PRIVACY POLICY

Last Updated: January 2024.

1. Data Collection & Processing
   When we use the terms “personal data” or “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
   
   Types of personal data collected. We may collect or generate the following types of personal data about individuals through the Services:
   • Usage, login credentials, and device information concerning Users and Prospects: connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based on such IP addresses, digital identifiers, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, log-in credentials to the Services, the cookies and pixels installed or utilized on the device, and inferred or presumed data generated from use of the Services.
     
     We collect and generate this information automatically, including through the use of analytics tools (including cookies and pixels), which collect data such as how often visitors visit or use the Sites, which pages are visit and when, which website, ad or email message brought them there, and how Users interact with and use the Services and its various features.
   • Contact and profile information concerning our Customers, Users and Prospects: contact and business details such as name, email, phone number, position, workplace and related business insights, our communications with such individuals (correspondence, sensory information including call and video recordings, and transcriptions and analyses thereof), feedback and testimonials received, CV, social media profiles, contractual and billing details, as well as any expressed, presumed, declared or identified needs, preferences, attributes and insights relevant to our potential or existing engagement.
     
     We collect this information directly from you, or from other sources and third parties such as our Customers (your employer) as a part of our commercial engagement. We may also obtain personal data from our Service Providers, e.g., marketing and sales tools, data enrichment services, our sales and marketing partners, distributors, job recruiters, or your colleagues.
   • Communications with our Customers, Users, Prospects: Personal data contained in any forms and inquiries that you may submit to us, including support requests, interactions through social media channels and instant messaging apps, registrations to events that we host, organize or sponsor, and participation in our online and offline activities; surveys, feedback and testimonials received; expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement; and sensory information including phone call and video conference recordings (e.g., with our customer experience or product consultants), as well as written correspondences, screen recordings, screenshots, documentation and related information that may be automatically recorded, tracked, transcribed and analyzed, for purposes including analytics, quality control and improvements, training, and record-keeping purposes.
   For the purposes of the California Consumer Privacy Act (“CCPA”), specifically in the last twelve (12) months, we have collected the following categories of Personal Information: Identifiers; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Customer Records Information; and Geolocation Information. We do not use or disclose sensitive personal information as defined in the CCPA.
2. Data Uses
   
   We use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

   Purpose

   Legal basis for processing

   To facilitate, operate, enhance, and provide our Services

   • Performance of a contract
   • Legitimate Interest

   To provide our Customers and Users with assistance and support, to test and monitor the Services, or diagnose or fix bugs or other technology problems

   • Performance of a contract
   • Legitimate Interest

   To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities

   • Legitimate Interest

   To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our Services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services

   • Legitimate Interest
   • Consent

   To facilitate, sponsor and offer certain events, contests and promotions

   • Legitimate Interest

   To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we can improve their and others’ user experience and the value they can generate from using the Services, so we can continue improving our products, offerings and the overall performance of our Services, including through the utilization and optimization of Artificial Intelligence and Machine Learning capabilities

   • Legitimate Interest

   To contact our Customers, Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them

   • Legitimate Interest
   • Consent

   To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity

   • Performance of a contract
   • Legitimate Interest
   • Legal Obligation

   To authenticate the identity of our Users and allow them to access and use the Services

   • Performance of a contract

   To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we and our Service Providers may use to provide and improve our respective services, or for any other purpose

   • Legitimate Interest

   To enforce our Terms and Conditions, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties

   • Legitimate Interest

   To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards

   • Performance of a contract;
   • Legitimate Interest
   • Legal Obligation
   If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to be processed by or via the Services, or due to nature of such processing), your acceptance of our Terms and Conditions (and/or the terms that govern your use of a Solution) (collectively, the “Terms”) and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes details herein. If you wish to revoke such consent, please contact us at privacy@preql.com.
3. Data Location and Transfers
   
