This Privacy Policy (“Privacy Policy”), is an integral part of our Terms of Service (“Terms”), and governs the processing and transfer of personal data collected or processed by Datomize Ltd. (“Company“, “we”, “us” or “our”) in connection with our website and our Services. 

Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms. 

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

In the event you are a California resident and the CCPA applies to you – please also review our CCPA Privacy Notice.

Applicability

This Privacy Policy explains Company’s data collection practices that are applicable toward: (i) any visitor of our website (“Visitor”); (ii) any entity which uses the Services and their users (i.e., their employees) (“Customer“); Customers and Visitors will be jointly referred to as “you” or “your“. 

The highlights

• You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. 
• You may not share Personal Data about other people with us which you are not authorized to share or use.
• You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data.
• If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please send us an email to: dpo@newsite.datomize.com

Information processed by the company

We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from which we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your action in the website or Services (such as session duration and page impressions), or approximate geo-location. 

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”). 

For avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

We are considered as the “Data Controller” of the Personal Data we collect from our Visitors and Customers. As with respect to Customer’s Personal Data we collect regarding we act as a “Data Processor” as further detailed below.

We do not knowingly collect or process any Special Categories of Personal Data, however our Customer’s might upload or provide us with access to such.  Special Categories of Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data” or “Sensitive Data”). Moreover, in connection with Customers’ use of the Services, we do not monitor the data uploaded to our Services, therefore it is the Customer’s responsibility to ensure that if Sensitive Data is transmitted or uploaded to the Services it is done in compliance with applicable Data Protection Law. 

Information We Collect

• Name and email address: As a Customer we will send you email marketing materials regarding the Services you are currently using or any services we may offer in the future (“Direct Marketing”). 
• Contact us: In the event you choose to contact us in order to ask any question you will be requested to provide your name, phone number, email address, your company and free text.
• Demo: In the event you choose use our demo of the services you will be requested to provide your name, phone number Company’s name and email address.
• Commercial materials and newsletters: If you sign up to receive our newsletter or other marketing materials, you will be requested to provide your email address.
• Career: In the event you apply for a job via our website, we will collect your CVs and additional information such as your contact details.
• Online identifier: When you access our website, we may, either directly or indirectly (through our third-party service providers) collect your Mac and IP address. We may collect technical Non-Personal Data from you when you access our website as well, as explained below. 
• Technical data: We also collect certain technical Non-Personal Information   which relates to your use of the Website such as: device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting the full Uniform Resource Locators (URL) clickstream to, though, and from our website (including date and time), content you viewed or searched for, page response times, download errors, and page interaction information (such as scrolling, clicks, and mouse-overs);

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on out legitimate interests.

How we collect the information

Depending on the nature of your interaction with the website and Services, we may collect information as follows:

• Automatically – we may use cookies (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our website.
• Provided by you voluntarily – we will collect information if and when you choose to provide us with the information.

Sharing personal data

We may share Personal Data only under the following limited circumstances:

• With trusted partners and third parties who assist us in operating the Services and conducting our business. 
• With our affiliates and connected companies, such as subsidiaries, sister-companies and parent companies. [Note to Company: please approve this is applicable to you]
• With third parties if necessary to comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
• Other third parties with your consent to do so.

In addition, we may share Non-Personal Data aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users.

USER RIGHTS

Privacy laws in different jurisdictions provide different rights regarding your Personal Data, such as the right to access your Personal Data; the right to delete Personal Data; the right to opt-out from Personal Data processing, and so on. 

Principally, if you are a resident of the European Economic Area (“EEA“) or California state, the provisions of the GDPR and the CCPA, respectively, provide you with the following rights: 

