Last Revised: February 20th, 2020
K2view Ltd. and its affiliates (“K2view” or “we”) respect the privacy of its website users (“User” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use about you when you use our primary website at http://k2view.com/ (the “Site”). Please read the following carefully to understand K2view’s views and practices regarding your personal information and how K2view will treat it.
Table of Content
2 Who we are
3 Your acknowledgment of this policy
4 Which information may we collect about Users?
5 How do we collect information about our Users?
6 What are the purposes of the collection and processing of information?
7 Sharing Personal Information with Third Parties
8 Your Rights
9 Location of Your Data
11 Third Party Service Providers and Third Party Software
12 Links to Third Party Websites
14 Data Retention
16 Have any Questions?
2. Who we are
In this policy, references to K2view, or to "we" or "us" are to K2view Ltd., which is a registered company in the state of Israel (No. 514314632) at Hayetsira 6, Yokneam, Israel. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at Legal@k2view.com.
3. Your acknowledgment of this policy
4. Which information may we collect about Users?
We collect from Users of our Site, two types of data and information:
4.1. Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).
You may access and browse the Site without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc; and (ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers such as Google Analytics and Hubspot to obtain detailed analytics on the device and the User's behavior on the Site.
When you use this Site, we may collect the following types of personal information on you:
Log data: Our servers automatically record information created by your use of the Site. Such data is collected by server logs and cookies (see explanation in Section 3 below), and may include information such as the date and time of visits to the Site, the pages viewed, time spent at our Site, and the Internet sites visited just before and just after our Site.
Contacting us: If you email or otherwise contact us, we may keep your message, email address and contact information to facilitate communications with you.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Such information does not reveal your identity and therefore is not considered personal data.
4.2. Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:
4.2.1. Personal Information which is provided voluntarily:
- Communications with K2view: Personal Information you provide us as part of any communications with K2view, by any means, including by approaching our customer services or during sales calls (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences).
We may record such calls for quality assurance purposes and in order to improve our services.
- Contact Details: Personal Information is collected from the details the Users provide in the Contact Us, Getting Started, Become a Partner or Press Inquiry Forms on the Site (the "Contact Forms"), which includes, inter alia, the User's full name, country, company/organization name, industry, the User's position in the company/organization, his/her e-mail address and telephone number. The User can optionally provide via the Contact Forms any text he/she wishes to insert into the “message box”. Once your contact details are received by us, our representative will contact you for further communication. Our representative may collect additional Personal Information from you.
4.2.2. Personal Information collected via technology:
- Geolocation data: while using the Site we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes. Please note that we may also analyze your IP address, using our third party service providers, in order to determine the name of the company whose IP address you have used to browse our Site, for the purpose of locating prospects and in order to analyze our Site's traffic.
- Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 3.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
- Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or another unique identifiers.
4.3. Please note:
- We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
5. How do we collect information about our Users?
There are two main methods we use to collect information:
5.1. We collect information through your entry, connection, access and/or use of the Site. In other words, when you access or use the Site we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioral Information.
5.2. We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide via the Contact Forms on our Site. We will inform you prior to collecting your Personal Information if it is requested on a voluntary basis and the consequences of not providing voluntary Personal Information.
5.3. We collect information from public sources. We may supplement personal information that we collect about you with information which you have made public on websites associated with you or your company or on social media platforms such as LinkedIn.
6. What are the purposes of the collection and processing of information?
6.1. Non-personal Information is processed in order to:
- Enhance the User’s experience on the Site;
- Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others); and
- Keep the Site safe and secured and for prevention of fraud.
- Enable the operation of the Site and administer your Account;
- Respond to your inquiry;
- Contact you by telephone and/or by email with further information relating to our products or services which you enquired about via the Site. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you;
- Add your contact details to our mailing list for the purposes of sending you information and commercial materials, updates about K2view’s developments products and services, new offerings, research or news by email, SMS, phone, through web-browser notification or through the post. You have the right to opt-out of marketing messages at any time by following the instructions in such message or by contacting us at: Legal@k2view.com;
- Personalize your experience on the Site;
- Contact Users for marketing and sales purposes;
- Enable us to contact Users for the purpose of providing them with technical assistance and in order to provide them the Services;
- Contact you for the purposes of processing your job application.
