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    Privacy Notice of
    דן דיגיטל

    For the use of the Connecteam app

    We at Mobilesson Ltd. d/b/a Connecteam (“Connecteam“, “us“, “we“, or “our“) recognize and respect the importance of maintaining the privacy of our Customers and their Personnel. This Privacy Notice describes the types of Personal Data (as defined below) we collect from you when you visit our website (“Site“) and/or use our Platform or any of our Apps (collectively, the “Services“), as well as the ways in which we collect, process, transfer, store and disclose such Personal Data. It also describes how you may control certain uses of the Personal Data. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://connecteam.com/terms-conditions/ (“Terms“). “You” means any user of the Site, App, Platform and/or Services.

    “Personal Data” or “Personal Information” means any information that refers to, is related to, or is associated with an identified or identifiable individual or household.

    This Privacy Notice does not apply to the processing of Personal Data on behalf of our Customers, where we provide our Services in our role as a “Data Processor”, as such term is defined in data protection laws, unless otherwise specifically stated. Such processing is described here for completeness and informational purposes only, and is governed by our Data Processing Addendum with the Customer. If you have any questions or requests regarding such processing, please contact your Account Owner directly. For more information, please refer to Section ‎10 below.

    Privacy Notice Key Points:

    The key points listed below are detailed further throughout this Privacy Notice. You can click on any section to find out more about the below topics.

    1. Data Collection & Processing
    2. Data Uses & Lawful Bases
    3. Communications with You
    4. Data Location
    5. Data Disclosure
    6. Cookies and Similar Technologies
    7. Opt-Out of Sale/Sharing
    8. Data Security
    9. Data Subjects Rights
    10. Data Controller/Processor
    11. Data Retention
    12. Additional Notices

    1.     Data Collection & Processing

    For the purposes of this Privacy Notice, the following terms shall have the meanings set forth below:

    “Prospects” means any visitor to our Site, participant at any of our events, or otherwise a prospective User (as defined below) who visits our Site or interacts with any of our online ads, emails or communications under our control.

    “User” means an Account Owner, an Administrator, or an Employee (including a service provider or an independent contractor of one of our Customers), using the Platform and/or an App in connection with a Customer account.

    Depending on the ways in which you use our Services, we collect different types of Personal Data, and we and any of our third-party contractors and service providers use such Personal Data for different business and commercial purposes, as specified below. You are not legally required to provide us with any Personal Data, and may do so (or avoid doing so) at your own free will. However, please keep in mind that without it, we may not be able to provide you with the full range with of our Services or deliver the best user experience when interacting with them. If you prefer not to provide us with your Personal Data, or have it processed by us, please refrain from providing it, visiting or interacting with our Site and/or Platform or App. You may also submit a request to exercise your rights as explained in Section 9 below. Connecteam does not collect, use or disclose sensitive Personal Data.

    Prospects:

    • Contact Information: When you (1) request information from us through the Site, (2) fill out (online) forms, (3) participate in our events, (4) contact us using a referral link, or (5) contact us for any other reason, we will collect any data you (or our Users who have referred you, as further described in this Section below) provide, such as your name and/or email address, and any additional information submitted via the Site, online ads, emails or other communication.
    • Communications Data: When you communicate with us, we may collect Personal Data, including through interactions with our account executives via phone calls, virtual meetings, and instant messaging apps. This may include your name, email address, phone number, job title, company name, and any information you choose to share during the interaction. This may also include any written correspondences, screen recordings, screenshots, and related information that may be automatically recorded, tracked, transcribed and analyzed.
    • Automatically Collected Data: When you visit the Site we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system and browser type, internet service provider (ISP), and Personal Data such as your IP address, sessions recordings, browsing history on our site, as well as referring and exit pages (the pages you clicked to reach our site and the pages you clicked from our site), how often you visit the Site, which pages you visit and when, which ad or email messages were presented to you and other information regarding your viewing history on our Site. For more information about the cookies and similar technologies we use, please see the section “Cookies and Similar Technologies” below.
    • Data Collected from Third Parties: We may receive Personal Data about you from third-party sources.

