EFFECTIVE: January 15, 2019
1.1 About Us. We (also "CommuniTake", "our" or "us") build security, productivity, and management solutions to guarantee the highest level of mobile security for individuals and organizations. We are headquartered at Yokneam Star Building, High-Tech Park,
Yokneam, Israel 2069205.
We have appointed a Data Protection Officer who is accountable for our personal data management practices. Our Data Protection Officer is Mr. Eran Karpen. If required, please contact us using the following link: email@example.com.
1.2 Basics. We respect your privacy and are committed to protecting it. We recognize the need for appropriate protection and management of information we learn about visitors of our website, (together with the other websites we may own and control), (the “Websites”), and our customers who use the tools and services offered by CommuniTake (the “Service”). “Services” means any service offered by us, including, inter alia, CommuniTake Intact solution or its sub-components, Total Care solution or its sub-components, CommuniTake Enterprise Mobility solution or its sub-components, Machine Care solution or its sub-components, CommuniTake InStore solution and any sub-services/offerings that are derived from it.
1.4 Your use of the CommuniTake Websites and the Service indicates your consent to the Policy.
2. Which data do we gather?
2.1 Performance Data. We collect encoded or anonymized information or aggregated data about a group or category of services, features or users which does not contain personally identifying information. “Performance Data” information may include parameters such as action ID, action start and end times, system user ID, MSISDN, IMEI, IMSI, diagnostics fetched from the device, device type, and the number of key presses. An anonymization process prevents the information from being re-associated or identified with any one customer account, user, or individual.
2.2 Usage Data. We collect information automatically through your use of the Service (“Usage Data”). We collect information about your mobile devices, how you use our Service and your actions in the Service, including, what software and hardware you use (such as, mobile device identifiers such as make and model, mobile carrier, operating systems, on-device applications), features of Service used and associated dates and timestamps, and other statistics related to your usage of the Services. This data collection is a contractual necessity in order to fulfill the declared capabilities of our Services for central monitoring and policy enforcement over connected devices and for remote assistance from afar. In some cases, we may collect limited location information. For example, we may use our software products to identify your device location to operate contractual obligations related to the software operation such as geofencing use policy and dropped calls tracking or we may use Google Analytics convert your IP address into a rough geolocation to understand in what areas our users are located and to improve and personalize CommuniTake.
We may also use tools, including third-party tools, to collect analytics data. Some of this information is collected through the use of "cookies" and other tracking technologies, such as web beacons, session replay scripts, and similar technologies ("tracking technologies"). We may also work with third-party partners to employ tracking technologies.
Our access capabilities to Usage Information through your use of our Services are automatically terminated once you are excluded from being part of our Services by you or by a system administrator.
2.3 Personal Information
2.3.3 Account and Registration Information
We are committed to limiting our collection of your information to only what is necessary to provide you with the Service in accordance with applicable data protection and privacy laws.
We only collect Personal Information if it was voluntarily given to us by you and or by an administrator for the entity or organization with which you are affiliated (“Administrator”) to represent Account and Registration Information. Account and Registration Information may include identifiable information, such as your name, email address, gender, postal address, and phone number. It also may include payment information, such as payment method, credit card information, and any contact information (such as name and postal address) associated with payment billing information. When you create an account with our Service, we may collect certain Personal Information directly from you or, if you create your account using an Administrator and or a third-party service, we may collect Personal Information about you from the Administrator and or the third-party service. By choosing to create an account using a third-party service, you authorize us to collect Personal Information necessary to authenticate your account with the third-party service provider. We also ask for and collect Personal Information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account. By voluntarily providing us with Account and Registration Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us.
We may use the Account and Registration Information to (a) process and complete transactions, and send you related information, including purchase confirmations and invoices; (b) send transactional messages, including responses to your comments, questions, and requests; (c) provide customer service and support; (d) send you technical notices, updates, security alerts, and support and administrative messages; (e) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; and (e) for other purposes for which we obtain your consent.
2.3.4 Secure Communications Data
Secure Instant Communications. Secure voice calls and chats operate through end-to-end or midway encryption. In end-to-end encrypted instant communications, all data is encrypted with a key that only you and the recipient know.