- Ensure that content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
- Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
- Keep the Site safe and secured and for prevention of fraud and crime;
- Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site;
- Maintain our data processing records and general administrative purposes;
- The processing of your billing information to complete transactions with you when you purchase our products or services;
Note to our Users in the EU:
In order for K2view to process your Personal Information, as detailed herein, such processing must be justified by a "basis" for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:
- The processing is necessary to comply with a legal obligation - we may process your Personal Information for disclosure of information to authorities; and
- The processing is in our legitimate commercial interests - subject to your interests and fundamental rights, under our legitimate interest in marketing our products and services via the Site and offering the public comfortable and safe access to our Site, we shall perform the Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the Site, assisting us to prevent crime and fraud, manage our internal operations, maintaining records and email tracking. We may also use the information contained in certain cookies and other such files or tags based on such ground for our legitimate interests in a safe and user-friendly presentation of our Site. Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.
Note to non-EU Users:
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.
Note to Users in California:
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.
Sales of Personal Information
In the preceding twelve (12) months, Company had not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to [45/90] days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that 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 us an electronic message through our website or write us at our address listed on our webpage.
Sharing Personal Information with Third Parties
6.3. In addition to using the information collected by us for the purposes described under Section 6 above, we may also share your information in the following cases:
- Local Distributors and Sales Representatives: When you provide us with your contact details via the Site or make certain requests for information about K2View products or services, we may transfer your name and contact information to the local distributor, dealer, reseller or sales representative of K2View products and services that is located close to your location, solely in order to enable us to respond to your request. We identify the nearest distributor, dealer or sales representative using the location that you provided us. Please note that we instruct our local distributors, dealers, resellers and sales representatives to maintain appropriate data security safeguards in place and they are contractually restricted from using your Personal Information for any purpose other than in order to offer you K2View's products and services, and/or in order to respond to any other specific request that K2View has received from you. We note that such distributors, dealers, resellers and sales representatives may separately ask you to provide your name and contact information for other marketing activities. Any information that you may transfer to them directly will be used by them according to their privacy practices and K2View will not be responsible for their use of such information.
- K2view Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of K2view for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section 6 above). Please note that all K2view personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
- Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processers who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site. Please note that we collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 10 below.
- Public and government authorities, to the extent we are compelled to disclose Personal Data to comply with our legal obligations.
6.4. For avoidance of doubt, K2view may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.
7. Your Rights
K2view acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: Legal@k2view.com and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:
- Right to access: you may have the right to request a review of your Personal Information held by K2view. We may refuse to comply with your access request if the request is manifestly unfounded, excessive or repetitive in nature.
- Right to erasure: under certain conditions, you may be entitled to require that K2view will delete or "block" your Personal Information (e.g. if the continued processing of those data is not justified).
- Right to Portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity). The right to data portability only applies where your Personal Information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
- Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either "public interest" or "legitimate interests", those lawful bases are not absolute, and you may have a right to object to such processing. Where you object on grounds of legitimate interest, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
- The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
- Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
To exercise these rights, where applicable, please contact us by sending an email to: Legal@k2view.com
8. Location of Your Data
Note to our Users in the EU:
If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries.
In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:
- Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;
- Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;
- Transferring your Personal Information to organizations that are Privacy Shield Scheme certified, as approved by the European Commission.
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.
The Site is intended for Users over the age of sixteen (16). Therefore, K2view does not intend and does not knowingly collect directly Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site.
10. Third Party Service Providers and Third Party Software
10.2. Note, that we collect, hold and/or manage your Personal Information through K2view's authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.
10.3. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
10.4. Such third parties service providers include without limitation the following categories of service providers:
11. International transfer of Personal Data
To facilitate our business practices, your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates in other countries where we operate, including countries outside the European Economic Area (EEA). We have implemented safeguards to ensure an adequate level of data protection where your Personal Data is transferred to countries outside the EEA, such as standard contractual clauses for the transfer of Personal Data as approved by the European Commission.
12. Links to Third Party Websites
13.1. We take appropriate measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.
13.2. Your Personal Information is hosted on Hubspot, Salesforce and Moose servers, which provide advanced strict security standards (both physical and logical).
13.3. Some of the security measures that we employ include, without limitation: highly secure services design and implementation using state of the art encryption and architectures mechanisms, restriction of access to your Personal Information to individuals who need access to it in order to process it on K2view’s behalf and implementation of a secured permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms.
Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
13.4. K2view will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.
13.5. TO THE EXTENT THAT K2VIEW IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, K2VIEW SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.
14. Data Retention
K2view will retain the Personal Information for as long as we are comfortable that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.
16. Have any Questions?