    Users:

    • Registration Data: If you are an Account Owner or an Administrator, in order to use our Services, you will be required to register and provide Personal Data requested by us, including your full name, email address and phone number. Administrators and Employees may be requested to provide additional details such as job title, profile picture or any other information as required by either your Administrator or Account Owner.
    • Payment Data: If and when you make a payment (using a credit card) to Connecteam for use of our Services, we receive information related to such a purchase, including the last four digits of your credit/debit card number, CVV, expiration date, and the name of the cardholder.
    • Communications Data: Personal Data contained in any forms and inquiries that you may submit to us, including support requests, interactions through instant messaging apps, registrations to our events, participation in our online and offline communities and activities; surveys, feedback and testimonials, phone call and video conference recordings, as well as written correspondences, screen recordings, screenshots, and related information that may be automatically recorded, tracked, transcribed and analyzed. In addition, any User may refer a friend to our Services, in which case such a User will be required to provide us with such User’s contact details (full name, email address and phone number) (“Referral Registration Data“).
      For information about our direct marketing activities and how you can control your preferences, please see the Promotional Communications Section below.
    • Automatically Collected Data: When you use our Services, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system and browser type, internet service provider (ISP) and language settings, and Personal Data such as your IP address, device ID, browsing history, including referring and exit pages, connectivity, session recordings, technical and usage data, activity logs, the relevant cookies and pixels installed or utilized on your device, clicks, use of features and other interactions, and any information regarding your viewing history on the Platform or App, browser language, and browser time zone. This data is collected and generated automatically, including through the use of analytics tools (including cookies and pixels) which collect data such as how often you use the Services, how you interact with and use the Services, including technical data concerning the performance, functionality, potential fraudulent activities and stability of the Platform. For more information about the cookies and similar technologies we use and how to adjust your preferences on the Services, please see the section “Cookies and Similar Technologies” below.
    • Data Collected from Third Parties: If you are an Account Owner or Administrator, we may receive Personal Data about you from third-party sources including our advertising, analytics, and data enrichment partners and third-party integration tools, depending on the settings, permissions, and privacy policies established by you and the third party integration service. We recommend that you review the privacy settings and notices of these third-party services to understand what data may be shared with us or disclosed through our Services.
    • Materials You Upload: Any personal data, including text, documents and images you upload to the Platform. Connecteam does not use this data for its own purposes and acts only as a “data processor” with respect to such data. The usage of this Personal Data and the relevant legal basis will be determined by the Customer to which your account is associated. For more information on this see Section 10 below.
    • Geo-location: When you use specific functionalities in our App, you may be asked to share your mobile device’s precise (GPS) geo-location information. Such geo-location information may include physical locations visited (latitude & longitude). Whether or not we collect this geo-location data is entirely determined by your Account Owner or Administrator in their sole discretion and Connecteam acts only as a “data processor” with respect to such information. For example, they may only allow you to clock-in or clock-out if they are able to verify your location via your device. If you do not wish to allow the collection of your precise location, in most cases you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or adjusting the permissions for the App. Please note, however, that some of the App’s features may not work properly if you turn this off, and we are not responsible for any implication of turning off such geo-location tracking.
      Connecteam does not use geo-location data for its own purposes. The use of geo-location data and the underlying legal basis for its use is determined by the Customer to which your account is associated. For more information on this see Section 10 below.

    For the purposes of the California Consumer Privacy Act (CCPA), specifically in the last twelve (12) months, we have collected the following categories of Personal Information: Identifiers; Customer Record Information; Internet or other electronic network activity information; Geolocation data; Audio, Electronic, Visual, or Similar Information; Commercial Information; Professional or Employment-Related information; and Inferences.

    2.     Data Uses & Lawful Bases

    The table below outlines the various purposes for which we process Personal Data, along with examples of the types of Personal Data we process in connection with each purpose and the corresponding lawful basis under applicable data protection laws. These purposes depend on how you interact with our Services—whether as a Prospect or a User—and help ensure that we collect and use Personal Data responsibly, transparently, and in accordance with legal requirements.

    Prospects and Users Personal Data
    Purpose Examples of Personal Data Processed Lawful Basis
    To handle Users and Prospects support requests or inquiries. Name, email address, phone number and information you provide in support requests. Performance of a Contract (where applicable); Legitimate Interest
    To provide Prospects, Account Owners and Administrators with informational and promotional materials relating to our Services, including via email and for general advertising efforts including ad measurement, audience research, and personalized advertising. Name, email address, phone number, the relevant cookies and automatically collected data. Legitimate Interest; Consent (where applicable)
    To document internal records of calls and meetings (including with the use of artificial intelligence) with Prospects and Users for the purpose of training our staff and improving our Services.  

    Phone calls and video conferences recordings.

    Performance of a Contract (where applicable); Legitimate Interest; Consent (where applicable)
    To track and understand how our Prospects and Users engage with our Site and Services, to help facilitate our operations, developing new products or services, and improving our current content, products, and services, or for any other business purpose such as business intelligence, including by collecting and analyzing aggregated, non-personal analytics. IP address, session recordings, referring and exit pages, browsing activity on the Site. Legitimate Interest
    To prevent fraud, protect the security of our Site and Services and address any problems with the Site and Services. sessions recordings, browsing history on our site Legitimate Interest; Legal Obligation
    To comply with any legal and contractual obligations, maintain our compliance with applicable laws, regulations and standards. Registration and payment data Performance of a Contract; Legitimate Interest; Legal Obligation

     

    Users Personal Data
    Purpose Examples of Personal Data Collected Lawful Basis
    To provide Account Owners and Administrators with customized content, targeted offers, and advertising related to our products and services, based on your usage history on the Services, other third-party sites, or apps you may visit and/or use, or via e-mail. Usage history, Automatically Collected Data. Legitimate Interest; Consent (where applicable)
    In the case of Referral Registration Data, to contact you (including via email) with referral activities, to provide you with informational newsletters and promotional materials relating to our Services. Referrer’s name and contact info, referred person’s name, phone number, email. Legitimate Interest; Consent (where applicable)
    To facilitate, operate, enhance, and provide our Services. Name, email address, job title. Performance of a Contract; Legitimate Interest
    To test and monitor the Services, or diagnose or fix problems Support ticket content, screen recordings, screenshots. Performance of a Contract; Legitimate Interest
    To provide support, respond to your inquiries and requests, to train our Customers and Customer-facing staff and to contact and communicate with you. Name, email address, phone number, Support ticket content. Performance of a Contract
    To process the payment for your purchase. Name on card, last four digits of credit/debit card number, expiration date. Performance of a Contract
    To create a general profile of Customers and usage profiles of their respective Users in order to improve and optimize our Services. Automatically Collected Data. Legitimate Interest
    To prevent fraud and secure payments. Payment information, IP address. Legitimate Interest; Legal Obligation
    To create analytics, quality control and improvements. Automatically Collected Data, surveys, feedback and testimonials. Legitimate Interest

    If you reside or are using our Services in a territory governed by privacy laws under which “consent” is the most appropriate legal basis for the processing of Personal Data as described herein (in general, or specifically with respect to the types of Personal Data you expect or elect to process or have processed by us, via the Services, or due to nature of such processing), your acceptance of our Terms and this Privacy Notice shall be deemed as your consent to the processing of your Personal Data for all purposes detailed hereunder, unless applicable law requires otherwise.

    3.     Communications with You

    We engage in service and promotional communications, through e-mail, phones, SMS, WhatsApp and push notifications.

    3.1.   Service Communications. We may send you service-related communications, including service announcements and administrative messages (such as registration confirmations, log-in attempts or password reset attempts). Please note that you will not be able to opt-out of receiving certain communications which are integral to the operation and use of our Services (like password resets).

    3.2.   Promotional Communications. If you are a Prospect, an Account Owner or Administrator, we may use your Personal Data to let you know about our products and services that we believe will be of interest to you. We may contact you by email or through other communication channels approved by you. We will always respect your preferences regarding how/whether you would like us to communicate with you. To ensure you have control over how we contact you with marketing offers:

    3.2.1.We will take steps to limit direct marketing to a reasonable level and only send you communications which we believe may be of interest or relevance to you.

    3.2.2.You can ask us to stop sending email marketing by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact us at [email protected].

    3.2.3.You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained in our Cookie Policy.

    4.     Data Location

    We are based in Israel and have subsidiaries in the US and Australia, and we use service providers located in the European Economic Area (“EEA”), the US, Israel and other jurisdictions, who process and store Personal Data. We conduct such international transfers for the purposes described above. We ensure that any third parties based in a third country and receiving Personal Data are subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice.

    4.1.   Connecteam is headquartered in Israel, a jurisdiction which is considered by the European Commission, the UK Secretary of State, and the Swiss Federal Data Protection and Information Commissioner, to be offering an adequate level of protection for Personal Data of individuals residing in EU Member States, the UK and Switzerland, respectively. We transfer data from the EEA, the UK and Switzerland to Israel on this basis.

    4.2.   Whenever we transfer your Personal Data to third parties based outside of the EEA, the United Kingdom, and Switzerland to a third country which isn’t covered by an “adequacy decision” we ensure a similar degree of protection is afforded to it by signing specific contracts approved by the European Commission, the FDPIC and the UK Secretary of State, which give Personal Data the same protection it has in the EEA, Switzerland and the UK.

    Please contact us at [email protected] if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA, Switzerland, and the UK.

    5.     Data Disclosure

    We disclose your Personal Data to other entities as follows:

    5.1.   Customers and other Users. If you are a User, we may disclose your Personal Data to the Customer (or any individual acting on their behalf, for example an Account Owner or Administrator) with whom your account is associated, in our capacity as a “data processor”. This includes where we are requested to disclose Personal Data regarding your usage of the Platform or App, your chats, IP address, or geo-location that we have collected on our Customers’ behalf. Other Users within the account may also have access to some of your Personal Data depending on the settings within the account (set by you or your Account Owner/Administrator).

    5.2.   Affiliates. We may disclose information, including your Personal Data, to our affiliates and subsidiaries (whether existing now or those that may be incorporated in the future).

    5.3.   Service Providers, and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with our Services; (2) aid in our understanding of how you use our Services; (3) improve, optimize and send promotional communications (as detailed in Section 3.2 above); (4) deliver advertisements, search for audiences and conduct ad measurement, and (5) provide us with IT and system administration, data backup, security, and storage services, data analysis, data enrichment, and payment processing services. Our Service Providers and Subcontractors may use artificial intelligence and similar technologies where such use is limited for the provision of relevant services, and is subject to our agreements with them.

    5.4.   Service Integrations. Our Customers may choose to use a third-party service to integrate with our Services (“Third-Party Provider”), or to enhance the usage of the Services (provided that our Services support such integration). The provider of such third-party service may receive certain relevant data about or from your account on the Services, or disclose certain relevant data from your account on the Third-Party Provider’s service to our Services, depending on the nature and purpose of such integration. This could include your Personal Data.

    The processing of your Personal Data by the Third-Party Provider is subject to the agreement of the relevant Customer (or you) with such Third-Party Provider.

    All use of third-party applications or services is at your own risk and subject to such third party’s terms and privacy policies.

    When you use our “AI Generated Courses” feature, such use shall also be subject to Google’s Privacy Policy located at http://www.google.com/policies/privacy/.

    5.5.   Change of Control; Business Interest. Should Connecteam or any of its subsidiaries or affiliates is involved in any proposed or completed change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, your Personal Data may be disclosed to or transferred to the parties involved in such an event. We may disclose Personal Data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Data may also be disclosed in the event of insolvency, bankruptcy or receivership. In addition, we may disclose your Personal Data where such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.

    5.6.   Law Enforcement Related Disclosure. We may disclose your Personal Data to third parties: (1) if we believe in good faith that disclosure is appropriate to protect our or a third-party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (2) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (3) as is necessary to comply with any legal and/or regulatory obligation.

    5.7.   Feedback or Recommendations. If you submit a public review or feedback, note that we may (at our discretion) store and present your review publicly on our Site and Services. If you wish to remove your public review, please contact us at [email protected]. If you choose to send others an email or message inviting them to use the Services, we may use the contact information you provide us to automatically send such invitation email or message on your behalf. Your name and email address may be included in the invitation email or message.

    For the purposes of the CCPA, in the past twelve (12) months, we may have disclosed Identifiers; Customer Record Information; Internet or other electronic network activity information; Geolocation data; Audio, Electronic, Visual, or Similar Information; Commercial Information; Professional or Employment-Related information; and Inferences to Customers, Affiliates, Service Providers, or for Law Enforcement Related Disclosures. We may have disclosed Identifiers; Customer Record Information; Internet or other electronic network activity information; and Commercial Information for Service Integrations. We may have disclosed Identifiers; Customer Record Information; Commercial Information; Professional or Employment-Related Information; or Audio, Electronic, Visual or Similar Information related to Feedback or Recommendations.

    For the avoidance of doubt, Connecteam may disclose your Personal Data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. Connecteam may also share aggregated, non-personally identifiable information with third parties for auditing, analytics, maintenance, security, or other related business purposes as determined appropriate by Connecteam.

    6.     Cookies and Similar Technologies

    We and our service providers use cookies, pixels, tags and other technologies in order for us to provide and monitor our Services and Site, to ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as IP address, as indicated by you. To learn more about our practices concerning cookies and tracking, please see our Cookie Policy. You may also use the “Cookie Settings”/”Do Not Sell Or Share My Personal Information” link available in our Services depending on your location and activity on our Services, as applicable.

    7.     Opt-Out of Sale/Sharing

    Under some US data protection laws, like the CCPA, our disclosure of certain internet activity and device information to third parties through cookies or pixels and disclosures of identifiers to certain service providers may be considered a “sale” or “sharing” of Personal Information. We do so in pursuit of the business and commercial purposes described in Section 2 above.

    For the purposes of the CCPA, in the last 12 months we have “sold” or “shared” identifiers, customer records information, internet or other electronic network activity information, geolocation data, and commercial information with our analytics and advertising partners and service providers. Connecteam has not knowingly sold or shared the personal information of individuals under the age of 16.

    To opt out of all cookies that may result in a “sale” and/or “sharing” of your Personal Information in the following ways:

    • On the cookie banner, click the “Do Not Sell Or Share My Personal Information” button, and move the toggle switch “Sale or Share of Personal Data” off.
    • Click the “Do Not Sell Or Share My Personal Information” button (available in our website’s footer) and move the toggle switch “Sale or Share of Personal Data” off. Please note: If you visit us from a different device or browser, or clear cookies, then you need to return to this screen to re-select your preferences.
    • Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party Advertising cookies (instructions on how to download and use GPC are available here).

    8.     Data Security

    We have implemented and maintain appropriate technical and organizational security measures, policies and procedures designed to protect Personal Data from unauthorized access, disclosure, destruction or loss. Our security measures include industry-standard physical, electronic, and procedural safeguards, such as secure servers and encryption protocols. We regularly review and update our security practices, maintain internal security policies, and ensure our personnel are bound by appropriate confidentiality obligations. Our systems and databases are backed up regularly to help ensure data preservation and business continuity.

    While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee that our Services will be immune from any malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

    As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

    9.     Data Subject Rights

    Subject to applicable privacy laws (including but not limited to GDPR, UK GDPR, Swiss Federal Data Protection Act, or CCPA), and in some cases dependent upon the processing activity we are undertaking, you may have certain rights in relation to your Personal Data. These rights may include the ability to access your Personal Data and obtain information about its collection and use; request rectification of your Personal Data; request the deletion of your Personal Data; restrict or object to the processing of your Personal Data; receive a copy of your Personal Data in a portable format; opt out of the sale or sharing of your Personal Data (where applicable); and receive equal service and pricing, even if you choose to exercise your privacy rights.

