PRIVACY POLICY

[Last Updated: April 10, 2025]

Howazit Ltd. (“Howazit”, “us” or “we”) provides its customers (“Customer”) with a Software-as-a-Service cloud-based managing solution (“Platform”) allowing Customers to enhance their business’s customer experience through digital engagement tools, including feedback and surveys, with integrated analytics to measure performance (together with the Platform and the feature, be “Services”).  

This privacy policy (“Privacy Policy”) describes how Howazit collects, uses, and processes Personal Data, specifically the types of Personal Data collected, the purposes for which we will use it, how long we will retain it, with whom we share it, and your rights regarding your Personal Data.

• Any individuals, including representatives of prospects and potential business partners, who access and use our website or other digital assets under our domain, including requesting a demo, or other similar forums as available through our website (respectively “website” and “Prospects”);
• Customers that access and use the Services (through the Platform). However, specifically excludes any data processed by Howazit in its role as a data processor, processing Personal Data on behalf of the Customer, which is subject to our commercial agreements and a data processing agreement with the Customer;
• Authorized users, employees or contractors, using and accessing the Services or marketplace on behalf of a Customer or Supplier (“Authorized User”); and

Customer and Prospect shall be, collectively and separately, referred herein as “you”.

ANY PERSONAL DATA YOU PROVIDE IS MADE AT YOUR FREE WILL AND CONSENT (WHERE REQUIRED UNDER APPLICABLE DATA PROTECTION LAWS), AND YOU ACKNOWLEDGE THAT YOU ARE NOT UNDER ANY STATUTORY OBLIGATION TO PROVIDE PERSONAL DATA TO HOWAZIT. HOWEVER, IF YOU WILL NOT PROVIDE US WITH CERTAIN PERSONAL DATA, WE WILL NOT BE ABLE TO FULFILL CERTAIN SERVICES.

This Privacy Policy further includes or incorporates specific information required under applicable data protection laws for residents of certain jurisdictions, among others:

If you are a located in the EEA or UK – this Privacy Policy further details our lawful basis for processing Personal Data, information regarding cross border data transfer and your rights, as well as additional information we are required to disclose to you under the EU and the UK General Data Protection Regulations (collectively “GDPR”).

If you are a California resident – please also review our CCPA Privacy Notice which serves as a Notice at Collection as required under the California Privacy Rights Act (“CCPA”) and further details the categories of information collected and additional information regarding our privacy practices, including your rights.

Additional Information to certain United States Residents – please also review Section 12 of this Privacy Policy “Additional Notice for US Residents” to learn more about our privacy practices and your rights under these territories.

• POLICY AMENDMENTS

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the website and the update date will be reflected in the “Last Updated” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

• CONTACT INFORMATION AND DATA CONTROLLER INFORMATION

Howazit, a company incorporated under the laws of the state of Israel, is the “Data Controller” (as such term is defined under applicable privacy and data protection legislation, which refers to the organization that determines the means and the processing of the personal data) of the Personal Data collected as described under this Privacy Policy.

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact as follows:

By Mail: 42 Ben Yehuda St., Herzliya, 4680444  Israel

By Email: privacy@howazit.com

Representative for Data Subjects in the EU and UK Contact Information:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the European Union and 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 website: https://app.prighter.com/portal/11447821152

• DATA PROCESSING, PURPOSES OF USE AND LAWFUL BASIS

You will find below information regarding the types of data we collect, the purposes for which we process Personal Data as well as our lawful basis for processing (where the GDPR applies to your Personal Data).

We may collect aggregated, non-personal, and non-identifiable information which may be made available or gathered via your use of the website or Services (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data and cannot link between the data and the individual with reasonable means. This refers mainly to technical information, or aggregated data.

We further collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data”). This may include online identifiers, names, emails, etc., subject to applicable law. 

For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

Below we detail the Personal Data we collect and how and for which purposes we process and use your Personal Data, as well as our lawful basis for processing (subject to the GDPR, if applicable). 

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ, and we are only responsible for the Personal Data we collect and process as the controller of the Personal Data. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of our Services, and to enforce our terms of use and other policies, as well as to protect the security or integrity of our databases and Services, and to take precautions or defend against legal liability and claims. Such processing is based on our legitimate interests.

