Data Privacy Statement of PRECOGNIZE LTD
The controller according to the EU General Data Protection Regulation (GDPR) and other data protection laws and regulations is:
Precognize LTD
Derech HaShalom 9
Nesher, Israel
Phone: +972-4-840-4364
E-mail: samguard@samsongroup.com
Internet: www.precog.co
1 General information on data processing
1.1 Processing of personal data and its purpose
PRECOGNIZE LTD (“PRECOGNIZE LTD” or “we” in the following) processes personal user data only as far as it is necessary for providing a functioning website, our contents and services. The following data are processed when visiting our website:
- User’s IP address
- Information on the web browser used (type, version, language)
- Operating system used
- User’s Internet service provider
- Date and time the user accessed our website
- Files retrieved from our website
- Web page from where the user got to our website
- Web page(s) that the user retrieves on our website
- Object (image, page) to be opened
- Protocol (http/https)
- Return codes (access successful/not successful)
- Referrer (which link was opened)
The IP address needs to be processed and temporarily saved to supply the web page to the user’s computer. This means that the user’s IP address must be saved for the session. The log files created contain IP addresses or other data that make it possible to identify the user. The log files are saved to ensure the proper functioning of the web pages. Additionally, we use the data to optimize our site and ensure the security of our IT systems.
Personal data are exclusively processed for the mentioned purposes and to the extent necessary for fulfilling these purposes.
1.2 Legal grounds for the processing of personal data
As a rule, personal user data are processed after users have given their consent. An exception applies in such cases where prior consent cannot be requested for factual reasons and where laws and regulations permit the processing of personal data. The storage of personal data and log files is governed by Article 6(1) lit. f) of GDPR.
1.3 Data erasure and period for which the data are saved
We delete or block the personal data of the data subjects as soon as the purpose for storage has become void. When data are processed to provide web pages, the data are erased at the end of the session. Personal data saved in log files are deleted after seven days at the latest. Any further storage is possible if the user’s IP address has been deleted or depersonalized beforehand so that the accessing client cannot be identified any longer.
2 Web analytics
We use Google Analytics on our website, a software for statistical analysis of user access to our web pages provided by Google. No personal user profiles are created, only anonymous statistics are generated. We aim to improve the quality of our website and its contents by using web analytics. We use cookies to do so (see above), which enables us to analyze the usage of our web pages. Users can block web analytics by deactivating JavaScript and cookies in their web browser. Further information on how to proceed can be found in the product documentation made available by the different web browser providers. The processing of data in this context is governed by Article 6(1) lit. f) of GDPR. We have a legitimate interest in analyzing the behavior of our website users for optimization
purposes. For further information on the Google terms of use and data protection regulations go to https://www.google.com/analytics/terms/us.html.
3 Newsletter
We offer a free newsletter on our website. We process the following personal data when users subscribe to it:
- First name, last name
- E-mail address
- Company
- IP address of accessing client computer
- Date and time of subscription
During the subscription process, users are asked to give their consent to the processing of data and reference is made to this privacy policy. The data processed for sending out the newsletter are not forwarded to third parties. The data are exclusively used for sending out the newsletter. The processing of personal data after subscribing to the newsletter is governed by Article 6(1) lit. a) of GDPR. We only save the user’s e-mail address while the newsletter subscription is active. Users can unsubscribe from the newsletter at any time by clicking on the link contained in every newsletter. The personal data are deleted immediately in this case.
4 Contact forms and e-mail contact
Our website includes several contact forms so that users can get in touch with us by electronic mail. If users choose to use this form of communication, the data entered in the form are transmitted to PRECOGNIZE LTD, where they are saved. This applies to the following data:
- Form of address
- First name, last name
- Department
- Company
- Address
- E-mail address
- Phone number
- User’s IP address
- Date and time of sending
Depending on the contact form, it may be possible to enter additional data. Also depending on the contract form, data may be transferred to our sister or parent companies in third countries. In such cases, we ensure that appropriate safeguards pursuant to Art. 46 GDPR are observed. Alternatively, users can make first contact with us at the e-mail address provided on the website. In this case, we save the user’s personal data included in the e-mail. The processing of personal data is governed by Article 6(1) lit. f) of GDPR. The data are only used to handle the first communication and the resulting communication. If we use the personal data for other purposes, we will request the user’s consent beforehand. The personal data entered in the contact form and sent by e-mail are deleted when the
communication with the user has been terminated, which means when the circumstances suggest that the issue in question has been settled. The additional data collected during the sending process are deleted after seven days at the latest.
