act (CPRA)): information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include information that has been de-identified or aggregated.

Personal Information We Collect and Share, and For What Purpose

In the past 12 months, we have collected and shared Personal Information from visitors in the following circumstances when they interact with the Services, as described in detail above:

– Account Information

– Information collected if you register through social network account

– Information collected when you use our Services 

– Voluntarily provided Information 

– Information Sent by Your Mobile Device

– Background Mode Information

– Information Related to Use of the Services

– Information Collected Using Cookies and other Web Technologies

– Mobile analysis

As described in detail above, we use your Personal Information for a variety of purposes to operate, assess activity on, and improve the performance of the Services, including the following:

– To administer and provide the Services

– For research and development

– To communicate with you about the Services

– To market, promote, and drive engagement with the Services

– For Customer support

– For safety and security

– To protect our legitimate business interests and legal rights

Except as described in detail above, we will not share with third parties information about you without your consent.

We do not share your Personal Information with third parties for third party marketing purposes.

Your Rights as a California Resident

Under California law, users who are California residents have specific rights regarding their Personal Information. These rights are subject to certain exceptions described below. When required, we will respond to most requests within 45 days unless it is reasonably necessary to extend the response time.

Right to Disclosure of Information

You have the right to request that we disclose certain information regarding our practices with respect to Personal Information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

– The categories of Personal Information we have collected about you in the last 12 months.

– The categories of sources for the Personal Information we have collected about you in the last 12 months.

– Our business or commercial purpose for collecting that Personal Information.

– The categories of third parties with whom we share that Personal Information.

– The specific pieces of Personal Information we collected about you.

– If we disclosed your Personal Information to a third party for a business purpose, a list of the Personal Information types that each category of recipient received.

Right to Delete Personal Information

You have the right to request that we delete any of your Personal Information collected from you and retained, subject to certain exceptions. Upon receiving a verified request to delete your Personal Information, we will do so unless otherwise authorized by law.

How to Exercise these Rights

You may submit a verifiable consumer request to us for disclosure or deletion of Personal Information by emailing [email protected].

We will respond to verifiable requests for disclosure or deletion of Personal Information free of charge, within 10 days of receipt.

In order to protect your privacy and the security of your information, we may request additional information to verify consumer requests. Any additional information you provide will be used only to verify your identity and not for any other purpose. 

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney under Probate Code sections 4000-4465 may submit a request on your behalf.

Right to Opt Out of Sales of Your Personal Information

You have a right to opt-out of the sale of your Personal Information. You may, at any time, direct businesses that sell your Personal Information to third parties not to sell your Personal Information.

We do not sell your Personal Information and therefore do not provide any mechanism for you to exercise the right to opt out. 

Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above.

European Union Rights

In accordance with the General Data Protection Regulation (“GDPR”), you have the following rights regarding the processing of your Personal Information. These rights may be limited or restricted pursuant to applicable laws and regulations, in which case we will inform you of these limitations or restrictions. “Personal Information” as used in this European Union Rights section has the same meaning as that ascribed to “Personal Data” under Art. 4 of GPDR.

You may exercise these rights by contacting us (see section “How to contact us” below).

These rights being purely personal, they may only be exercised by you. Please attach a copy of a valid ID document to your request; we will only retain that copy for the time necessary to verify your identity.

Right of access

You may request access to your Personal Information that is processed by us. In this case, we will provide you with a copy of Personal Information we have relating to you, as well as with all mandatory information regarding processing of this Personal Information, namely:

– The categories of collected and processed Personal Information;

– The purposes of processing;

– The categories of data recipients;

– The data retention period(s);

– Information regarding your rights as data subject.

Right to data portability

For those of the processing activities described above which are based on your consent or on their necessity for performance of a contract to which you are a party, you also have a right to data portability.

This right differs from the right of access in that (i) it only covers Personal Information we collected from you and (ii) it allows you to obtain a copy of your Personal Information in a structured, machine-readable format.

The right to data portability also allows you to request transmission of such Personal Information to another data controller, at your own choice, to the extent that it is technically feasible.

Right to rectification

You have a right to request the rectification of your Personal Information, provided that such Personal Information is inaccurate, incomplete or outdated.

Right to erasure

You may request erasure of your Personal Information from us and our processors’ servers and files in the following cases:

– In case your Personal Information is no longer necessary for the purposes for which it has been collected and processed;

– In case you have withdrawn your consent (if consent was legally required) and there is no other legal basis for the processing;

– In case you have objected to the processing of your Personal Information (see section “Right to object to processing” below);

– In case the processing of your Personal Information is illicit;

– In case your Personal Information must be erased by us in order to comply with our legal obligations;

– In case you were a minor at the time of collection of your Personal Information through our Services.

If your Personal Information has been shared with third parties, we shall inform these third parties of your request for erasure, to the extent that it is feasible.

Right to object to processing

For those of the processing activities which are based either on:

– out or a third party’s legitimate interest, or

– performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller,

You have a right to object to such processing on grounds relating to your particular situation.

You also have an unconditional right to object to any processing activities which purpose is direct marketing.

Right to limitation of processing

You may request limitation of processing of your Personal Information in the following cases:

– In case you request rectification of your Personal Information, for the duration necessary to check that Personal Information;

– In case processing is illicit and you prefer to limit it rather than erasing the concerned Personal Information;

– In case you want us to retain your Personal Information in order for you to use it in the context of a judicial claim; or

– In case you have objected to the processing of your Personal Information by us, for the period necessary for us to assess the grounds relating to your particular situation.

We will in such case cease to process the concerned Personal Information and retain them for the appropriate duration.

Right to provide instructions relating to the use of your Personal Information after your death

If you are a French resident, you have a right to provide us with instructions relating to retention, erasure or communication of your Personal Information after your death.

Right to withdraw consent

For those of the processing activities which are based on your consent, you have a right to withdraw such consent at any time, without justification.

Right to lodge a complaint with a supervisory authority

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at [email protected]. If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you have a right to lodge a complaint relating to the processing of your Personal Information by the Company with the competent supervisory authority in your country.

Revisions to this Privacy Policy

Any information that is collected via our website is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on our website or by sending you an email or other notification. 

How to contact us

If you have any general questions regarding the Services or the information that we collect about you and how we use it, and for any request regarding your rights, please contact us at [email protected].

For any question relating to the emergency services available through our Services, or if you wish to contact the body, authority, service or other entity providing the emergency services, please directly contact such body, authority, service or other entity.

Information about us

You can find the addresses of our offices here.