Privacy Policy

BY OPENING AN ACCOUNT AT, USING OR SUBSCRIBING TO GETCTRL LTD.'S ("CTRL" OR "WE") PROPRIETARY SOLUTION (“SOLUTION”) YOU ("YOU") CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND CONSENT THAT ALL PERSONALLY IDENTIFIABLE INFORMATION ("PII") THAT YOU SUBMIT OR THAT IS PROCESSED OR COLLECTED THROUGH THE SOLUTION MAY BE PROCESSED BY CTRL AND ITS AFFILIATES IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THE FOLLOWING PRIVACY POLICY.

WE DEFINE “PII” TO MEAN ANY INFORMATION RELATING TO AN IDENTIFIED OR IDENTIFIABLE NATURAL PERSON; AN IDENTIFIABLE NATURAL PERSON IS ONE WHO CAN BE IDENTIFIED, DIRECTLY OR INDIRECTLY, IN PARTICULAR BY REFERENCE TO AN IDENTIFIER SUCH AS A NAME, AN IDENTIFICATION NUMBER, LOCATION DATA, AN ONLINE IDENTIFIER OR TO ONE OR MORE FACTORS SPECIFIC TO THE PHYSICAL, PHYSIOLOGICAL, GENETIC, MENTAL, ECONOMIC, CULTURAL OR SOCIAL IDENTITY OF THAT NATURAL PERSON.

YOU ARE NOT LEGALLY REQUIRED TO PROVIDE US WITH PII, HOWEVER, SOME OF THE SOLUTIONS REQUIRE YOU TO DO SO PURSUANT TO THIS PRIVACY POLICY. IN THESE CASES, IF YOU CHOOSE TO WITHHOLD ANY PII REQUESTED BY US, IT MAY NOT BE POSSIBLE FOR YOU TO ACCESS CERTAIN ASPECTS OF THE SOLUTION. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN PLEASE DO NOT USE THE SOLUTION.

We recognize that privacy is important. This Privacy Policy applies to all of the information, tools, features and functionality available through the solution as offered by CTRL or its subsidiaries or affiliated companies and covers how PII that CTRL collects and receives. If you have any questions about this Privacy Policy, please feel free to contact us at: info@getctrl.co.

Please also read the CTRL's Terms of Service which describe the terms under which you use our Services which describe the terms governing the processing of personal data provided by users of the Services.

1. Information We Collect and How We Use It. In order to provide and improve our SOLUTION, we may collect and process PII, including the following types of information:

1.1. Information You Provide. For registration purposes, for example for purpose of providing you with a demo to our Services or opening an account, we ask you for personal information, including, without limitation your name, your professional affiliation details including address, email and phone numbers.

1.2. User Communications. When you send email or other communication to CTRL, we may retain those communications in order to process your inquiries, respond to your requests and improve our Solution.

1.3. Third Parties. We sometimes supplement the information that you provide with information that is received from third parties actively permitted or added by you through the API integrated to our services made available through the Solution (for example, Google, Asana, Salesforce, etc.). You will consent to the integration of such API on an individual basis. Ctrl's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

1.4. User Information. When you use the Solution, we may automatically receive and record information from your browser or device, including without limitation information and statistics about your online/offline status, your IP address, internet service provider, pages visited, date and duration of the visit, search history, type of browser, your regional and language settings and software and hardware attributes. Our systems may automatically record and store technical information regarding the method and nature of your use of the Solution. An IP address is a numeric code that identifies your browser on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. CTRL uses such PII in order to understand the usage trends of our SOLUTION and improve it.

1.5. Aggregate and Analytical Data. In an ongoing effort to better understand and serve the customers of the Solution, we often conduct research on its customer demographics, interests and behavior based on the PII and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes. We also use aggregate data for monetization.

2. Cookies. In order to collect the data described herein we may use temporary cookies that remain on your browser for a limited period of time. We may also use persistent cookies that remain on your browser until it is closed, in order to manage and maintain the Solution and record your use of the Solution. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your browser. Cookies do not damage your browser. Most browsers may allow you to block cookies but you may not be able to use some features on the Solution if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not). We may also use web beacons via the Solution to collect information. Web beacons or "gifs", are electronic images that may be used in our SOLUTION or in our emails. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon.

