Howazit Ltd., (“Howazit”, “we”) is committed to maintaining the privacy of its users (“user”, “you”). The following information describes how Howazit collects and processes information about you when you use our website (the “Website”) and Services (as described below).

Our Privacy Policy explains:

• What information we collect and why we collect it.
• How we use that information.
• Your rights with regard to the collection of such information.

By using our Website and Services, you agree to this Privacy Policy.

Howazit provides an end-to-end customer communication platform (the “Platform”) which allows its customers (“Customer User”) to provide sufficient customer care by allowing them to communicate with their end-users (“End-Users”) to enhance customer satisfaction, loyalty, engagement and sales. The Platform collects feedback, which is converted into customer reviews, assists in addressing dissatisfied End-Users’ needs and provides them with personalized content (the “Services”). The Website provides information about Howazit and its Services and enables its users to contact Howazit with respect to the Services.

Collecting Information

Please note that the scope of this Privacy Policy is limited only to information collected by Howazit through your use of its Website and Services. Some information may be automatically collected, and some is collected when you interact with our Website and Services. The type of information that may be automatically collected is non-personal information, which includes your session durations, the content you accessed on the Website or Services, the frequency and scope of your use of the Website and Services and information about your computer and internet connection including the operating system you use and browser type.

Information from which you can be personally identified may also be collected, including but not limited to your name, address, email address, telephone number, and the location of the computer through which you used the Website or Services (hereinafter: “Personal Information”). Personal Information shall be collected only if received voluntarily from you, including, without limitation, via the following ways:

1. Booking a Demo

If you wish to book a demo, we will collect your full name, email address, phone number, company name, job title, and the content you submitted to facilitate your demo.

2. Communication with End-Users

If you wish to join our Services and use the Platform, we will collect the content of the conversation transmitted over the Platform between you, as the Customer User and the End-User, to assure sufficient assistance regarding the Services and to improve the End-User’s experience.

3. Contact Form

If you wish to contact us for support regarding our Services, Website, this Privacy Policy or any other matter, we will collect your full name, email address, phone number, company name, job title, and the content you submitted to facilitate your inquiry.

4. Newsletter

If you wish to register to our newsletter and be provided with information on the Website and Services, subject to your consent, we will collect your email address, and will send you the required materials.

Please note that with regard to information collected when providing our Services to Customer Users, any notification requirements towards End-Users shall apply on the respective Customer User, and all to the extent required under the applicable law.

Use of Information

We use the Personal Information we collect from you for a range of different business purposes according to different legal bases of processing. We may use or process your Personal Information for the following purposes. One or more purposes may apply simultaneously.

1. Providing the Requested Services

• We collect Personal Information included in the end-to-end Customer User and End-User communication process, such as the “chat-like feedback collection”, “personalized information on the go” and the “live chat” to provide Customer Users with the Services they contracted to receive, and to improve End-User’s experience.
• We collect Personal Information, such as your full name, email address, phone number, company name, job title, in order to facilitate your demo request.
• We collect Personal Information, such as your full name, email address, phone number, company name, job title, and the content you submitted to facilitate your inquiry when you choose to contact us via the designated form.
• Such collection of information will enable us to provide you with technical and professional assistance, with regard to the Website and Services you use or intend to use.

We process the Personal Information where it is necessary for the adequate performance of the contract we have with you or if you are an End-User, you may have with the Customer User.

2. Improvement and Development of the Services

• We collect Personal Information to improve and develop our Services and understand feedback on Howazit’s Website and Services and to help provide more information on the use of our Services quickly and easily.
• We collect Personal Information for ongoing review and improvement of the information provided on our Website to ensure it is user friendly.
• We collect Personal Information to improve the management and administration of our business and maintain compliancy with our internal policies and procedures.
• We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve our Website and Services, develop new features, and conduct audits and troubleshooting activities.

We process this information in light of our legitimate interest in improving the Website and Services, to allow our users to have the best experience.

