Privacy Policy

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

  1. When you browse or visit our website, https://www.panorays.com/  (“Website”);
  2. When you make use of, or interact with, our Website
  1. When you request demo
  2. When you send us a request to receive your security profile/posture in order to share your profile
  3. When you send us a request to test the cyber posture of some suppliers of your choice
  4. When you request to read more of our case study, whitepaper, data sheet and any other resources that we have in our Website
  5. When you publish reviews of Panorays services
  6. When you complete a survey/questionnaire
  7. When you subscribe to our newsletter(s) / blog(s)
  8. When we process your job application
  9. When you contact us (e.g. need help, submit a request)
  1. When you make use of, or interact with, our platform (the “Platform”)
  1. When you create an account, and log in to the Platform as a user (including, without limitation, a customer or as a vendor/third party)
  2. When you are a vendor and you enter with your guest//anonymous account
  1. When you attend a marketing event and provide us with your personal data
  2. When you exchange business cards with us
  3. When we acquire your personal data from third-party sources (such as lead-generation companies)
  4. When we use the personal data of our customers (e.g. contact details)
  5. When we use the personal data of our resellers, distributors, agents and/or finders (e.g. contact details)
  6. When we use the personal data of our service providers (e.g. contact details)  
  7. When you interact with us on our social media profiles (e.g., Facebook, Instagram, 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” or “personal information” 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. How we protect and retain your personal data
  3. How we share your personal data
  4. Additional information regarding transfers of personal data
  5. Your privacy rights. How to delete your account
  6. Use by children
  7. Interaction with third party products
  8. Log files
  9. Analytic tools
  10. Specific provisions applicable under California privacy law
  11. Automated collectionof personal data
  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 this Privacy Policy.  If we implement significant changes 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

Retention period

 

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

 

Marketing, analytics and statistics.

Consent

 

Legitimate interest (e.g. essential cookies)

 

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)

For more information, please read our cookies policy

 

Certain Website features may not be available

 

Read more about the purposes of each cookie her 

When you make use of, or interact with, our Website

When you request a demo

  • Full name
  • Email address
  • Phone number
  • Company name
  • IP address
  • Location (as country/city bases)
  • Comments
  • Any other data you decide to provide/supply
  • To provide you a demo

 

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:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot provide a demo

 

When you send us a request to receive your security profile in order to share your profile

  • Full name
  • Business email
  • Company name
  • Phone number
  • IP address
  • Location (as country/city bases)
  • Any other information that you decide to supply/provide us

 

 

  • To send you a link with your profile, per request
  • To analyze cyber gaps and providing actionable insights requested by you
  • To analyze your answers to the questionnaires
  • To allow you to log-in to the Platform

 

 

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 send you the requested link)

 

3rd party platforms such as for the following purposes:

 

  • Google (Cloud)
  • Mongo DB (Managed service)
  • Gsuite (Google emailing services)
  • SendGrid (Emails from the Platform)

 

 

 

 

 

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot send you a link with your profile, per request

 

Cannot analyze cyber gaps and providing actionable insights requested by you

 

Cannot analyze your answers to the questionnaires

 

Cannot allow you to log-in to the Platform

 

  • Full name
  • Business email

 

  • To send you marketing communications

Consent

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot send you marketing communications

When you send us a request to test the cyber posture some suppliers of your choice

  • First name
  • Last name
  • Business email
  • Business phone number
  • Company name
  • Supplier name and URL to test
  • IP address
  • Location (as country/city bases)
  • Any other information that you decide to supplier/provide us

 

 

  • To provide you with a sample security test, as requested
  • To analyze cyber gaps and providing actionable insights requested by you
  • To communicate with you to share additional information about your request
  • To allow you to log-in to the Platform

 

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 you with a sample security test of three suppliers)

3rd party platforms such as for the following purposes:

 

  • Google (Cloud)
  • Mongo DB (Managed service)
  • Gsuite (Google emailing services)
  • SendGrid (Emails from the Platform)

 

 

 

 

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot provide you with a sample security test, as requested

 

Cannot analyze cyber gaps and providing actionable insights requested by you

 

Cannot communicate with you to share additional information about your request

 

Cannot allow you to log-in to the Platform

  • First name
  • Last name
  • Business email

 

  • To send you marketing communications

Consent

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot send you marketing communications

When you request to read more of our case study, whitepaper, data sheet and any other resources that we have in our Website

  • First name
  • Last name
  • Business email
  • Company name
  • Title
  • IP address
  • Location (as country/city bases)

 

 

 

  • To download our resources

 

 

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 download our resources)

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot download our resources

 

 

  • First name
  • Last name
  • Business email

 

  • To send you marketing communications

Consent

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot send you marketing communications

When you publish reviews of Panorays services

  • First name
  • Last name
  • Business email
  • Company name
  • Title
  • Message/comments/review
  • IP address
  • Location (as country/city bases)
  • Any other information that you decide to supply/provide us
  • To publish your review in our Website and Panorays’ social media channels

 

 

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 publish your review).