We may use remarketing services to inform you of new programs, blogs and opportunities by placing ads on third party web sites to you. We and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service.

3. Links. Links to other services, sites and applications may be provided by CTRL as a convenience to our users. CTRL is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. This Privacy Policy applies solely to PII collected by us.

4. Children. If you are a child under the age of 18, you must obtain parental consent prior to using our Solution. CTRL will not knowingly contact or CTRL with children under the age of 18 without said parental consent. If you have reason to believe that a child has provided us with their PII, please contact us at the address given above and we will endeavor to delete that PII from our databases.

5. Information Sharing. As part of providing the Solution our affiliates, agents and representatives may have access to your PII. We require these parties to process such information in compliance with this Privacy Policy and subject to security and other appropriate confidentiality safeguards. CTRL may also share PII in the following circumstances: (a) as required for the provision, maintenance and improvement of the Solution, including with our service providers providing hosting and storage services (e.g. Amazon EU, FullStory services on Google Cloud platforms, U.S. and Sentry, U.S. which may be updated by the CTRL from time to time); (b) if we become involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of our assets, with any type of entity, whether public, private, foreign or local; and/or (c) to satisfy applicable law or prevention of fraud or harm or to enforce applicable agreements and/or their terms, including investigation of potential violations thereof. Where we transfer PII of data subjects pursuant to the provisions of the GDPR outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your PII. CTRL transfers such PII only pursuant to an Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), or by relying on the Standard Contractual Clauses issued by the European Commission.

6. Information Security. We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. We retain your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

7. Data Integrity. CTRL processes PII only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service agreements. We review our data collection, storage and processing practices to ensure that we only collect, store and process the PII needed to provide or improve our Solution. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this Privacy Policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.

8. Your Rights.

8.1. Right of Access and Rectification. You have the right to know what PII we collect about you and to ensure that such data is accurate and relevant for the purposes for which we collected it. We allow our users the option to access and obtain a copy of their PII and to rectify such PII if it is not accurate, complete or updated. However we may first ask you to provide us certain credentials to permit us to identify your PII.

8.2. Right to Delete PII or Restrict Processing. You have the right to delete your PII or restrict its processing. We may postpone or deny your request if your PII is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.

8.3. Right to Withdraw Consent. You have the right to withdraw your consent to the processing of your PII. Exercising this right will not affect the lawfulness of processing your PII based on your consent before its withdrawal.

8.4. Right of Data Portability. Where technically feasible, you have the right to ask to transfer your PII in accordance with your right to data portability.

8.5. You may exercise the above rights by sending a request to info@getctrl.co.

8.6. Right to Request Information on Transfers. You have the right to request certain details of the basis on which your PII is transferred outside the European Economic Area. Please be aware that certain information relating to such transfers may be partially redacted or restricted due to data transfer agreements or reasons relating to commercial confidentiality.

8.7. Right to Lodge Complaint. You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your PII.

9. Enforcement. CTRL regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of PII by contacting us as provided above. When we receive formal written complaints it is CTRL's policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between CTRL and an individual.

10. Changes to This Privacy Policy. CTRL may update this Privacy Policy. We will notify you about significant changes in the way we treat PII by placing a prominent notice on the SOLUTION. We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices.

11. Consent To Processing. By providing any PII to us pursuant to this Privacy Policy, all users, including, without limitation, users in the United States, Israel and member states of the European Union, fully understand and unambiguously consent to this Privacy Policy and to the collection and processing of such PII abroad. The server on which the Solution is hosted and/or through which the Solution is processed may be outside the country from which you access the Solution and may be outside your country of residence. Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country. By submitting your PII through the Solution, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your PII as described in this Privacy Policy. You hereby acknowledge that your consent is provided at your volition and not due to a legal obligation.

12. Your California Privacy Rights and Do Not Track Notices. California Civil Code Section 1798.83 permits customers of CTRL who are California residents to request certain information regarding its disclosure of PII to third parties for their direct marketing purposes. To make such a request, please send an email to info@getctrl.co. Please note that we are only required to respond to one request per customer each year. You are also advised that CTRL does not respond to “Do Not Track” signals.

13. Questions. If you have any questions about this Privacy Policy or concerns about the way we process your PII, please contact us at info@getctrl.co.

Last Date Updated: January 20, 2022.

‍