PRIVACY POLICY

1. When you browse or visit our Website
   1. 1. Specific Personal Data we collect. Cookies, analytic tools, and log files. For more information, please read our cookies policy.
      2. Why is the Personal Data collected and for what purposes? For marketing and analytics purposes.
      3. Legal basis (GDPR only, if applicable). Consent or legitimate interest (e.g., essential cookies).
      4. Third parties with whom we share your Personal Data. Read more about the purposes of each cookie here [https://go.gytpol.com/cookie-policy]
      5. Consequences of not providing the Personal Data. Certain non-essential Website features may not be available. Read more about the purposes of each cookie here [https://go.gytpol.com/cookie-policy].

2. When you make use of, or interact with, our Website
   1. When you request to book a free trial or a product demo
      1. Specific Personal Data we collect. Full name, company name, job title, email address and any other Personal Data that you decide to provide us with.
      2. Why is Personal Data collected and for what purposes? To process your demo request, to provide you with a free trial and to communicate with you about the trial of the products and further commercial stages.
      3. Legal basis (GDPR only, if applicable). Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract or legitimate interest (e.g., to book a demo).
      4. Consequences of not providing the Personal Data. We cannot (i) process your demo request; (ii) provide you with a free trial; and (iii) communicate with you about the trial of the products and further commercial stages.
   2. When you apply to become a partner
      1. Specific Personal Data we collect. Full name, company name, job title, email address, phone number and country.
      2. Why is the Personal Data collected and for what purposes? To process your request to be a partner.
      3. Legal basis (GDPR only, if applicable). Consent and Legitimate interests (e.g. to allow you to become a partner).
      4. Consequences of not providing the Personal Data. We cannot process your request to be a partner.
   3. When you are a partner and you create an account and when you log in
      1. Specific Personal Data we collect. Username, full name, email address, and password.
      2. Why is the Personal Data collected and for what purposes? To allow you to create an account and to log-in to the portal.
      3. Legal basis (GDPR only, if applicable). Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering a contract and Legitimate interests (e.g. to create your account).
      4. Consequences of not providing the Personal Data. We cannot allow you to create an account and log in to the portal
   4. When you subscribe to our distribution list(s)/ newsletter(s)
      1. Specific Personal Data we collect. Email address.
      2. Why is the Personal Data collected and for what purposes? To add you to our mailing list, to contact you, to send you newsletters or other marketing communications.
      3. Legal basis (GDPR only, if applicable). Consent and Legitimate interests.
      4. Consequences of not providing the Personal Data. We cannot (i) add you to our mailing list; (ii) contact you; and (iii) send you newsletters or other marketing communications.
   5. When we process your job application
      1. Specific Personal Data we collect. Full name, email address, phone number, CV/resume, cover letter and any other Personal Data that you decide to provide/supply us with.
      2. Why is the Personal Data collected and for what purposes? To review your application; to assess you as a candidate; to analyze your application; and to communicate with you in connection with your job application.
      3. Legal basis (GDPR only, if applicable). Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract and legitimate interests (e.g. to assess you as a candidate).
      4. Third parties with whom we share your Personal Data. 3^rd party platforms such as for the following purposes: HubSpot to manage communications and customer relationships.
      5. Consequences of not providing the Personal Data. We cannot (i) review your application; (ii) assess you as a candidate; (iii) analyze your application; and (iv) communicate with you in connection with your job application.
   6. When you contact us (e.g., customer support, online chat)
      1. Specific Personal Data we collect. Full name, company name, job title, email address, and any other Personal Data that you decide to provide us with.
      2. Why is the Personal Data collected and for what purposes? To process and answer your questions; to provide support (e.g., to solve problems, bugs or issues); and to customize your experience.
      3. Legal basis (GDPR only, if applicable). Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and legitimate interest (e.g. respond to a query sent by you).
      4. Consequences of not providing the Personal Data. We cannot (i) assist you and respond your query; (ii) provide support; and (iii) customize your experience.
3. When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data
   1. Specific Personal Data we collect. Full name, email address, company name, job title, phone number, any other Personal Data you decide to provide/supply us with.
   2. Why is the Personal Data collected and for what purposes? To establish a business connection, and to send you marketing communications.
   3. Legal basis (GDPR only, if applicable). Consent and legitimate interest.
   4. Consequences of not providing the Personal Data. We cannot (i) establish a business connection; and (ii) send marketing communications.
4. When we acquire your Personal Data from third-party sources (such as lead-generation companies)
   1. Specific Personal Data we collect. Email addresses.
   2. Why is Personal Data collected and for what purposes? To establish a business connection, and to contact possible leads and customers (e.g., by email or phone).
   3. Legal basis (GDPR only, if applicable). Depends on the case, consent and/or legitimate interest (e.g., B2B situation).
   4. Consequences of not providing the Personal Data. Cannot establish a business connection and cannot contact possible leads and customers.
5. When we use the Personal Data of our service providers (e.g. contact details)
   1. Specific Personal Data we collect.  Full name, email address, phone number, job title, company name, any other Personal Data you decide to provide/supply us with.
   2. Why is the Personal Data collected and for what purposes. To contact our service providers; to perform the applicable agreement; and to send contract-related communications.
   3. Legal basis (GDPR only, if applicable). Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.). Legitimate interest (e.g. perform the contract, send contract-related communications).
   4. Consequences of not providing the Personal Data. We cannot (i) communicate with you; (ii) perform the applicable agreement; and (iii) send contract-related communications.
6. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
   1. Specific Personal Data we collect. Full name, email address, phone number, job title, company name, any other Personal Data you decide to provide/supply us with.
   2. Why is Personal Data collected and for what purposes? To reply and/or respond to your request or question; and to send marketing communications or additional information of our products and services (when requested by you).  
   3. Legal basis (GDPR only, if applicable). Depending on the context, consent or legitimate interest (e.g. send you more information about us in certain B2B situations).  
   4. Consequences of not providing the Personal Data. We cannot reply or respond to your request; and we cannot send you marketing communications.

Finally, please note that some of the above mentioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes.

Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes.

“Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
2. Retention of your Personal Data. Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. Regarding retention of cookies, you can read more in our cookie policy https://go.gytpol.com/cookie-policy. 

In addition to the recipients described above, we may share your Personal Data as follows:

1. With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies. 
2. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
3. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
4. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or 
5. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

1. External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data.
2. Transfer mechanisms: When GYTPOL engages transfers of Personal Data, it relies on Adequacy Decisions adopted by the European Commission based on Article 45 of the GDPR (for example, when we access Personal Data from Israel), Standard Contractual Clauses laid down by the European Commission, or any other approved transfer mechanism. Gytpol continually monitors the circumstances surrounding such transfers to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the level of protection guaranteed by the GDPR.

1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
   1. You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
   2. You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
   3. You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
   4. You have the right to object, to or to request restriction, of the processing;
   5. You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
   6. You have the right to object to profiling;
   7. You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
   8. You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
   9. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
2. You can exercise your rights by contacting us at privacy@gytpol.com.  You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
3. Deleting your partner account: Should you ever decide to delete your account, you may do so by emailing privacy@gytpol.com. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
4. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@gytpol.com. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt. 

1. We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@gytpol.com.

1. We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

We reserve the right to remove or add new analytic tools.

Our California Do Not Track Notice (Shine the Light). Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.