• The right to be informed: in order to ensure fair and transparent processing of Personal Data, you have the right to be provided with information regarding how we collect collection and our privacy practices, as detailed herein. 
• The right to access data: you have the right to request a confirmation from us that we process your Personal Data, and under certain circumstances, be provided with a copy of the Personal Data we process. 
• The right to request deletion of you Personal Data: you have the right to require us to delete certain Personal Data, if certain conditions are satisfied (if the personal data is no longer needed for the original purpose it was collected for and there is no new lawful basis for continued processing; if you have exercised your right to withdrawn consent (to the extent applicable), or to object to the processing and we have no overriding grounds for the continued processing; the personal data is processed unlawfully; or erasure of personal data is necessary to comply with applicable legislation. Please note, this right is not absolute. We may reject your request under certain circumstances, including where we have to retain the data in order to comply with legal obligations or defend against legal claims, etc. 
• The right to object: you have the right to object the processing of Personal Data, in the event the basis for our processing activity is based on our legitimate interests, however, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise or defend a legal claim or right, etc.
• The right to restrict processing: you may ask us to restrict the processing your Personal Data, when: the accuracy of the data is contested; processing is unlawful and you requests restriction instead of erasure; the Personal Data is no longer needed for the original purpose it was collected, however the retention of data is still required to establish, exercise or defend legal rights; or is there are overriding grounds in the context of an erasure request. 
• Rectification (in the event you are an EEA resident): you have the right to require updating or amending Personal Data which is not correct.
• Portability: you have the right to have your Personal Data “port” to a third-party, subject that: the Personal Data was provided by you; the Personal Data is processed automatically; and the Personal Data was processed on the legal bases of contract or consent;
• The Right to Non-Discrimination (in the event you are a California resident): you have the right not to be discriminated against for having exercised your rights under the applicable laws. In particular, we cannot not: deny the consumer goods or service, charge the consumer different prices for goods or services, whether through denying benefits or imposing penalties provide the consumer with a different level or quality of goods or services to the consumer.

We provide you with the option to exercise certain choices and controls in connection with our treatment of your Personal Data, depending on your relationship with us. If you wish to exercise any or all of the above rights, please download our applicable form and send it to our privacy team at: dpo@newsite.datomize.com

Where we are not able to provide you with the information or exercise the rights for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are EEA resident). We reserve the right to ask for reasonable evidence to verify your identity prior to providing you with any such information in accordance with applicable law.

Data retention

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

Security

We take great care in implementing and maintaining the security of our website, our Services and your information. We have implemented technical, physical and administrative security measures to protect the Personal Data. In addition, we limit access to your information on our servers. The data collected by us is stored in (i) AWS (ii) WalkMe; (iii) HubSpot data servers, for more information regarding the data security provided by AWS, please see their Privacy Policy in the applicable links: (i) AWS (ii) WalkMe (iii) Hubspot.  

Transfer of Data

We use Amazon Cloud to store our data which are located in the EU and US. Further certain processing activities are conducted in Israel. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data an adequate level of data protection when it is being transferred as required under applicable law. 

Children

Our website and Services are intended for the general audience, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. 

We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.

If you are a Customer, please be aware that you may not upload to the Services any data concerning persons under the age of 16, and you may not send emails to users who are under 16 years old. Doing any of the above constitutes an infringement of our Terms and may result in the suspension or Termination of the User’s Account.  

Changes and updates

The terms of this Privacy Policy will govern the use of the website, the Services and any information collected therein. Company reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently. In the event of any substantial change of this policy, we will make reasonable efforts to post a clear notice on the w website. Such substantial changes will take effect seven (7) days after such notice was provided on the Company Services or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Services after the Last Updated date will constitute acceptance of, and agreement to be bound by, those changes. 

Data protection officer

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@newsite.datomize.com. Please include your name, address, email address and applicable DSR form, in any correspondence so that we can respond to your inquiry or request.

Contact us

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at:

Datomize, Ltd,

dpo@newsite.datomize.com

By accessing or using the Website or Services you acknowledge that you have read and understood these Terms. You agree to be bound and to fully comply with the Terms, you further agree to comply with all applicable laws and regulations regarding your use of the Services and you acknowledge that these Terms constitute a binding and enforceable legal contract between you and us.

You further represent and warrant that: (i) you are eligible to enter into these Terms, or, where applicable, you have all proper authorization to enter into these Terms; (iii) You are not defined as a “child”, “minor” or other similar term, in your jurisdiction and specifically you are not under the age of 16.

We respect our users’ privacy rights. Please review our Privacy Policy [Note: to be linked] prior to using the Services or accessing the Website.

The website & services

The Website provides information and resources about the Company’s business and other content related thereto, including, inter alia, contact information, images, text, logos, button icons, links, download files, other specialized content, documentation, data, and related graphics and other features (collectively, the “Content”). In addition, the Website provides you with communications means which you can use to contact us, e.g. if you have any question, if you wish to be provided with a demo, if you wish to join our team and be provided with the applicable information in this regard, or if you wish to receive notifications by email (the Website and Content shall be referred to collectively as the “Service(s)”).

