[Last Updated: June 2022]
This privacy policy (“Privacy Policy”) governs the data collection, processing, and usage made by Tactile Mobility Ltd. (“Company”, “Tactile”, “we” or “us”) with respect to the data we collect from individuals who access and use our website (respectively “Website” and “Visitors” or “you”).
This Privacy Policy constitutes an integral part of the Website Terms and Conditions and any other agreement between you and us (together “Terms”), and provides you with information regarding our processing operation, the lawful basis pursuant to which we process your Personal Data (as defined below), third parties to whom Personal Data will be transferred, data retention periods, as well as how you may exercise your rights, among others, and where applicable ,as required according to applicable privacy legislation including the EU General Data Protection Regulation (“GDPR”). Definitions used herein but not defined herein shall have the meaning ascribed to them in the Terms.
You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. However, in some cases, without providing your data we would not be able to provide you with all or some of our Services.
We reserve the right to periodically amend or revise the Privacy Policy, which will immediately affect the implementation of the revised Privacy Policy on our Website. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.
2. WHO ARE WE
We are Tactile Mobility Ltd.
Our address is: Derech Ha’atzmaut 61, Haifa 3303323
Phone: +972-4-375-0050
Email: contact@tactilemobility.com
Under the GDPR, we are the data controller of the data collected from our website.
If you have any questions or comments about this Privacy Policy or any concerns with respect to how your privacy any information are handled, please contact our privacy team through the contact details above.
3. THE DATA WE COLLECT AND ITS PURPOSES
“Non-Personal Data”: means non-identifiable, including statistical and aggregated data, that is mainly technical data which is transmitted to us by your device when you access and interact with the Company Services. Such data includes the type of browser, type of operation system, type of device used, the time and date you access the Company Services, navigation, language preference, etc. Non-Personal Data is used mainly for technical analysis of the Company’s services activity in order to provide, maintain, develop and enhance it, and is not used to identify individuals. Under this Privacy Policy, we can use any aggregated, statistical, and such de-identified data, which can no longer be associated with any individual with no limitation. That, even if such anonymized data was derived from Personal Data. Such data may be included in our proprietary information and does not deem as Personal Data under the law.
“Personal Data”: means, information which identifies or may identify, with reasonable effort, an individual. Such data includes, inter alia, your name, address, phone number and online identifiers (such as IP address or Cookie ID).
Please see below the table which specifies the Personal Data we collect and how we use it:
DATA SET | PURPOSE AND OPERATIONS | LAWFUL BASIS |
Contact Us If you voluntarily contact us for your interest in our products, for support, or for other inquiries, including through the use of any form on the Company Website (e.g., “Contact,” “Schedule a Demo” or “Help Center”) you may be required to provide us with certain information such as your name, email address, referral subject (“Contact Information”). If you are interested in leaving a comment on the “Help Center” page, you will be required to register with our website. If you are contacting us on behalf of another person, we value your assistance and care for others, please note that it is your responsibility to make sure that any person whose Personal Data you provide is aware of the principles of this statement and agrees that you will provide Personal Data to us on this basis. | We will use this data to respond to your inquiry or provide you with information regarding our services. We may process the content of our correspondence with you to improve our customer service, and in the event, we believe it is required in order to provide you with any further assistance (if applicable). We will store your data, including in any of our data systems such as CRM, analyze it, provide access to our relevant staff members and keep record of our correspondence with you. | We process such Contact Information subject to our legitimate interest in order to respond to your inquiry and as part of our marketing efforts. If you are an actual customer of our services contacting us for support or any similar inquiry, we will process your data for the fulfillment of the contract between us – providing you with our services. After addressing your inquiry, we may retain your data in our systems, as part of our business records keeping under our legitimate interest. |
Subscribing to our Mailing lists In the event you sign up to receive our newsletter or other marketing materials (“Marketing Materials“), you will be requested to provide your contact details, such as email address. | We will use your email in order to send you our newsletter and other Marketing Materials. | We process such Marketing Materials subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email or by contacting us directly. |
Recruitment Information In the event you apply for a job, we will collect your CVs as uploaded by you and your name, email address, phone number and a photo (optional). Further, we may receive from third parties, such as recruiting agencies, information about candidates who are interested in working at Company Group. In such cases we rely on the agreements we have with the third parties for obtaining your information. | To process your job application and for recruitment purposes, and in order to enable us to comply with corporate governance and legal and regulatory requirements. If you are hired by us, the Recruitment Information that you provide us may be used in connection with your employment and our corporate management. We will keep your data including your CV, analyze it, store it in our systems, use the data or contacting you or for further recruitment stages (e.g., interview) and keep records of our interaction with you. | We process such Recruitment Information subject to our legitimate interest. |
Online Identifiers We use third-party cookies on the Company Website, as further detailed below, these cookies provide us with analytic services as well as marketing services. The Personal Data processed is an online identifier, either a cookie agent, the IP address, etc. | We will use your Online Identifiers for analytic and marketing purposes. We will collect your information and analyze it, whether directly or through the use of third-party systems and services. | We will process such data subject to your consent through the Cookie Banner on our Website. For more information, see below “Cookies Usage”. |
Please note that, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of personal data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated in the table above.