   We and our authorized Service Providers maintain, store and process personal data in the United States of America (“US”), Israel, and in other locations as reasonably necessary for the proper delivery and performance of our Services, or as may be required by law.
   Since we operate globally and may use service providers worldwide, including in the US, Israel and other locations as reasonably necessary for the proper performance of our Services, or as may be required by law, we may transfer your personal data outside your country of residence.
   While privacy laws may vary between jurisdictions, Preql is committed to protect personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such Personal Information is transferred.
   For data transfers from the European Economic Area, Switzerland or the United Kingdom, we will transfer your personal data only to such countries, approved by the relevant authorities within those jurisdictions, as providing adequate level of data protection, or enter into Standard Contractual Clauses as approved by the relevant data protection authority. You can obtain a copy of these clauses by contacting us as indicated below.
4. Data Retention
   
   We retain personal data for as long as we deem it reasonably necessary to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
   To determine the appropriate period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.If you have any questions regarding our data retention practices, please contact us by email at privacy@preql.com.
5. Data Disclosure
   
   We may disclose personal data in the following situations:
   • Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks, data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
   • Partnerships: Preql engages with selected business and channel partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a tailored experiences for our Customers, Users and Prospects. In such instances, we may disclose relevant contact, business and usage details with the respective partner, to allow them to engage with those entities and individuals for such purposes. If you directly engage with any of our partners, please note that any aspect of that engagement which is not directly related to the Services and directed by Preql is beyond the scope of Preql’s Terms and Conditions and Privacy Policy, and may therefore be covered by the partner’s terms and privacy policy.
   • Event Sponsors: If you attend an event or webinar organized by us or a conference in which we are also in attendance, or download or access a related asset on our Sites, webinar or other activity involving third-party sponsors or presenters, we may disclose your personal data to them. If required by applicable law, you may consent to such disclosure via the registration form or other relevant mechanism. In these circumstances, your personal data will be subject to the sponsor’s privacy statements. If you do not wish for your personal data to be disclosed, you may choose not to opt in via event/webinar registration, or you can opt out in accordance with Section ‎7 below.
   • Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data in response to a legal request, such as a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interest, including the security or integrity of our products and Services.
   • Sharing Personal Data with our Customers: We may disclose Users’ personal data with their affiliated organization. In certain cases, other Users from your organization may control your account and will be entitled to monitor, process and analyse your data and associated content, including (i) view any content you submit and your activities on the Services; (ii) view statistics regarding your account; (iii) change your account password or other access credentials or privileges; (iv) suspend or terminate your account access; and (v) access or retain data stored as part of your account. Please note that in these circumstances Preql is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of your organization, that acts as the “Data Controller” of such data (as further described in Section 10 below).
   • Protecting Rights and Safety: We may disclose your personal data with others, if we believe in good faith that this will help protect the rights, property or personal safety of Preql, any of our Customers, Users or Prospects, or any members of the general public.
   • Preql Subsidiaries and Affiliated Companies: We may disclose personal data internally to our affiliated companies, for the purposes described in this Privacy Policy. In addition, should Preql or any of its subsidiaries or affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your personal data 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 Services.
   • Additional Disclosure: Preql may disclose your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. Additionally, we may transfer, disclose or otherwise use non-personal data at our sole discretion and without the need for further approval.
   For the purposes of the CCPA, in the past twelve (12) months, we may have disclosed Identifiers; Professional or Employment-Related Information; Internet or other Electronic Network Activity Information; Customer Records Information; and Geolocation Information to the third parties listed above.
6. Cookies and Data Collection Technologies
   
   We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may disclose non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.
   Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
   Some cookies are necessary for the Services to function properly, and cannot be declined or disabled unless you delete and block them through your web browser settings. Other cookies, which are used for functional, performance, analytics and marketing purposes, are optional. These include web and app analytics tools and tools that provide us with insights on the performance of our ads and campaigns.
   While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. You may also use the “cookie settings” feature available at the bottom of our website at www.preql.com.
   We also use Google Analytics, a web analytics tool which helps us understand Users’ behavior on our Sites, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of Google Analytics is available at: www.google.com/policies/privacy/partners/. Further information about your option to opt out of Google Analytics is available at: https://tools.google.com/dlpage/gaoptout.
   Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt out, so an additional opt out will be necessary to prevent additional tracking.
7. Communications
   