The Website may include links to third parties’ websites and resources not operated or owned by us. By entering such third parties’ websites, you will be subject to their terms of services and privacy policies, thus we recommend that you carefully review the applicable terms and policies of such third parties. We have no control over third parties’ websites, and are not liable in any way for the actions of third parties.

THE CONTENT PUBLISHED ON THE WEBSITE IS PROVIDED FOR GENERAL INFORMATIONAL PURPOSES ONLY, AND MAY BE USED BY YOU AT YOUR SOLE RISK. WE EXPRESSLY DISCLAIM ALL LIABILITY IN RESPECT OF ACTIONS TAKEN OR NOT TAKEN BASED ON ANY CONTENT AVAILABLE ON THIS WEBSITE, WHICH ARE AT YOUR SOLE RESPONSIBILITY AND RISK.

Representation, warranties & restriction of use

You hereby represent and warrant the following: you shall not, nor shall you agree, authorize or encourage any third party to: (1) use the Services in non-compliant, unlawful, illegal, fraudulent or inappropriate manner; (2) circumvent, disable or otherwise interfere with security-related features of the Website and Service or prevent others from using the Services; (3) modify, create a derivative work of, reverse engineer, or disassemble the Service; (4) remove, deface, obscure, or alter the Website and Services or any Content therein including any copyright notices, trademarks, or other proprietary rights provided as part of the Service; (5) use the Services to promote, conduct, or contribute to fraudulent, illegal or otherwise inappropriate activities; (6) assert any proprietary rights in or to the Content nor remove, obscure or alter any notices of proprietary rights or disclaimers appearing in or on the Website and Content; (7) sublicense, resell, rent, lease, assign, transfer any right, share or otherwise commercially exploit or make the Services or the Content; (8) use, access or attempt to access the Services with any automated means (including robots, scrapers, etc.); (9) use our name, logo or trademarks without our prior written consent; (10) otherwise use the Website, Services or the Content in any unlawful manner, in  a breach of third parties’ rights or our rights, including intellectual property rights and privacy rights, or in breach of these Terms;

Intellectual property

The Service and Content are exclusively owned by the Company or its licensors. Except as explicitly provided herein, no license, right, title or interest to the Service and/or Content shall be granted to you, and we and/or our partners reserve any and all rights, title and ownership of the Service, Content and Website. You shall not use any Company’s copyrights, trademarks, trade names, or other Intellectual Property in any way except to the limited extent as may be expressly agreed in these Terms.

Disclaimer of warranties

Except as provided herein, the Website and Services are provided on an “as is” and “as available” basis, without warranties of any kind, express or implied, including, without limitation, representations, warranties and conditions of merchantability, fitness for a particular purpose, title, non-infringement, and those arising by statute or from a course of dealing or usage of trade, marketability, suitability, incompleteness, applicability or relevance of the Content. You agree that the Company will not be held responsible for any decision made or action taken or not taken in reliance on the Content nor do we assume any responsibility for any loss, injury or damages incurred as a result or in connection with such actions. We make no representation or warranties that the Services and Content are or will be available for use in any particular location or at specific time. Except as expressly stated herein, the Company does not make any representations, warranties or conditions of any kind, express or implied, as to the security of any information you may provide or activities you engage in during the course of your use of the Services. Your use of the Services is at your own risk and responsibility. Applicable law may not allow the exclusion of certain warranties, so to that extent certain exclusions set forth herein may not apply.

Limitation of liabilities

YOU ACKNOWLEDGE AND AGREE THAT TO THE FULLEST EXTENT PERMITTED BY LAW, THE COMPANY, INCLUDING, WITHOUT LIMITATION, ITS AFFILIATES AND THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS, COLLECTIVELY: “COMPANY’S GROUP”), AS WELL AS ITS VENDORS, DISTRIBUTORS, AND THIRD PARTY LICENSORS, SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR EXEMPLARY DAMAGES OR DAMAGES FOR LOST PROFITS, INTERRUPTION, LOSS OF DATA, LOSS OF GOODWILL, WORK STOPPAGE, DEVICE FAILURE, OR MALFUNCTION, OR DAMAGES ARISING OUT OF THE USE OR INABILITY TO USE THE WEBSITE OR SERVICES EVEN IF THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. FURTHER, WE WILL NOT BE LIABLE OR RESPONSIBLE FOR ANY FAILURE TO PERFORM, OR DELAY IN PERFORMANCE OF, ANY OF OUR OBLIGATIONS HEREIN THAT IS CAUSED BY AN EVENT OUTSIDE OUR CONTROL (WHICH MEANS ANY ACT OR EVENT BEYOND OUR REASONABLE CONTROL). IN NO EVENT SHALL THE COMPANY’S GROUP AGGREGATE LIABILITY FOR ANY CLAIM ARISING OUT OF OR RELATED TO THESE TERMS AND THE SERVICES, SHALL EXCEED $500 (US DOLLARS).