3. Maintain a Safe and Secure Environment

We may use your information to detect and prevent fraud, abuse and security incidents in the following ways;

• Verify and authenticate your identity and prevent unauthorized or illegal activity;
• Enhance the safety and security of our Website and Services;
• Conduct security investigations and risk assessments;
• Prevent or take action against activities that are, or may be, in breach of our terms of service or applicable law.

We process this information in light of our legitimate interest in improving our Website and Services by enabling our users to browse in a secure environment.

4. Personalize Content, Advertising and Marketing

• If you have used Howazit Services in the past, we have a legitimate business interest for matching the data we collect with other data we had already collected.
• This enables us to understand your needs and interests, optimize the content we send you and make it more suitable and relevant to your needs.
• This also enables us to improve your experience on the Website and Services by providing you with personalized content, recommendations, and features.

We process this information in light of our legitimate interest to personalize your experience and customize our content.

Disclosure of Information and Transfer of Data

Except as otherwise provided in this Privacy Policy, we reasonably attempt to ensure that we never intentionally disclose any of your Personal Information, to any third party without having received your permission, except as provided for herein or otherwise as permitted or required under law.

In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your Personal Information with third parties.

We will share your Personal Information without limitation with:

• AWS in order to facilitate cloud computing solutions.
• Google Workspace to facilitate email corresponds with Customer Users.
• Twilio, 019, Maskyoo and Plivo to engage in SMS communication with Customer User.

We may as well share your Personal Information with our affiliates, subsidiaries or any third party service providers and individuals to facilitate our Services or any portion thereof, such as marketing, data management or maintenance services. We may also share your information with analytics service providers, such as Google Analytics, for analytics services. Such analytics service providers set their own cookies or other identifiers on your computer, through which they can collect information about your usage of our Website and Services. This helps us compile aggregated statistics about the effectiveness of our Website and Services.

The above mentioned third parties may be located in countries other than your own, and we may send them information we receive. When such third party service providers process your Personal Information on our behalf, we will assure that they comply with obligations similar to those which are set forth in this Privacy Policy. We will also assure that they will abide by our data privacy and security requirements, and will be allowed to use the Personal Information solely for the purposes we set. We will transfer your Personal Information while using appropriate and suitable safeguards, while using a variety of legal mechanisms, including contracts, to ensure your rights and protections travel with your data.

We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate changes. Furthermore, information about you may also be released in order to comply with any valid legal obligation or inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if you use the Website or the Services to perform an unlawful act or omission or take any act or omission that may damage Howazit, its property and goodwill, or if there is an attempted breach of the security of the Website or Services or a physical or property threat to you or others. In case you feel that any of your rights have been compromised, you have the right to file a complaint to the relevant supervisory authority.

Your Rights

You have the right at any time to request to access or modify your information. To exercise these options, please contact us at info@howazit.com.

In some jurisdictions, in particular those located within the European Union (the “EU“) or within the European Economic Area (the “EEA“), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:

1. Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
2. Object to the processing of your Personal Information for direct marketing purposes.
3. Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
4. Object to an automated decision-making (including profiling) in certain circumstances.
5. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;
6. Receive your Personal Information, or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.

Generally, with regard to information collected on our Website, Howazit is a “Data Controller”. Therefore, if you wish to exercise the above mentioned rights, please contact us, and we will make our best efforts to fulfill your request.

With regard to information collected on our Services, Howazit is a “Data Processor”. Therefore, if you are an End-User and wish to exercise the above mentioned rights, please contact the relevant Customer User, and we will make our best efforts to fulfill your request.

If you wish to file a request regarding any of the above, you may contact us at: info@howazit.com.

Cookies

We may use “cookies” and/or other technologies or files (collectively, “Cookies”) to identify how visitors make use of our Website and Services. This aggregated tracking information may be used to help us improve and enhance the Website and Services experience for all of our users. In addition, Cookies are used for adjusting the Website and Services to your personal preferences. Cookies contain information such as the pages you visited, the length of time you stayed on the Website and Services, the location from which you accessed the Website and Services and more. If you would prefer not to have Cookies stored on your computer, you may modify your browser settings to reject most Cookies, or manually remove Cookies that have been placed on your computer. However, by rejecting the Cookies, you may be unable to fully access the offerings on our Website and Services. To find out more about Cookies, visit www.allaboutcookies.org.

