Privacy Policy

 

Last Revised: April 22, 2019

 

Eybna Technologies Ltd., (“Eybna” or  “we” or “us” or “our”) is committed to protecting the privacy of those who visit its websites at https://www.wingman.co.il https://www.wingmanblends.com https://www.wingmanblends.es https://www.wingmanblends.de (the “B2C Site”) and/or at https://www.eybna.com (the “B2B Site” and together with the B2C Site, the “Sites” or as may otherwise be available from time to time) and of those who register for the Services and/or purchase the Products, as such terms are defined in our Terms of Use posted on each of the Sites.

A user shall be either: (i) an individual purchasing product/s on the B2C Site; or (ii) a business purchasing products on the B2B Site  (collectively, “you” or the “Users”).

 

The Privacy Policy also describes how we use and disclose such information and the measures we implement in order to maintain and protect your information. For the purposes of EU data protection laws (if applicable) and unless otherwise stated, we are the “data controller” and we are responsible for the processing and storage of your Personal Information (as defined below). You can find our contact details below.

 

  • The Information We Collect and How We Collect It

 

We may collect Personal Information and non-Personal Information. Personal information is information by which an individual may be personally identified, including name, address, e-mail address, telephone number or any other information that is defined as “Personal Information”, “Personal Data”, or “Personally Identifiable Information” under applicable law (“Personal Information”).

In order to use the Services, you will be required to create an account on our Sites (“Account”).  Upon creating the Account and/or using the Services and/or contacting us with feedback or queries, you may provide us with the following Personal Information:

  1. Contact information (name, email address, shipping address and telephone number) and other corporate identification information (such as company tax number or registration number) as shall be explicitly requested and actively provided by yourself.
  2. Login credentials to create an Account on the Sites (including email address and password).
  3. Payment Information to be collected by third party payment services (such as PayPal). This information is no available to us and shall be retained and processed by the payment service provider under its own privacy policy. The provision of information to the payment service providers shall be governed under the agreement you execute with such provider. We may only be provided with the necessary information to confirm payment (such as a token, identifiers etc.).
  4. Personal Information contained in content you submit through our “Contact Us” feature or other customer support tools on the Sites;

We also gather and process Non-Personal data. Such Non-personal data does not and may not relate or refer to any specific individual, and we therefore do not regard it as “Personal Data” and may use it without restriction, for example to aggregate data for industry benchmarks or comparative performance metrics, that we might publish from time to time.

 

  • Why Are We Collecting and Processing Information?

 

We use your Personal Data as necessary for providing our Sites and our products (the “Services“), for complying with applicable law, and based on our legitimate interests in maintaining, improving and advertising our Services and offerings, understanding how our Services are used or how our Users would like to use them, using more effective marketing and advertising strategies and methods, improving our client service and support operations, and protecting and securing our Services, ourselves and our Site visitors, clients, inventors and prospects.

Accordingly, we use Personal Data for the following purposes only:

– To facilitate, operate, and provide our Services;

– To authenticate the identity of our Users;

– To provide customer care, assistance and professional support;

– To further develop, customize and improve the Services, and to improve your user experience, based on common or personal preferences, experiences and difficulties;

– To enable and receive payment for our Services;

– To facilitate and improve our and our business partners’ marketing and advertising strategies and practices, and make them more effective;

– To send communications or otherwise make contact with general or personalized service-related notices, informational materials and promotional messages, in accordance with this policy only, and to facilitate, sponsor and offer certain events and promotions;

– To manage and assess risk, support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;

– To monitor aggregate metrics and create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data, which we or our business partners may use to provide and improve our respective services and offerings;

– To act as permitted by, and to comply with, any legal or regulatory requirements; and

– To conduct any additional activities that may require the use of your Personal Data, for which we will request your specific approval in advance.

In addition, we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. You will not be able to opt-out from receiving such service communications.

Notifications and Promotional Communications: we may also send you, based on your consent, notifications about new features, offerings and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. mobile push notifications or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. This communication may or may not be based on your chrematistics (i.e. based on your profile including your gender, location, previous purchases, your behavior on our Sites and your previous behavior when receiving marketing materials from us). If possible, under your applicable law, you hereby consent to sending such communication. If you do not wish to receive such promotional communications, you may notify us at any time by e-mailing us at info@eybna.com or by following the “unsubscribe”, “stop”, “opt out”, or “change e-mail preferences” instructions contained in each of the promotional communications you receive. Subject to certain limits under California law, California residents may ask us to provide them with: (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes and (2) the identity of those third parties. Please contact us if you wish us to send you this information (subject to identification process and applicable law). 

 

  • Sharing Information with Third Parties

 

Only the people who need to process personal data for the purposes mentioned above have access to your personal data under a confidentiality obligation. We may share or otherwise disclose your Personal Data for the following reasons:

Legal Compliance: We may disclose or allow government and law enforcement officials access to Personal Data, in response to a subpoena, search warrant, court order or similar requirement, or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Service Providers: We may engage selected third parties to perform services complementary to our own (namely, hosting services, data analytics services, marketing and advertising services, data and cyber security services, payment processing services, user engagement services, IT support, e-mail distribution and monitoring services, session recording, and our business, legal and financial advisors) (collectively, “Service Providers”). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes. You can see the add-ons used by the Site in your browser settings. We use Pay-Pal to process your payments (privacy policy available here: https://www.paypal.com/en/webapps/mpp/ua/privacy-full), Pipedrive as a CRM service (privacy policy available here: https://www.pipedrive.com/en/privacy) and wordpress.