Indemnification

You agree to defend, indemnify and hold harmless the Company and its affiliates, and respective officers, directors, employees and agents from any third party claims, damages, liabilities and expenses (including reasonable attorney’s fees) arising from (i) your use of the Services does not comply with these Terms including negligence and wrongful act; (ii) abusing or infringing third party rights through the Services; and (iii) your breach of any applicable law, regulation and policies. This indemnification obligation will survive the termination or expiration of these Terms and the termination of your use of the Services.

Termination

You can terminate your use of the Services at any time. If you wish to terminate your use of the Services, you may do so simply by cease your use of the Website. We may change, modify, suspend, or discontinue any aspect of the Services at any time without notice to you and without any liability to you whatsoever in connection therewith.

Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of the State of Israel. You hereby agree to resolve any dispute you have exclusively with the competent court in Tel Aviv, Israel. Any cause of action you might have relating to the service is limited in time to one (1) year from the arising incident, and will be permanently barred afterwards.

Miscellaneous 

These Terms constitute the entire understanding between you and the Company with respect to the use of the Services. If any provision of these Terms is held to be unenforceable, such provision shall be reformed only to the extent necessary to make it enforceable and such decision shall not affect the enforceability of such provision under other circumstances, or of the remaining provisions hereof under all circumstances. Failure of the Company to enforce any rights or to take action against you in the event of any breach hereunder shall not be deemed as a waiver of such rights or of subsequent actions in the event of future breaches. These Terms and any right granted herein may not be assigned by you without the prior written consent of the Company. The Company may assign its rights and obligations set forth herein at any time, at its sole discretion. Your relationship with the Company is that of an independent contractor, and nothing in these Terms is intended to, or should be construed to, create a partnership, agency, joint venture or employment relationship.

Amendments

We reserve the right to periodically amend or revise the Terms at our sole discretion; such changes will be effective immediately upon the display of the revised Terms. The last revision date will be reflected in the “Last Updated” above. Your continued use of the Services following such amendments constitutes your acknowledgement and consent of such amendments to the Terms and your agreement to be bound by them. In the event of a material changes, we will make best efforts to provide written notification by applicable means of communication.

We use “cookies” (or similar tracking technologies) when you access the Site or interact with the Services we offer. This use is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes. You can find more information about cookies at: https://www.allaboutcookies.org/ and https://cookiepedia.co.uk./.

There are several types of cookies, the three main and common ones are:

• Essential, Functionality, Operation & Security Cookies – essential for enabling user movement around the Site, for the Site to function properly, and for security purposes. Please note that these cookies either cannot be disabled, or if disabled, certain features of the Services may not work.
• Analytic, Measurement & Performance Cookies – used to collect information about how users use the Site (clickstream, navigation, time and date of access, etc.) in order to improve our Services and the way we offer them, as well as assessing performance of the content available in the Site.
• Preference, Targeting & Advertising Cookies – used to advertise across the internet and to display relevant ads tailored to users based on the parts of the Site they have (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage).

The specific cookies (ours and third party’s) we currently use (may differ in each website), purpose of use, their privacy policy and opt-out controls are set forth in the table below: 

Google analytics: Essential, Functionality, Operation. & Security Cookies – www.google.com/policies/privacy/partners , https://tools.google.com/dlpage/gaoptout/.

Cookies Opt-Out

• Please note that, most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. By following the instructions of your device preferences, and by adjusting the privacy and security settings of your web browser, you may remove cookies, however, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited.
• Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful: Google Chrome; FireFox; Internet Explorer; Safari; Edge; Opera
• You may also contact us (see our contact details below), and we will make efforts to assist you.

Datomize Ltd. (“Company” or “we”) is committed to provide transparency regarding the security measures and policies which it has implemented in order to secure and protect personal data and personal identifying information (together “Personal Data“), all as defined under applicable data protection law, including without limitations, including without limitations, the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) (all collectively shall be defined herein as the “Data Protection Regulation”).