Content in Secure Chats. The Service allows you to share files you have on your device. We encrypt and store shared photos, videos, and documents from your cloud chats on our servers prior to their opening by the recipient. Once opened by the recipient, the content is removed from the servers and keeps residing only on users’ devices. Depending on the settings of a shared file, it may be downloaded locally on user devices.
Recorded Instant Communications. The Service allows an Administrator to activate recording of the secure instant communications for the entity or organization with which you are affiliated for regulatory or other purposes. We encrypt and store cloud Recordings data. This data is stored in our servers with a key known only to the Administrator. We have no ways of deciphering the actual information.
3. Information We Do Not Collect
3.1 Secure Instant Communications. We do not store or retain the actual content of any secure chat and voice communications. We cannot decrypt any information regarding the content of secure messages and voice communications.
3.2 Personal Information. We do not collect Personal Data that was not voluntarily provided to us by you or by the Administrator.
3.3 Children’s Personal Information. CommuniTake does not knowingly collect any Personal Information from children under the age of 13.
4. How do we collect Usage Data and Personal Information?
4.1 Directly – when you provide information or contact us; and
4.2 Indirectly – through our Websites’ "cookies" technology and other tracking technologies, such as web beacons, session replay scripts, and similar technologies, collecting, for example, your IP address, the pages you view, your operating system and browser type.
4.3. Indirectly – through our mobile security tools, care tools, and mobility management tools, for example, the applications you use, the URLs you navigate to, and your communications usage levels.
5. When we collect information?
We may collect information from you when you:
5.2 Create or register an account, and when you administer your account.
5.3 Input information or data into any of our Services, or post or upload content to our Services.
5.4 Submit questions, requests, and other communications to us via forms, email, or other communication media.
5.5 Contact us for customer support or technical support.
5.6 Visit any of our websites or download any of our apps.
5.7 Participate in any promotions, demonstrations, contests, surveys, or other marketing events.
5.8 Integrate third-party products and services with your CommuniTake account.
6. Why do we collect Usage Data and Personal Information?
We use the information we collect for a variety of purposes, and how we use it depends on what we collect and what Service you use (or features of the Service). These purposes may include:
6.1 We collect and analyze Usage Data in order to determine what is most effective about our Websites, and to help us understand trends in the usage of the Service so that we can better consider how to improve it and make it more effective.
6.2 We use Personal Information to provide you with the information you request and for other purposes which we describe to you at the point where it is collected or which will be obvious to you.
6.3 We use Personal Information to provide you the Service you request in regards to mobility, care, and security, including securing the Services and our systems and protecting your information and data.
6.4 We may also use the Personal Information you provide to operate the Service and tailor it to your needs, for billing, identification and authentication, to contact and communicate with you about the Service and your use of the Service, send you marketing materials (subject to your opt-out option), product updates, information about products you have requested or purchased, for research purposes, and to generally improve the content and functionality of the Service.
6.5 We may also use the Personal Information you provide to respond to requests or inquiries from you or provide customer support or technical assistance.
6.6 We may also use the Personal Information you provide to derive market insights, ways to improve the Service, and other business analysis or research purposes, customize existing and future product offerings and other aspects of the Services to you and other users.
6.7 We may also use the Personal Information you provide for any legitimate business purpose, provided that the information is aggregated and anonymized.
7. Inspecting, correcting and deleting your information.
You may exercise rights with respect to your information:
7.1 Right to access your information. You can request a copy of your information which we hold. If you would like a copy of some or all of your information in a structured, commonly used format, please email us or write to us, provide proof of your identity, and identify the information you want a copy of.
7.2 Right to modify your information. You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please email us or write to us, provide proof of your identity, and clearly indicate the information that is incorrect and what it should be replaced with.
7.3 Right to be forgotten. You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please email us or write to us, provide proof of your identity, and clearly indicate your request and the acceptable way in which we may contact you in the future. If you do, personal information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law.
7.4 CommuniTake has no direct relationship with the individuals with whom our customers may interact using the Service. Any such individual seeking access to, or who would like to correct, amend, or delete data which may be stored in the Service should direct his/her query to the applicable CommuniTake customer acting as the “data controller” for such information.
8. Protection of Information.
7.1.1 Except as described in this Policy, CommuniTake will not sell, trade, or disclose to any third parties Usage Data and Personal Information derived from the use of the Service or visiting the CommuniTake Websites.
