Last Updated: July 2, 2023
(i) When you browse or visit our website, https://www.statement.io/ (“Website”);
(ii) When you make use of, or interact with, our Website
(iii) When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data
(iv) When we acquire your Personal Data from third-party sources (such as lead-generation companies)
(v) When we use the Personal Data of our customers (e.g. contact details)
(vi) When we use the Personal Data of our service providers (e.g. contact details)
(vii) When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
Table of contents:
1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. 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 or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “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).
2. HOW WE PROTECT AND RETAIN YOUR INFORMATION
2.1 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.
3. HOW WE SHARE YOUR PERSONAL DATA
We may share your Personal Data as follows:
3.1 - We may also share information with our affiliated companies about you.
3.2 - We may use third party service providers to process your information for the purposes outlined above, including, without limitation:
3.2.1 - With cloud service providers for hosting purposes;
3.2.2 - With websites and web content creation platforms in order to help us manage our Website;
3.2.3 - With email providers, marketing, CRM, other similar tool providers; and
3.2.4 - With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.
3.3 - To the extent necessary, with regulators, courts, banks 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, as well as for internal compliance procedures and to protect the safety, security, and integrity of Statement, our services, customers, employees, property, and the public..
3.4 - 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 information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). 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 information in connection with the foregoing events.
3.5 - Where you have otherwise provided your consent to us for sharing or transferring your information.
If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to firstname.lastname@example.org.
4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
4.1 - Storage: We store the Personal Data with the following storing companies: Amazon Web Services (AWS) with servers located in Frankfurt, Germany..
4.2 - Internal transfers: Transfers within Statement will be covered by an internal processing agreement entered into by members of the Statement group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.
4.3 - External transfers: Where we transfer your Personal Data 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 Personal Data. When Statement engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. Statement also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.
4.4 - In order to run our business and provide our Website and services to you, we transfer Personal Data to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your Personal Data may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever we make such transfers, we will use commercially reasonable efforts to implement an appropriate level of protection to your Personal Data by implementing at least one of the following safeguards:
4.4.1 - making sure the destination country has been deemed to provide an adequate level of protection for Personal Data; and/or
4.4.2 - by executing implement data onward transfer instruments such as data processing and protection agreements.
5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
5.1 - 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 specific laws):
5.1.1 - You have the right to withdraw consent to the processing, where consent is the basis of processing.
5.1.2 - You have the right to access the personal information that we hold and request further details about how we process it, under certain conditions.
5.1.3 - You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.
5.1.4 - You have the right to object to unlawful data processing under certain conditions.
5.1.5 - You have the right to the erasure of past data about you (your “right to be forgotten”) under certain conditions.
5.1.6 - You have the right to demand that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate.
5.1.7 - You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
5.1.8 - The personal information we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by Titan by contacting Titan directly or by following the instructions through the unsubscribe options in our email messages.
5.2 - You can exercise your rights by contacting us at email@example.com. 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 need 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 requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
5.3 - Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to firstname.lastname@example.org. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.
5.4 - Deleting your account: Should you ever decide to delete your account, you may do so by emailing email@example.com. 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.
6. 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 firstname.lastname@example.org.
7. 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.
8. LOG FILES
We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information
9. COOKIES AND ANALYTIC TOOLS
10. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
10.1 - California Privacy Rights:
California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com. Please note that we are only required to respond to one request per customer each year.
10.2 - Our California Do Not Track Notice (Shine the Light):
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 Website.
11. 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 firstname.lastname@example.org.
Data controller: Statement Ltd. [Shahar Lahav, email@example.com]