Opt In or Opt Out

You are always in control of your data, and if you choose to receive information from us, or others, you can change your mind later. If, at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to info@howazit.com. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.

Links to Other Websites

This Website may provide links to other websites. Please be aware that these other websites are not covered by our Privacy Policy. This Privacy Policy does not cover the information practices exercised by other providers of products or services, advertisers or other websites, companies or individuals, which are not owned or controlled by Howazit. We suggest that when linking to another website, you always read that website’s privacy policy before volunteering any personally identifiable information.

Data Security

We deploy industry standard measures to ensure the security, confidentiality, integrity and availability of the Personal Information we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavor to restrict access to Personal Information on a ‘need to know’ basis for the provision of the Website and Services to you. No such measures are perfect or impenetrable. In the event of a security breach, we will take all reasonable action to minimize any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to our Website and transmission is at the users own risk.

Data Retention

Generally, Howazit does not retain information longer than necessary to provide its Services and for its reasonable business and lawful needs. If you withdraw your consent to us processing your Personal Information, we will erase your Personal Information from our systems, unless the Personal Information is required for Howazit to establish, exercise or defend against legal claims or it is necessary for the performance of the Services.

California Online Privacy Protection Act

CalOPPA requires commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers, to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf.

According to CalOPPA, we agree to the following:

• Once this Privacy Policy is created, we will add a link to it on the first significant page after entering our Website.
• Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the Website.
• You can request to change your Personal Information by emailing us.

California Privacy Rights

The California Consumer Privacy Act of 2018 (“CCPA”) permits users who are California residents to request to exercise certain rights. If you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to your Personal Information. In particular, you can request to receive information on the following:

• The categories and specific pieces of your Personal Information that we have collected.
• The categories of sources from which we collected your Personal Information.
• The business or commercial purposes for which we collected your Personal Information.
• The categories of third parties with which we shared your Personal Information.

You can be rest assured that we do not sell your Personal Information. If you choose to exercise your rights, we will not charge you different prices or provide different quality of our Services, unless those differences are related to your provision of your Personal Information.

Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Moreover, you may designate an authorized agent to make a request on your behalf.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide, will only cover the 12 month period preceding your verifiable request’s receipt. If, for some reason, we cannot reply within such time frame, our response will include an explanation for our inability to comply. If you wish to exercise your CCPA rights, please contact us at: info@howazit.com.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you with a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CAN SPAM Act

The CAN-SPAM Act is a Federal US law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

To be in accordance with CAN SPAM, we agree to the following:

• Not use false or misleading subjects or email addresses.
• Identify the commercial message sent to you as an advertisement when required.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at info@howazit.com and we will promptly remove you from ALL correspondence.

Children’s Privacy

The Website is not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under 16 years of age.

IF YOU ARE UNDER THE AGE OF 16 YOU MAY NOT USE THE WEBSITE AND SERVICE, UNLESS PARENTAL CONSENT IS PROVIDED.

If you believe that we may have any Personal Information from or about a person under the age of 16, please contact info@howazit.com.

Revisions and Modifications to our Privacy Policy

We reserve the right to revise, amend, or modify this Privacy Policy at any time. When changing the policy, we will update this posting accordingly. Please review this Privacy Policy often so that you will remain updated regarding our current policies.

Governing Law and Jurisdiction

This Privacy Policy will be governed and interpreted pursuant to the laws of the State of Israel without giving effect to its choice of law rules. You expressly agree that the exclusive jurisdiction for any claim or action arising out of or relating to this Privacy Policy shall be to the competent courts in Tel Aviv, Israel only, to the exclusion of any other jurisdiction.