• HOW WE COLLECT PERSONAL DATA

Depending on the nature of your interaction with us, we may collect Personal Data as follows:

• Automatically– we may use cookies (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our website or Services.
• Provided by you voluntarily– we will collect Personal Data you provide us with, such as when you contact us, etc.

• COOKIES AND TRACKING TECHNOLOGIES

We use “cookies” (or similar tracking technologies such as tags and pixels) when you interact with our website. The use of cookies is a standard industry-wide practice. Cookies and similar technologies are a small piece of information, text, or code that a website assigns and stores on your computer or browser while you access a website.

Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, for statistical purposes, for operation and security purposes, as well as for advertising purposes.

The information generally collected and stored by cookies includes Online Identifiers, Usage Data, and Service Usage Data (as defined under Section 3 of this Privacy Policy “Data Processing, Purposes of Use and Lawful Basis”). 

You can find more information about cookies here: www.allaboutcookies.org

Please see our cookie list available through the Cookie Manager accessed through the icon (in the website footer), which details the cookies we use on our website. You may change your cookies preference at any time.  Note that, certain cookies used for strict operation and security purposes are considered as “strictly necessary” and cannot be disabled.

Please note that once you choose to opt out or disable cookies, some features of our website may not operate properly, and your online experience may be limited.

• DISCLOSURE OF PERSONAL DATA

We may disclose your Personal Data to third parties, including our affiliated companies, partners or service providers that help us manage our business operations or provide our Services. You can find in the table below information about the categories of such third-party recipients.

For the avoidance of doubt, we may share Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share, or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

• USERS RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is ‎to be clear about what Personal Data we collect so that you can make meaningful choices about ‎how it is used. We allow you to exercise certain choices, rights, and controls in connection with ‎your Personal Data. Depending on your relationship with us, your jurisdiction and the applicable ‎data protection laws that apply to you, you have the right to control and request certain limitations ‎or rights to be executed. ‎

Note that, as further explained below, some of your rights can be exercised independently through ‎your browser settings, and to exercise certain rights – you will be requested to submit a request by ‎filling out the Data Subject Request (“DSR”) form available https://www.howazit.com/privacy-policy/DSR and send it to our team at: privacy@howazit.com

In the table below you can review your choices depending on your interaction with us, how you can ‎exercise them, and appeal a decision we take in this regard. Any specification per geo-location or ‎territory are available below the table:‎

• CROSS-BORDER DATA TRANSFER:

Transfers of your Personal Data will be made in accordance with applicable laws. When Personal Data is transferred outside the country where it was originally collected, we will take the steps necessary (and to the extent required by applicable laws) to ensure that sufficient safeguards are provided to such data during its transfer and processing. Some of the measures implemented to safeguard your Personal Data include ensuring that the recipient is bound by specific contractual clauses approved by relevant data protection authorities to provide adequate protection for Personal Data. Where applicable, you can request a copy of the relevant contractual safeguards that we have put in place. 

• DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.

Other circumstances in which we will retain your Personal Data for longer periods of time include:

• Where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements;
• For us to have an accurate record of your dealings with us in the event of any complaints or challenges; or
• If we reasonably believe there is a prospect of litigation relating to your Personal Data.

Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

• SECURITY

We take great care in implementing and maintaining the security of your Personal Data. We employ ‎industry standard procedures and policies to ensure the safety of individuals’ information and ‎prevent unauthorized use of any such.‎

We have implemented technical, physical and administrative security measures to protect the ‎Personal Data we process. Although we take reasonable steps to safeguard information, we cannot ‎be responsible for the acts of those who gain unauthorized access or abuse our website, and we ‎make no warranty, express, implied or otherwise, that we will always be able to prevent such ‎access.‎

Please contact us at: privacy@howazit.com if you feel that your privacy was not dealt with properly, in a way that was ‎in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain ‎unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you ‎and the appropriate authorities (if required by applicable law) in the event that we discover a ‎security incident related to your Personal Data.‎

• CHILDREN

Our Services are not intended for use by children, and we do not knowingly collect or maintain information about anyone under the age of 16. Please contact us at:  privacy@howazit.com if you have reason to believe that a child has shared any information with us. 

• ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 effective November 2020, and as amended by the CPRA, effective January 1, 2023 (collectively “CCPA”). 