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • Gsuite (Google emailing services)

 

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot publish your review in our Website and Panorays’ social media channels

 

 

When you complete a survey

  • Full name
  • Email address
  • IP address
  • Location (as country/city bases)
  • Your answers to the questionnaire, when includes Personal Data

 

 

 

  • To analyze your answers
  • To send you the results of the survey
  • To allow you to log-in to the Platform to respond the survey

 

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 allow you to complete the survey).

 

3rd party platforms such as for the following purposes:

 

  • Google (Cloud)
  • Mongo DB (Managed service)
  • Gsuite (Google emailing services)
  • SendGrid (Emails from the Platform)

 

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot analyze your answers

 

Cannot send you the results of the survey

 

Cannot allow you to log-in to the Platform to respond the survey

 

 

When you subscribe to our newsletter(s) / blog(s)

  • Full name
  • Email address

 

 

 

  • To send you marketing communications
  • To send you more information about Panorays
  • To send you Panorays’ updates, case studies, and other materials

Consent

 

 

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot send you marketing communications

Cannot send you more information about Panorays

Cannot send you Panorays’ updates, case studies, and other materials

 

When we process your job application

  • Full name
  • Email address
  • Phone number
  • CV/resume
  • Cover letter
  • IP address
  • Location (as country/city bases)
  • Any other data you decide to provide/supply

 

 

  • To process your job application

 

  • To assess the candidate

 

 

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:

 

  • Gsuite (Google emailing services)
  • HubSpot (Marketing automation)

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot process your job application

 

Cannot assess your suitability as a candidate

 

When you contact us (e.g. need help, submit a request)

  • First name
  • Last name
  • Business email
  • Company name
  • Phone number
  • IP address
  • Location (as country/city bases)
  • Any additional comments you decide to leave us.

 

  • To answer your questions

 

  • To provide support

 

  • To customize your experience

 

 

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. provide support and answer your questions)

3rd party platforms such as for the following purposes:

 

  • Drift (chat box)
  • HubSpot (Marketing automation)

 

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot answer your questions

 

Cannot provide support

 

Cannot customize your experience

 

  • First name
  • Last name
  • Business email

 

  • To send you marketing communications

Consent

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot send you marketing communications

When you make use of, or interact with, our Platform

When you create an account, and log in to the Platform as a user (including, without limitation, customers or as a vendor/third party)

  • Full name
  • Business email
  • Company name
  • Job title
  • User and password
  • IP address
  • Location (as country/city bases)

Any other information that you decide to supply/provide us

  • To provide Panorays’ services

 

  • To give you access to Panorays’ Platform

 

  • To enjoy features available to registered users only

 

To allow you to communicate with other users of the Platform

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 you with Panorays’ services).

 

3rd party platforms such as for the following purposes:

 

  • Google (Cloud)
  • Mongo DB (Managed service)
  • Gsuite (Google emailing services)
  • SendGrid (Emails from the Platform)
  • ZendDesk (Customer support)

 

 

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot provide you with the services

 

Cannot give you access to Panorays’ Platform

 

Cannot enjoy features available to registered users only

 

Cannot allow you to communicate with other users of the Platform

           

When you are a vendor and you enter with your guest/anonymous account

  • Business email
  • Password
  • IP address
  • Location (as country/city bases)

Any other information that you decide to supply/provide us

To give you access to Panorays’ Platform

 

 

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 give you access to Panorays’ Platform).

 

3rd party platforms such as for the following purposes:

 

  • Google (Cloud)
  • Mongo DB (Managed service)
  • Gsuite (Google emailing services)
  • SendGrid (Emails from the Platform)
  • ZendDesk (Customer support)

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot give you access to Panorays’ Platform

When you attend a marketing event and provide Personal Data

  • Full name
  • Company name
  • Email address
  • Phone number
  • Any other data you decide to provide/supply

 

 

  • To establish a business connection
  • To send you marketing communications

 

 

Consent

 

Legitimate interest (e.g. to send you more information about Panorays)

 

 

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot establish a business connection

 

Cannot send you marketing communications

 

When you exchange business cards with us

  • Full name
  • Company name
  • Email address
  • Phone number
  • Any other data you decide to provide/supply

 

 

  • To establish a business connection
  • To send you marketing communications

 

 

Consent

 

Legitimate interest (e.g. to send you more information about Panorays)

 

 

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot establish a business connection

 

Cannot send you marketing communications

 

When we acquire your Personal Data from third-party sources (such as lead-generation companies)

Contact details (e.g., email address)

 

  • To establish a business connection
  • To send you marketing communications

 

 

Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot establish a business connection

 

Cannot send you marketing communications

 

When we use the Personal Data of our customers

  • Full name
  • Company name
  • Job title
  • Business address
  • Phone number
  • Payment information
  • Any other data you decide to provide/supply

 

 

  • To provide our services

 

  • To perform the applicable agreement

 

  • To communicate with our customers/clients

 

 

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:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)
  • DocuSign (digital signatures)

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot provide the services

 

Cannot perform the agreement

 

Cannot communicate with you

 

  • Full name
  • Business address
  • To send you product updates and marketing communications

Depending on the context, legitimate interest (B2B marketing) or consent

3rd party platforms such as for the following purposes:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot send you product updates and marketing communications

When we use the personal data of our resellers, distributors, agents and/or finders (e.g. contact details)

  • Full name
  • Company name
  • Email address
  • Phone number
  • Any other data you decide to provide/supply

 

 

  • To contact our reseller, distributors, agents and/or finders

 

  • To perform/execute the applicable agreement

 

  • To send you updates and information about Panorays’ for you to share with the potential customers

 

 

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:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)
  • DocuSign (digital signatures)

 

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot contact our reseller, distributors, agents and/or finders

 

Cannot perform the applicable agreement

 

Cannot send you updates and information about Panorays’ for you to share with the potential customers

 

When we use the personal data of our service providers

  • Full name
  • Company name
  • Email address
  • Phone number
  • Any other data you decide to provide/supply

 

 

  • 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:

 

  • HubSpot (Marketing automation)
  • SalesForce (Sales  automation)
  • SalesLoft (Sales  automation)
  • Gsuite (Google emailing services)
  • DocuSign (digital signatures)

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot contact our service providers and suppliers

 

Cannot perform the  applicable agreement

 

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

  • Full name
  • Email
  • Phone number
  • Company name
  • Job title
  • Social media profiles
  • Any other information you choose to share with us

 

 

  • To reply and/or respond to your request or question
  • To establish a business connection

Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent

3rd party platforms such as for the following purposes:

 

  • LinkedIn (social media channel)

 

 

Your Personal Data will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cannot reply or respond to your request

 

Cannot establish a business connection

 

 

 

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. HOW WE PROTECT AND RETAIN YOUR INFORMATION 

 

  1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised 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 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. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookie policy.

 

  1.  HOW WE SHARE YOUR PERSONAL DATA

 

In addition to the recipients described above, we may share your personal data as follows:

 

  1. 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;
  2. 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;
  3. 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
  4. 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 the current recipients of your personal data, please make your request by contacting us to [email protected] .

 

  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

 

  1. Storage: Google Cloud, with servers in Belgium, and GSuite, with servers in US.

 

  1. 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 .

 

  1. Access from US: Access from US is covered by Panorays’ privacy shield certification.

 

  1. Internal transfers: Transfers within the Panorays group will be covered by an internal processing agreement entered into by members of the Panorays group (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.  

 

  1. External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with 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.

 

  1. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

 

  1. 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 [email protected]. 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.

  1. Deleting your account: Should you ever decide to delete your account, you may do so by emailing [email protected]  or [email protected]. 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 products or 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 [email protected].

  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 use 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 personal 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/.
  • Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.
  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/  choices or http://www.youronlinechoices.eu/.

Google Signals. The Website uses a tool called “Google Signals” to collect information about use of the Website. When we activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856/). Audiences that we create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross device-eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about users who have turned on Ads Personalization, base across device types and on aggregated data from users who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your Personal Data is used to make ads more relevant to you, and turn on or off certain advertising services in the Ads Personalization link above. We reserve the right to remove or add new analytic tools.

  1. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
  1. 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 [email protected]. Please note that we will respond to one request per customer each year, unless otherwise required by law.
  2. Our California Do Not Track Notice: We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, 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.
  3. 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. AUTOMATED COLLECTION OF PERSONAL DATA


Panorays uses different automated technologies to process data from third party sources to help us detect security gaps, malware, activities and illegal activities. To the extent Panorays is considered a controller and such practices are deemed to be subject to the GDPR, please note that we do not provide a specific notification to data subjects because we believe that an exception of Article 14 of the GDPR would apply. In particular, providing information to a potential fraudster or a person with malicious intent to a company. For the same reason, we cannot obtain the consent of the person in question and legitimate interest is the most appropriate legal basis (Recital 47 of the GDPR). However, we have included this paragraph in our privacy policy to inform, in a generic manner, that these practices happen. For avoidance of doubt, we are not selling or sharing this information with any third party.  

  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 [email protected].

 

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