This information security policy outlines the Company’s security, technical and organizational practices. 

As part of our data protection compliance process we have implemented technical, physical and administrative security measures to protect the Personal Data, including upholding standards of Cybersecurity and Infrastructure Security Agency and the national institute standards and technology and technology and the GDPR TOM requirements.

Physical Access Control

The Company ensures the protection of the physical access to the data servers which store the Personal Data. The Personal Data processed by the Company is stored on AWS, Microsoft Azure, Google cloud or by our third party vendors. Further, the Company secures the physical access to its offices (i.e – alarm systems, code locks) and maintain records of any physical access to the protected Personal Data in order to ensure that solely authorized individuals such as employees and authorized external parties (maintenance staff, visitor, etc.) can access the Company’s offices.

Security Risk Analysis and Management.

The Company conducting an accurate and thorough assessment of the potential risks and vulnerabilities of the Company’s Personal Data to ensure the confidentiality, integrity, and availability of electronic Personal Data. The Company applies a periodic testing of the policies in order to ensure that the Company can cope with a consummation of any disaster and emergency case. The Company’s office is equipped with fire detectors, fire extinguishers and other applicable measures for the case of consummation of a nature disaster.

System Control 

Access to the Company’s database is highly restricted in order to ensure that solely the appropriate prior approved personnel can access the Company’s Personal Data. Safeguards related to remote access and wireless computing capabilities are in implemented therein. Employee are required to comply with the Company’s password policy when composing a password in order to allow strict access or use related to Personal Data all in accordance with position, and solely to the extent such access or use is required. There is constant monitoring of the access to the data and the passwords used to gain login access. 

Data Access Control

There are restrictions in place to ensure that the access to the Personal Data is restricted to employees which have a permission to access it. Any permission is granted by the Company’s authorized personal. The Personal Data information shall not be accessed, modified, copied, used, transferred or deleted without specific authorization. The access to the Personal Data information, as well as any action performed involving the use of the Personal Data requires a password and user name, which is routinely changed, as well as blocked when applicable. Each employee is able to perform actions solely according to the permissions determined by the Company. Each access is logged and monitored, and any unauthorized access is automatically reported. Further, the Company has ongoing review of which employees’ have authorizations, to assess whether access is still required. Company revokes access immediately upon termination of employment. Authorized individuals can solely access Personal Data that is established in their individual profiles. 

Organizational and Operational Security 

The Company invests a multitude of efforts and resources in order to ensure compliance with the Company’s security practices, as well as continuously provides employees on-going training and periodic updates regarding Company’s security procedures. The Company strives to raise awareness to the risk involved in the processing of Personal Data. In addition, the Company implemented applicable safeguards for its hardware and software, including web content filtering, firewalls and anti-virus software (“Protection Measures”) on applicable Company hardware, software or employee’s computer, in order to protect against virus, worms, Trojan identifications or any other malicious software. The Protection Measures cannot be deactivated by any user other than the Company’s cyber security officer and according to the Company’s policies.

Transfer Control 

Except for transfer data to our business partners, The Company does not transfer any Personal Data outside of the Company’s cloud servers. All transfer of Personal Data between the client side and the Company’s servers is protected using encryption and safeguards. The Company’s servers are protected by industry standards. Furthermore, the destruction of Personal Data following termination of the engagement is included within the contract between the parties. In addition, to the extent applicable, the Company’s business partners execute an applicable Data Processing Agreement, all in accordance with applicable laws.

Data Retention 

Personal Data is retained for as long as needed to provide the services or as required under applicable laws. Individuals may request data deletion; however, this request is not absolute and is limited, all as detailed in the Company Privacy Policy. 

Job Control 

All of the Company’s employees are required to execute an employment agreement which includes confidentiality provisions as well as applicable data protection provisions binding them to comply with the Company’s policies, in particular the computer security policy. In addition, employees undergo a screening process applicable per regional law. In the event of a breach of an employee’s obligation or non-compliance with the Company’s policies, the Company includes repercussions to ensure compliance with the policies. In addition, prior to the Company’s engagement with third party contractors, the Company reviews such third party’s security policies, specifically their information data security policies to ensure it complies with the Company’s standard for data security protection. Third party contractors may solely access the Personal Data as explicitly instructed by the Company.