   We engage in Services and promotional communications, through email, phone, SMS and notifications.
   Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service maintenance or changes, password retrieval notices, etc. You will not be able to opt out of receiving such service communications while using our Services, as they are integral to such use (for example, password resets or billing notices).
   Notifications and Promotional Communications: We may notify you about new features, offerings, events, and special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contacts means available to us (e.g., phone, mobile or email), through the Services, or through our marketing campaigns on any other websites or platforms.
   If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to privacy@preql.com or by following the "unsubscribe", "stop" or "change email preferences" instructions contained in the promotional communications you receive.
8. Data Security
   
   To protect your personal data held with us, Preql and our Service Providers implement systems, applications, and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide industry-standard security. However, please be aware that regardless of any security measures used or implemented, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.
9. Data Subject Rights
   
   Individuals have rights concerning their personal data. Please contact us by e-mail at: privacy@preql.com if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (“GDPR”), the Swiss Federal Act on Data Protection, (“FADP”), the California Consumer Privacy Act (“CCPA”) and other similar US State Laws. Such rights may include, each to the extent available to you under the laws which apply to you: the right to know/request access to (specific pieces of personal data collected, categories of personal data collected, categories of sources from whom the personal data was collected, purpose of collecting personal data, categories of third parties with whom we have shared personal data); to request rectification or erasure of your personal data held with Preql; or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future); or to port such personal data; or the right to equal services and prices (e.g. freedom from discrimination). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
   Please note, when you ask us to exercise any of your rights, we may need to ask you to provide us certain credentials (e.g. in order to authenticate and validate your identity so that we know which data in our systems relates to you, and where necessary, to better understand the nature and scope of your request). If your request relates to personal data contained in Customer Data (i.e., personal data we process on our Customers’ behalf as its “data processor” or “service provider”, as further explained in Section 10 below), such Customer exclusively determines how the data may be processed, as well as if and how your request should be handled – so we advise that you submit your request directly to them.
   We may not be able to fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data, and if such data is processed on behalf of any of our Customers, to which Customer it particularly relates, so that we may forward it to them for their further handling. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfillment). We may redact from the data which we will make available to you, any personal data or confidential information related to others.
10. Data Controller/Processor
    
    Certain data protection laws and regulations, such as the EU and UK GDPR, the FADP and CCPA, typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA, the “Business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, the “Service Provider”), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
    Preql is the “Data Controller” of Prospect and User Personal Data. With respect to such data, we assume the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.
    Preql is the “Data Processor” of Customer Data. Such data is processed by Preql on behalf of the Customer (who is the “Data Controller” of such data; and our Service Providers who process such Customer Data on our behalf are the “sub-processors” of such data). Accordingly, Preql processes Customer Data strictly in accordance with our Customers’ reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such Customer.
    Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the Services.
11. Additional Notices and Contact Details
    
    Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the published date. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments to this Privacy Policy shall be deemed accepted by you.
    Requirements under US State Privacy Laws: This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention and deletion practices (Section 4). We have also included information about how we may process your information (in Sections 2 through 7), which includes for “business purposes” under the CCPA and similar US state laws, as applicable. We do not sell or “share” your personal information for the intents and purposes of the CCPA. We do disclose personal data to third parties or allow them to collect personal data from our Services as described in Section ‎5 above, if those third parties are our Customers (with respect to Customer Data processed on their behalf), or our authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 5 above. Please note, you may designate, in writing or through a power of attorney, am authorized representative to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights be emailing us. Note that we will not discriminate against you by withholding our Services from you or providing a lower quality of service to you for requesting to exercise your rights under the law. If you have any questions or would like to exercise your rights under US state laws, please contact privacy@preql.com.
    External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or services of such third parties and to read the privacy policies of each website and service you visit. This Privacy Policy only applies to our Services.
    Children’s Privacy: Our Services are not intended for use by children under the age of 18. We do not knowingly collect personal data from minors under the age of 18 and do not wish to do so. In the event that it comes to our knowledge that a minor is using the Services, we will prohibit and block such user from accessing the Services (to the extent reasonably possible) and will make all efforts to promptly delete any personal data stored with us with regard to such user.
    Contacting Us: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your personal data held with us, please contact us at privacy@preql.com.