Google Analytics: We also use a tool called “Google Analytics” to collect information about use of our Services. Google Analytics collects information such as how often users visit the Services, what pages they visit when they do so, and what other sites they used prior to coming to our Services. We use the information we get from Google Analytics to maintain and improve the Services and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service, available at https://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at https://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at https://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/.

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of the Company, any of our Users or any members of the general public. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Eybna’s Subsidiaries, Affiliated Companies and M&A: We may share Personal Data internally within our group for the purposes described in this Privacy Policy. In addition, should Eybna or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services

Please note: Eybna may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

 

  • International Data Transfers

 

Data Location: Your Personal Data may be maintained, processed and stored by us and our authorized affiliates and Service Providers in various locations, as necessary for the proper delivery of our Services, or as may be required by law.

Eybna is headquartered in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.

While privacy laws may vary between jurisdictions, Eybna and its affiliates are committed to protect Personal Data in accordance with this Privacy Policy and with industry standards, regardless of any lesser legal requirements that may apply.

Data Retention: We retain your Personal Data in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our User and have not notified us otherwise. We will also retain your Personal Data further for legal and accounting purposes (i.e., as required by laws applicable to record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), for up to seven years. If you have any questions about our data retention policy, please contact us at info@eybna.com.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.

 

  • User Rights

 

You may have a legal right under certain applicable laws (for instance if you are an E.U. resident) to request to:

5.1 Receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information.

5.2 Receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.

5.3 Rectify your Personal Information.

5.4 Erase your Personal Information

5.5 Object to the processing of Personal Information by us.

5.6 Restrict processing of your Personal Information by us.

5.7 Right to withdraw consent (this will not affect the lawfulness of any processing activities carried out based on your consent before its withdrawal)

5.8 Lodge a complaint with a supervisory authority.

Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. so we have proof of the identity of the person submitting the request), in accordance with the above.

In addition, please note that such rights (if any) are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Personal Data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

 

  • Security

 

We implement physical, administrative and technical safeguards designed to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destructions. These safe guards include encryption means when appropriate. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide us at all times.

 

  • Cookies & Passive Collection

 

When you access or use the Site, Company may use industry-wide technologies such as “cookies” or similar technologies (web beacons etc.), which stores certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your Site experience much more convenient and effortless. The cookies used by the Service are created per session and do not include any information about you, other than your session key (usually removed as your session ends but sometimes can be kept in your device for no more than 6 months) and the ability to login again quickly. While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser and recommend their use for an optimal experience of our Services, most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience with the Site may be limited. If you only disable third party cookies, you will not be prevented from making purchases on our sites. If you disable all cookies, you will be unable to use our Services. We use Cookies and other technologies on the basis that using them is in our legitimate interests (where we have considered that these are not overridden by your rights). Demisto uses secured Cookies. That means a cookie with a secured flag which can only be transmitted over an encrypted connection. This makes the cookie less likely to be exposed to cookie theft via eavesdropping. We use the following types of Cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our Site and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our Site.

Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognize you when you return to our Site. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Except for essential cookies, some cookies used on our site may expire after the session ends and some may be retained for a longer period of time as can be seen in the cookie section in your browser.

 

  • Third Party Websites

 

While using the Service you may encounter links to third party websites. Please be advised that such third party websites are independent from the Service, and we assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites. We encourage you to carefully read the privacy policies and the terms of use of such websites.

 

  • Children’s Privacy

 

Our Services are not designed to attract children under the age of 18. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us regarding to such child. If you believe that we might have any such data, please contact us.

 

  • Changes to the Privacy Policy

 

The terms of this Privacy Policy will govern the information collected upon visiting the Sites and purchasing Products on the Sites. We reserve the right to change this policy at any time, so please re-visit this page frequently. Subject to applicable law, in case of any material change, we will make reasonable efforts to post a clear notice on the Sites.

 

Changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

 

  • Have any Questions?

 

If you have questions or concerns regarding this Privacy Policy, you are welcome to send us an email or otherwise contact us at the following address: 

VIA EMAIL

info@eybna.com.

IN WRITING:

Eybna Technologies Ltd.

Address:

Eybna US Office
156 2nd St, San Francisco
CA 94105, USA

Eybna Israel Office
23 Pa’amei Aviv St, Givat Hen
43905 Israel

 

E.U. citizens have the right to lodge a complaint with a supervisory authority (Data Protection Authority in your jurisdiction) in case of a breach of any E.U. data protection and privacy regulations. If the supervisory authority fails to deal with a complaint or inform you within the time frame set under applicable law, you have the right to an effective judicial remedy.