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 Our service, as well as to protect the security or integrity of our databases and Company Services, and to take precautions against legal liability. Such processing is based on out legitimate interests.
4. COOKIES USAGE
We use cookies to improve your experience while you use the Company Services. We may use various types of Cookies:
Please note that the data collected by the use of Cookies may be linked to and combined with any other data, including Personal Data.
In addition, Cookie’s data is usually collected through the use of third-party services, like Google, Facebook, etc. In those cases, your Personal Data might be transferred to those third parties, which might link it and use it together with other information they have on you from other sources. Such data is “owned” and processed separately by those third-parties under their terms and conditions and the direct accounts or subscriptions you have with those third parties. For example, suppose you have a Facebook account, the Personal Data collected through Facebook’s Cookies on the Company Website might be linked to other data that Facebook collects from you as a Facebook user, and might be used by Facebook per the independent agreements between you and Facebook.
The specific cookies we currently use and your choices with regard to such use are detailed HERE[APM2] .
5. METHODS FOR COLLECTING YOUR DATA
According to the nature of your interaction with Company Services, we may collect information as follows:
Provided by you voluntarily – we will collect information if and when you choose to provide us with information, such as filing any contact form.
Automatically – we may use cookies and similar tracking technologies (as elaborated in the Cookies Section above) to gather some information automatically when you access the Company Website.
Provided to us by third parties – as part of our digital marketing efforts as described ABOVE.
6. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:
Where we share information with service providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations.
7. DATA TRANSFERS
Any information you provide us may be transferred to and processed in countries other than the country from which you accessed the Company Services. If you are a resident of the European Economic Area (“EEA“) we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.
8. YOUR RIGHTS
Individuals have certain rights under applicable privacy laws with regards to their Personal Data. Subject to your jurisdiction (and additional conditions), these rights may include might include:
You may exercise any or all of your above rights in relation to your Personal Data by contacting us by send you Data Subject Request to contact@tactilemobility.com.
Where we are not able to provide you with the information 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 before we provide you with any such information in accordance with applicable law.
9. RETENTION
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable.
The criteria used by us to determine our retention periods are as follows:
We may at our sole discretion, rectify or erase information from our systems, without prior notice to you, once we deem it is no longer necessary for such purposes.
10. SECURITY
We implement extensive security measures to reduce the risks of damage, loss of information and unauthorized access or misuse of Personal Data. We implement appropriate data collection, storage and processing practices and security tools to protect personal data against unauthorized access, alteration, disclosure or destruction. You should be aware that no security measures are completely fail-proof, and it is impossible to prevent any and all threats to the security of data and systems. Therefore, you should be aware that any processing of digital Personal Data holds certain inherent risks, and we cannot guarantee that our services and databases will be immune to any wrongdoings, malfunctions, unauthorized interceptions or access, malware attacks or other kinds of abuse and misuse.
11. CHILDREN
Our website is not directed nor is it intended for use by children under the age of sixteen (18) and we do not knowingly process a child’s information. We will immediately discard any information that we receive from a visitor that is considered a child upon our discovery that such a visitor shared information with us. If you are under the age of eighteen (18), please be sure to read the terms of this Policy carefully with your parents or other legal guardians. Please contact us through the above means of contact if you have reason to believe that a child has shared any information with us.