Please see our CCPA Privacy Notice, which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom we share the personal information for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident.

• ADDITIONAL NOTICE TO US RESIDENTS

The section is applicable to residents of certain U.S. states (depending on the applicable state law, acting in an individual or household context and not in a commercial or employment context or as a representative of business), including the following state laws:  Colorado Privacy Act; Connecticut Data Privacy Act; Delaware Personal Data Privacy Act; Florida Digital Bill of Rights; Indiana Consumer Data Protection Act; Iowa Consumer Data Protection Act; Kentucky Consumer Data Protection Act; Maryland Online Data Privacy Act; Minnesota Consumer Data Privacy Act; Montana Consumer Data Privacy Act; Nebraska Data Privacy Act; Nevada S.B. 370; New Hampshire Data Privacy Act; New Jersey Data Protection Act; Oregon Consumer Privacy Act; Rhode Island Data Transparency and Privacy Protection Act; Texas Data Privacy and Security Act; Tennessee Information Protection Act; Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act.

We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, purpose of processing, instructions for exercising consumer rights and appealing decisions, categories of Personal Data shared with third parties, categories of third parties with whom data is shared, and any sale of data or targeted advertising.

Under Section 3 – “Data Processing, Purposes of Use and Lawful Basis” of this Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collecting and processing, and the purposes for which Personal Data is processed, stored or used.

Under Section 6 – “Disclosure of Personal Data” of this Privacy Policy, we detail and disclose the categories of third parties we share Personal Data with for business purposes. We will not collect additional categories of Personal Data or use the Personal Data we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent.

Additionally, under Section 7 – “Users Rights” of this Privacy Policy, we detail and disclose your rights and how to exercise such requests.

“Sale” of Personal Data:

Under US privacy laws, in principle, the term “sale” is referring to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as this term is commonly understood, meaning – we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment. However, subject to the definition of the term “sale” under applicable US privacy laws, our practice of using “cookies or other third-party advertising services and sharing Personal Data for such purpose is considered as a “sale”.

Appeal Rights:

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request, by contacting us as instructed in our response. Please send your appeal request with a summary of the request and decision you want to appeal to: privacy@howazit.com

Not more than 60 days after receipt of an appeal, and always in accordance with the timelines set by the applicable US Privacy Laws, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision.

If you are not happy with our response, depending on your jurisdiction, you may have the right to lodge a complaint against us with the relevant State’s Attorney General:

• Colorado Attorney General as follows: Colorado AG at https://coag.gov/file-complaint .
• Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint /.
• Delaware Attorney General at https://attorneygeneral.delaware.gov/fraud/cmu/complaint/. 
• Florida Attorney General at https://www.myfloridalegal.com/consumer-protection/consumer-complaint-form.
• Indiana Attorney General at https://www.in.gov/attorneygeneral/consumer-protection-division/file-a-complaint/.
• Iowa Attorney General at https://www.iowaattorneygeneral.gov/for-consumers/file-a-consumer-complaint. 
• Kentucky Attorney General at https://secure.kentucky.gov/formservices/AttorneyGeneral/ConsumerMediationForm.
• Maryland Attorney General at https://www.marylandattorneygeneral.gov/Pages/CPD/Complaint.aspx.
• Minnesota Attorney General at http://www.ag.state.mn.us/
• Montana Attorney General at https://dojmt.gov/consumer/consumer-complaints/. 
• Nebraska Attorney General at https://ago.nebraska.gov/constituent-complaint-form.
• Nevada Attorney General at https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/
• New Hampshire Attorney General at https://onlineforms.nh.gov/app/#/formversion/e0c5d644-c9d8-4056-a7cc-24d29c446fcb. 
• New Jersey Attorney General at https://www.njoag.gov/contact/file-a-complaint/.
• Oregon Attorney General at https://www.doj.state.or.us/consumer-protection/contact-us/. 
• Rhode Island Attorney General at https://riag.ri.gov/forms/consumer-complaint
• Texas Attorney General at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.
• Tennessee Attorney General at https://www.tn.gov/attorneygeneral/working-for-tennessee/consumer/file-a-complaint.html
• Utah Attorney General at https://www.attorneygeneral.utah.gov/contact/complaint-form/.
• Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform .