Curve Tech Privacy Notice

Last Updated: September 23, 2019

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Curve Tech Ltd. (together, “Curve Tech” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“User”, “you”) such as in the following use cases:

  • When you browse or visit our website, https://curve.tech/ (“Website”);
  • When you make use of, or interact with, our Website
    1. When you request a demo and/or a free trial
    2. When you contact us (e.g. customer support, when you call us, send us an email, submit an inquiry)
    3. When we process your job application
    4. When you subscribe to our email list/newsletters
  • When you make use of, or interact with our Dashboard
    1. When you sign up for an account, log in and make use of our services
    2. When you create administrator for your use of the Dashboard
    3. When your administrator user create users for your use of the Dashboard
  • When you attend a marketing event and provide Personal Data
  • When you exchange business cards with us
  • When we use the Personal Data of our service providers and suppliers
  • When we use the Personal Data of our customers
  • When we use the Personal Data of our resellers, distributors, agents and/or finders
  • When you interact with us on our social media profiles (e.g., Facebook, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

  1. What information we collect, why we collect it, and how it is used
  2. Period of storage of collected information
  3. How we protect and retain your personal data
  4. How we share your personal data
  5. Additional information regarding transfers of personal data
  6. Your privacy rights. How to delete your account
  7. Use by children
  8. Interaction with third party product
  9. Log files
  10. Analytic tools
  11. California privacy rights
  12. Contact us

This Privacy Policy can be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below.  If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

 

Specific personal data we collect

 

Why is the personal data collected and for what purposes?Legal basis (GDPR only, if applicable)Third parties with whom we share your personal data

 

Consequences of not providing the personal data
When you browse or visit our Website
Cookies, analytic tools and log files

For more information, please read our cookies policy –

https://curve.tech/cookies-policy/

 

Marketing, analytics, analysis, market research, to improve our websiteConsent

Legitimate interest (e.g. essential cookies)

3rd party platforms such as for the following purposes:

·         Google analytics

Cannot collect and store the information

Cannot use or access some parts of the Website

When you make use of, or interact with, our Website
When you request a demo and/or a free trial
·         Full name

·         Phone number

·         Email address

·         Any other data that you decide to provide/supply us

·         To provide a demoProcessing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. to provide a demo)

3rd party platforms such as for the following purposes:

·         Google (cloud)

·         MailChimp (marketing tool)

·         AWS )cloud)

Cannot provide a demo
·         Full name

·         Email address

·         To send you marketing communicationsConsent3rd party platforms such as for the following purposes:

·         MailChimp (marketing tool)

Cannot  send you marketing communications
When you contact us (e.g. customer support, when you call us, send us an email, submit an inquiry)
·         Full name

·         Email address

·         Website

·         Message

·         Any other data you decide to provide/supply us

·         To process and answer questions

·         To provide support (e.g., to solve problems or other issues)

·         To customize your experience

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to answer your questions)

3rd party platforms such as for the following purposes:

·         Google (cloud)

·         Shoppify (API- data collecting)

·         AWS )cloud)

Cannot assist you and respond your query

Cannot provide support, solve problems

Cannot customize your experience

·         Full name

·         Email address

·         To send you marketing communicationsConsent3rd party platforms such as for the following purposes:

·         MailChimp (marketing tool)

Cannot  send you marketing communications
When we process your job application
·         Full name

·         Email address

·         Phone number

·         CV / resume

·         Cover letter

·         Any other data you decide to provide/supply us

·         To process your job application

·         To assess the candidate

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to assess a candidate)

3rd party platforms such as for the following purposes:

·         Facebook (Responses to job applications on Facebook)

·         LinkedIn (business development and job responses)

Cannot process your job application

Cannot assess your suitability as a candidate

When you subscribe to our email list/newsletters                                    
·         Full name

·         Email address

·         Any other data that you decide to provide/supply us

·         To send marketing communicationsConsent

Legitimate interest (e.g. to send you Curve Tech’ updates)

3rd party platforms such as for the following purposes:

·         MailChimp (marketing tool)

Cannot send you marketing communications
When you make use of, or interact with our Dashboard
When you sign up for an account, log in, and make use of our services
·         Full name

·         Email address

·         User name

·         Password

·         Telephone number

·         Company name

·         Geographic locations

·         IP address

·         Device type and mode

·         Transaction history

·         If you use the Curve application on Shopify, we collect the merchant’s shop ID.

·         To create an account

·         To fulfill your requests for services and for related activities (e.g., account management, support and to provide other services related to your relationship with)

·         To perform/execute the agreement (i.e. to provide you with Curve.)

·         To grant you access to the services (our Dashboard)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to sign up to the services)

3rd party platforms such as for the following purposes:

·         Shopify (API- data collecting)

·         Magento (API- data collecting)

·         WooCommerce (API- data collecting)

·         Wix (API- data collecting)

·         Vitex (API- data collecting)

Cannot create an account

Cannot fulfill your request for products and/or services

Cannot perform the agreement

Cannot grant you access to the services

·         Full name

·         Email address

·         To send marketing communicationsConsent3rd party platforms such as for the following purposes:

·         MailChimp (marketing tool)

Cannot send you marketing communications
When you create administrator for your use of the Dashboard
·         Full name

·         Email address

·         Company name

·         Job position / role

·         Phone number

·         User name

·         Password

·         Device type

·         IP Address

·         Geolocation

·         Usage patterns

·         Any other data you decide to provide/supply

·         To create administrator users for your use of the Dashboard

·         To fulfill your requests for services and for related activities

·         To perform/execute the agreement

·         To grant you access to the services (our Dashboard)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to create administrator users)

3rd party platforms such as for the following purposes:

·         Google (cloud)

·         AWS )cloud)

Cannot create administrator users

Cannot fulfill your request for products and/or services

Cannot perform the agreement

Cannot grant you access to the services

·         Full name

·         Email address

·         To send marketing communicationsConsent3rd party platforms such as for the following purposes:

·         MailChimp (marketing tool)

Cannot send you marketing communications
When your administrator user create users for your use of the Dashboard
·         Full name

·         Email address

·         Company name

·         Job position / role

·         Phone number

·         User name

·         Password

·         Device type

·         IP Address

·         Geolocation

·         Usage patterns

·         Any other data you decide to provide/supply

·         To create users

·         To fulfill your requests for services and for related activities

·         To perform/execute the agreement

·         To grant you access to the services (our Dashboard)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to create users)

3rd party platforms such as for the following purposes:

·         Google (cloud)

·         AWS )cloud)

Cannot create users

Cannot fulfill your request for the services

Cannot perform the agreement

Cannot grant you access to the services

·         Full name

·         Email address

·         To send marketing communicationsConsent3rd party platforms such as for the following purposes:

·         MailChimp (marketing tool)

Cannot send you marketing communications
When you attend a marketing event and provide Personal Data
·         Full name

·         Email address

·         Company name

·         Phone number

·         Any other data you decide to provide/supply us

·         To establish a business connection

·         To send marketing communications

Consent

Legitimate interest (e.g. send you more information about Curve Tech)

3rd party platforms such as for the following purposes:

·         Google (cloud)

·         AWS )cloud)

·         MailChimp (marketing tool)

Cannot establish a business connection

Cannot send you marketing communications

When you exchange business cards with us
·         Full name

·         Email address

·         Company name

·         Phone number

·         Any other data you decide to provide/supply us

·         To establish a business connection

·         To send marketing communications

Consent

Legitimate interest (e.g. send you more information about Curve Tech)

3rd party platforms such as for the following purposes:

·         Google (cloud)

·         AWS )cloud)

·         MailChimp (marketing tool)

Cannot establish a business connection

Cannot send you marketing communications

When we use the Personal Data of our service providers and suppliers
·         Full name

·         Email address

·         Company name

·         Phone number

·         Any other data you decide to provide/supply us

 

·         To contact our service providers and suppliers

 

·         To perform the applicable agreement

 

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

 

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as for the following purposes:

·         Google (cloud)

·         AWS )cloud)

Cannot contact our service providers and suppliers

 

Cannot perform the agreement

When we use the Personal Data of our customers
·         Full name

·         Email address

·         Company Address

·         Company name

·         Role/Title

·         Phone number

·         Country

·         Billing address and delivery address

·         Financial information (bank account and payment card details) and information about the transaction

·         If you use the Curve application on the eCom platform, we collect the merchant’s shop ID. It is necessary to allow us to carry out our contract with you and necessary for our legitimate interests (in the event we need to recover debts due to us).

·         Any other data you decide to provide/supply us

●        To provide our services

 

●        To perform the applicable agreement

 

●        To notify you about changes and updates to our service

 

Processing is necessary for the performance of a contract to which our customer is a party.

 

Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).

Legitimate interest (e.g. send you contract-related communications)

3rd party platforms such as for the following purposes:

·         Google (cloud)

·         AWS )cloud)

Cannot provide the services and/or our products

 

Cannot perform the agreement

Cannot notify you about changes and updates to our service

 

·         Full name

·         Email address

●        To send marketing communicationsConsent3rd party platforms such as for the following purposes:

·         MailChimp (marketing tool)

Cannot send you marketing communications
When we use the Personal Data of our resellers, distributors, agents and/or finders [TBD]lets discuss
·         Full name

·         Email address

·         Company name

·         Phone number

·         Any other data you decide to provide/supply us

·         To contact our service resellers, distributors, agents and/or finders

 

·         To perform the applicable agreement

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

 

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as for the following purposes:

·         Google (cloud)

·         AWS (cloud)

 

Cannot communicate with  our resellers, distributors, agents and/or finders

 

Cannot perform the agreement

 

 

When you interact with us on our social media profiles (e.g., Facebook, Twitter, LinkedIn)
·         Full name

·         Email address

·         Any other data you decide to provide/supply us

●        To reply and/or respond to your request or question

●        To establish a first business connection/discussion

Depending on the context, legitimate interest (e.g. certain B2B marketing practices or replying your requests/questions), pre-contractual discussions (e.g. if you show interest in our services) or consent3rd party platforms such as for the following purposes:

·         Google (cloud)

·         AWS (cloud)

 

Cannot reply or respond to your request

Cannot establish a business connection

 

Cannot send you marketing communications

Finally, please note that some of the abovementioned Personal Data will be used for fraud detection and prevention, and for security purposes. The abovementioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

  1. PERIOD OF STORAGE OF COLLECTED INFORMATION

We have an internal data retention policy to ensure that we do not retain your personal data perpetually.

Personal Data. We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax or accounting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Where you purchase the Curve solution and we are acting as your data processor, it is your right to determine for how long your Personal Data is retained for, and note that it should be retained for as long as it is necessary for Curve to perform the service.

Cookies. Regarding retention of cookies, you can read more in our cookie policy https://curve.tech/cookies-policy/.

  1. HOW WE PROTECT AND STORE YOUR INFORMATION
  • Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  • Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
  1. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described in Section 1, we may share your information as follows:

  • To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
  • In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or

Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

If you want to receive the list of recipients of your Personal Data, please make your request by contacting us to privacy@curve.tech.

  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

Storage:

Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

 

External transfers:

  • Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our services, we will obtain contractual commitments from them to protect your Personal Data.
  • Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.

 

  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
  1. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
  • Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
  • You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at privacy@curve.tech. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

  • Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@curve.tech. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
  1. USE BY CHILDREN

We do not offer our services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@curve.tech.

  1. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

  1. LOG FILES

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

  1. ANALYTIC TOOLS
  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • We reserve the right to use other analytic tools.
  1. CALIFORNIA PRIVACY RIGHTS
    • California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@curve.tech. Please note that we will respond to one request per customer each year, unless otherwise required by law.
    • Our California Do Not Track Notice:

We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

  • Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law.  Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
  1. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@curve.tech.