5 Rights of the data subjects
If PRECOGNIZE LTD processes your personal data, you are a data subject as defined in Article 4(1) of GDPR and have the following rights towards PRECOGNIZE LTD:
5.1 Right of access
Pursuant to Article 15 of GDPR, you have the right to obtain from us a confirmation as to whether or not we process personal data concerning you. Where that is the case, you are entitled to obtain access to the personal data and the following information:
- The purposes of the processing;
- The categories of personal data we process;
- The recipients or categories of recipients to whom your personal data have been or will be disclosed by us;
- Where possible, the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;
- The existence of the right to request from us rectification or erasure of personal data or restriction of processing of your personal data or to object to such processing;
- The right to lodge a complaint with a supervisory authority;
- Where the personal data are not collected from the data subject him- or herself, any available information as to their source;
- The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
You have the right to obtain access as to whether we have been, are or will be disclosing your personal data to recipients in third countries or international organizations. Where personal data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Article 46 of GDPR relating to the transfer.
5.2 Right to rectification
Pursuant to Article 16 of GDPR, you have the right to obtain from us the rectification of inaccurate personal data concerning yourself and/or to have incomplete personal data completed.
5.3 Right to erasure
Pursuant to Article 17 of GDPR, you have the right to obtain from us the erasure of personal data concerning yourself without undue delay. We have the obligation to erase your personal data without undue delay where one of the following grounds applies:
- Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- You withdraw consent on which the processing is based according to Article 6(1), lit. a) of GDPR or Article 9(2), lit. a) of GDPR, and where there is no other legal ground for the processing;
- You object to the processing pursuant to Article 21(1) of GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of GDPR;
- Your personal data have been unlawfully processed;
- Your personal data have to be erased for compliance with a legal obligation in European Union or Member State law to which we are subject;
- Your personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of GDPR.
Where we have made your personal data public and are obliged pursuant to Article 17(1) of GDPR to erase the personal data, we, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform controllers who are processing your personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, your personal data.
The right to erasure does not apply to the extent that processing is necessary:
- For exercising the right of freedom of expression and information;
- For compliance with a legal obligation which requires processing by European Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
- For reasons of public interest in the area of public health in accordance with Article 9(2) lit. h) and i) of GDPR as well as Article 9(3) of GDPR;
- For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of GDPR in so far as the right referred to in item a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- For the establishment, exercise or defense of legal claims.
5.4 Right to restriction of processing
Pursuant to Article 18 of GDPR, you have the right to obtain from us restriction of processing of your personal data where:
- You contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data;
- The processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- We no longer need your personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims; or
- You have objected to processing pursuant to Article 21(1) of GDPR pending the verification whether our legitimate grounds override yours.
Where processing of your personal data has been restricted, such personal data, with the exception of storage, are only processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State. If you have obtained restriction of processing pursuant to the above sections, we will inform you before the restriction of processing is lifted.
5.5 Right of information
If you have requested from us the rectification or erasure of personal data or restriction of processing, we are obliged according to Article 19 GDPR to inform each recipient to whom we have disclosed your personal data of this request, unless this proves impossible or involves disproportionate effort. You are entitled to request information about those recipients from us.
5.6 Right to data portability
Pursuant to Article 20 of GDPR, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller without hindrance from us, where:
- The processing is based on consent pursuant to Article 6(1) lit. a) of GDPR or Article 9(2) lit. a) of GDPR or on a contract pursuant to Article 6(1) lit. b) of GDPR; and
The processing is carried out by automated means.
In exercising your right to data portability, you also have the right to have your personal data
transmitted directly from us to another controller, where technically feasible. This must not adversely affect the rights and freedoms of others. The right to data portability does not apply to processing personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
5.7 Right to object
Pursuant to Article 21 of GDPR, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning yourself which is based on Article 6(1) lit. e) or f) of GDPR, for example by sending an e-mail to info@precog.co . This also applies to profiling based on those provisions. We 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.
5.8 Right to withdraw the declaration of consent on privacy and data protection
You have the right to withdraw your declaration of consent on privacy and data protection at any time, for example by sending an e-mail to info@precog.co. The withdrawal of consent does not affect the lawfulness of processing based on consent before the withdrawal.
5.9 Automated individual decision-making, including profiling
Pursuant to Article 22 of GDPR, you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:
- Is necessary for entering into, or the performance of, a contract between you and us;
Is authorized by European Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or Is based on your explicit consent.
5.10 Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to yourself infringes the GDPR.
6 Responsibility for contents and information
Our website contains links to websites and web pages by external providers. We checked the contents of these external sites or pages for compliance with the applicable civil and criminal laws when the links were included. Nevertheless, we cannot exclude that the providers change these contents afterwards. If you consider linked external sites or pages to be in violation of the applicable laws or if you consider them to be otherwise inappropriate, we kindly ask you to tell us that. We will verify your notification and remove the external link, if necessary. PRECOGNIZE LTD is not responsible for the contents and accessibility of linked external websites or pages.
7 Inclusion and validity of the privacy policy
By using our website, you consent to data processing as described above. This privacy policy applies to the websites of PRECOGNIZE LTD only. Other privacy, data protection and data security policies apply to the contents accessible by external link. Check the disclaimer or general terms that apply to the external links to see who is responsible for these contents. It may be necessary to revise this privacy policy to further develop our website or implement new features. As a result, we reserve the right to change this privacy policy at any time with effect for the future. The version as amended and accessible at the time you visited our website is valid.
Last update: January 2019