7.1.2 Notwithstanding the above, we may share Usage Data with third parties, including our customers, partners, and service providers, for various purposes, including helping us better understand our customers’ needs and improve the Service as well as for advertising and marketing purposes. We do not share Usage Data with third parties in a way that would enable them to identify you personally.
7.1.3 Notwithstanding the above, we may also transfer Personal Information to our contracted service providers who are sometimes located in other countries. For example, we may share your Personal Information with our third-party service providers (such as its credit card processors and hosting partners) to provide the necessary hardware, software, networking, storage, and other services we use to operate the Service and maintain a high-quality user experience. In the event that we transfer Personal Information, we ensure your Personal Information is sufficiently protected in accordance with law and our internal policies.
7.1.4 In addition, certain exceptions may apply, including if the disclosure is required by law, if it is necessary to protect the rights, property, or safety of CommuniTake, our client or third parties, if the Personal Information is publicly available, or if the disclosure is reasonably necessary.
We have implemented appropriate security features as well as internal policies to protect Personal Information from unauthorized access or improper use, which we will continue to do as new technology becomes available. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Unfortunately, no company can fully eliminate the risks of destruction, loss, alteration, unauthorized disclosure of, or access to information it collects and stores. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit personal information to us using our website if you consider that information to be sensitive.
8.3 Data Integrity.
We periodically confirm that the Policy complies with the relevant privacy laws.
9. Applicability of the Policy.
8.1 This Policy only applies to Usage Data and Personal Information collected by us and for our use.
8.2 The Policy does not cover the data processing in any cloud service, even if we manage it. The cloud provider’s privacy policies apply.
8.3 You acknowledge that by providing us the information we will not be in breach of Israeli protection of privacy laws.
8.4 Our Websites may contain links to other websites and web applications that are not owned or controlled by CommuniTake. Please be aware that we do not determine and we are not responsible for the privacy practices or content of such other sites. We encourage you to be aware when you leave our Web sites and read the privacy statements of other websites and web applications linked to our Websites.
11. Web Beacons.
We also may employ web beacons. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of internet users. Unlike cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on websites. We tie the information gathered by web beacons to information we otherwise collect and use them in our emails to learn which emails have been opened by recipients. This allows us to gauge the effectiveness of our marketing campaigns as well as to operate and improve our service. You cannot remove these tracking technologies as they form part of the content of web pages. However, as they work together with cookies, by turning off cookies you will also prevent any web beacons from tracking your user activity on our Websites. That is, even though the web beacon will still account for anonymous visits, your information will not be recorded.
12. Targeted emails.
11.1 We may send targeted emails to our customers and other individuals and companies which often include web beacons, cookies, and other technologies that let us know if you open, read, or delete our email and whether you click on a link.
11.2 If you click on a link from an email you receive from us, we will also use a cookie to log what pages you view and what content you download from our Websites.
11.3 You may choose to opt out of advertising emails but not service-related emails and other communications.
13. Public Forums.
The Service (including the CommuniTake Websites) may offer publicly-accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
14. International transfers of Personal Information.
CommuniTake complies with the transfer of data regulations as set forth by local privacy laws regarding the collection, use, retention and transfer of Personal Information outside of Israel. You are responsible for compliance concerning data you process in any cloud service, even if you ask us to upload it to any cloud service on your behalf.
15. Changes to this Policy.
We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of our Websites and the Service constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue visiting our Websites and using the Service.
16. Customer Testimonials/Comments/Reviews.
From time to time, we may post customer testimonials on our Websites which may contain Personal Information. We obtain the customers’ consent to post their names along with their testimonials.
17. Business Transactions.
CommuniTake may assign or transfer this Policy, and your user account and related information and data, including any Personal Information, to any person or entity that acquires all or substantially all of the business, stock or assets of, or is merged with CommuniTake.
18. Governing Law.
Our Service and Websites are controlled and operated by CommuniTake Technologies from Israel. This Policy shall be governed by and construed in accordance with the laws of Israel.
19. Contact Us.
If you have questions regarding this Policy or about the privacy practices of CommuniTake, or to report a privacy concern, please contact us by email at , or at:
CommuniTake Technologies, Inc.
Attn: Privacy Officer
Yokneam Star Building, High-Tech Park
Yokneam Israel 2069205