    If you wish to exercise any of these rights, please contact us at [email protected]. You may authorize an agent to submit privacy rights requests on your behalf by providing written authorization or power of attorney. We may require additional verification of such authorization.

    When you submit a privacy rights request, we may:

    • Guide you to fulfill the request through your account settings
    • Direct you to your Account Owner, for example, if we only hold your personal data because we are providing the Services to your employer organization as our Customer
    • Request additional information to verify your identity and ensure we can accurately process your request
    • Retain documentation of your request and our response as required by law
    • We reserve the right to redact any third-party personal or confidential information when fulfilling access requests.

    For EU/UK residents, you have the right to file a complaint with your local data protection authority if you have concerns about how we handle your Personal Data.

    10.  Data Controller/Processor

    10.1 Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “Business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “Services Provider”), who processes such data on behalf of the data controller (or business). Below we explain how these roles apply to our Services.

    10.2 Connecteam is the “data controller” of: (1) its Prospects’ Personal Data and (2) Account Owners’ & Administrators’ Registration Data, Payment Data, User Communications Data and User Automatically Collected Data as detailed in Section 1 above. Accordingly, we assume the responsibilities of a data controller (solely to the extent applicable under law), as set forth in this Privacy Notice.

    10.3 Connecteam is the “data processor” of: (1) Materials uploaded by Users (2) Personnel Registration Data, and (3) Geo-Location Data, as submitted by our Customers and their Users to the Services. We process such data on behalf of our Customer (who is the “data controller” of such data) and in accordance with its reasonable instructions, subject to our Terms, our Data Processing Addendum (to the extent applicable) and other commercial agreements with such Customer.

    10.4 Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose Personal Data may be submitted to the Services, have been provided adequate notice and given informed consent to the processing of their Personal Data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the Customer. Our Customers are also responsible for handling data subject requests under applicable law, by their Users and other individuals whose data they process through the Services.

    10.5 If you would like to make any requests or queries regarding Personal Data we process as a data processor on our Customer’s behalf, including accessing, correcting or deleting your data, please contact the Customer’s Account Owner or Administrator directly.

    11.  Data Retention

    11.1 Subject to applicable law, we retain Personal Data as necessary to maintain and expand our relationship with you and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes.

    11.2 In some circumstances, we may store your Personal Data for longer periods of time, for instance, where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements, for an accurate record of your dealings with us in the event of any legal challenges or complaints, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or concerning our relationship. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.

    11.3 With respect to data within our Services for which we serve as data processors we will retain that data for as long as directed by the applicable Customer. For example, a Customer may choose to archive Personal Data within the Platform of Employees who have been terminated, in which case such archived data will be retained until deleted by the Customer. If you have any questions regarding such Personal Data, please contact the relevant Customer directly.

    11.4 Please contact us at [email protected] if you have any questions regarding our data retention periods.

    12.  Additional Notices

    12.1 Representatives. Mobilesson has appointed Prighter Group with its local partners as our privacy representative and your point of contact for the European Union and the United Kingdom. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter, or make use of your data subject rights, please visit the following site: https://prighter.com/q/14267474. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.

    12.2 Children. We do not knowingly collect Personal Data from children under the age of sixteen. In the event that you become aware that an individual under the age of sixteen has enrolled without parental permission, please advise us immediately.

    12.3 Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business. We will place any updates on this webpage. Please check this page regularly to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will inform you by notice on our Site, through the Services or by email.

    12.4 Comments and Questions. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at [email protected].

    12.5 DPO. We have appointed a data protection officer (DPO) who is responsible for overseeing our privacy and data protection practices you may contact our DPO using at:[email protected].

    Last updated: June 10, 2025

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