Privacy Policy

Anagog Ltd. respects your privacy. This policy explains the privacy practices of Anagog Ltd. (“Anagog“/ “we”/ “us”/ “our”) on www.anagog.com (the “Website“) and with respect to Anagog’s JedAI SDK that is installed on our customers’ applications as well as Anagog’s own applications (the “Applications“) (Website, Applications, and other Anagog services are collectively referred to as “Services“). This privacy policy describes the ways Anagog collects, uses and discloses your Personal Information. This is important; we hope you will take time to read it carefully.

As of the 25th of May 2018, Anagog no longer collects any personal data of data subjects who are in the European Union and from November 1st 2019 we are no longer collecting data globally through our older SDK version. SDK (Software Developer Kit) refers to technology provided by Anagog and which is embedded in our customers’ own applications, (“SDK”). In this context, personal data has the meaning given in Article 4(1) of the General Data Protection Regulation (GDPR) 2016/679. This Privacy Policy therefore does not relate to our older SDK version.

This Privacy Policy covers the personal data we collect:

About our customers and prospective customers, including on our Website and when customers contact us in relation to the Services. Anagog would usually be a Controller of this data.

About users of our own Applications. Anagog would usually be a Controller of this data.

About users of applications that have embedded Anagog’s new SDK, which processes personal data on the user’s own device. Anagog would usually be a Processor of this Data.

Anonymized data used for statistical purposes and business analysis.

Our Privacy Policy explains:

1
What information we collect and why we collect it.
2
How we use that information.

If you do not agree with this Policy, do not use our Services and do not provide us with your personal data.

Users can access the Services through our Website and/or Applications on Devices. A “Device” is any computer used to access the Services, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device. Anagog also provides our SDK technology for inclusion within certain third-party applications (“Third Party Apps”) and/or services provided by our customers with whom we have entered into agreements, in order to provide you with an improved personalized and contextualized experience while using those Third-Party Apps and/or services.

This Privacy Policy applies only to the collection and use of information by Anagog, and not to the collection and use of information by the customers of our SDK. Please refer to the privacy policies of the respective Third-Party Apps that use Anagog’s SDK to understand the privacy practices of these Third-Party Apps. The providers of those Third-Party Apps may collect and/or use your information in different ways than we do, and we are not responsible for any actions of customers providing Anagog’s SDK’. This Privacy Policy governs your access of the Services, regardless of how you access them.

This policy is incorporated into Anagog’s terms of use (the “Terms of Use”), available at www.anagog.com.

The Services are 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 SERVICE IN ANY WAY.

Personal Information that you provide:

In this policy, the term “Personal Information” means any information that may be used with reasonable efforts to contact you and/or identify you, such as a first and last name, home address, phone number and email addresses, places you visit, etc.

On our Website we collect Personal Information about you, that you have provided us as part of our Website’s various ‘contact us’ / ‘request demo’ / ‘get JedAI’ forms. We use this information in order to provide you with our Website services. You choose what you want to share and how you want to share it. For example, we collect such information on this Website if you participate in a survey, provide us feedback, send us questions, or otherwise supply additional information or respond to our requests for information. When you use the Services, Anagog may ask you to provide certain contact and personal details, such as a telephone number and e-mail address. Bear in mind that false, incorrect, or outdated information may impair Anagog’s ability to provide you with the Services and to contact you when necessary. Anagog will explicitly indicate the fields for mandatory completion. You are not required to provide us with any information; however, if you do not enter the requisite data in these fields, you may not be able to use the Services. We may also collect Personal Information about you through cookies, as described below. We collect this personal data on the basis of our legitimate interest to market and offer our Services and on the basis that processing is necessary for the performance of a contract with you.

We collect personal data on our own Applications on the basis of your consent. You have the right to withdraw your consent at any time and we will stop processing all your data immediately and will permanently erase all the data that we hold about you. We collect information on device-level events, such as crashes and battery life information, in order to provide customer service. We also collect and analyze the signals and data from the Device’s sensors such as GPS, Accelerometer, Barometer, WiFi, Bluetooth, Cellular transceivers, Magnetometer, Gyroscope and any other on-Device sensors. We use such signals in order to understand your mobility status and whereabouts, in order to provide you with a greater contextual service that can better address your personal needs and in order to improve your experience with the Services.

Most of the other information we collect from or analyze on your Devices, such as your advertiser ID, your device and hardware IDs and device type, your carrier, your carrier user ID, operating system version, data regarding which other apps are installed on the Device and the duration of their use, and basic usage stats about your Device and use of the Services does not by itself identify you to Anagog, though it may be unique or consist of or contain information that you consider personal or that may be deemed Personal Information under applicable law. You may provide additional Personal Information that will be used to personalize the Services, for example by providing you the shortest route between work and home, and enhance your experience with the Services. Further information may be collected when you communicate with Anagog. For example, if you submit a request, provide us with feedback, participate in a survey, contact Anagog’s support team, or report a violation to the abuse team.

When our SDK is embedded on our customers’ applications, Anagog typically does not have access to your personal data. In certain cases, we may be the processor of your personal data and the owners of those applications are the controllers. The SDK can work in different manners as follows:

  • Anagog gives a license to its customer to use the SDK and all personal data is processed on the user’s device. In this case, Anagog does not collect and store any personal data of the user.
  •  Anagog’s SDK runs on the customer’s application. Most of the user’s personal data is processed on the user’s own device and not sent to Anagog. Anagog may receive aggregated non-personal data which it uses to improve the Services.
  •  Anagog provides both the SDK and in some cases also cloud storage services to its customer. In this instance, Anagog stores and processes the user’s personal data on behalf of its customer who is the controller.

If you have Applications that include Anagog’s SDK installed on your Device, you may be sending us location information. This information may reveal your actual location, such as GPS data, or it may not, such as when you submit a partial address to look at a map of the area. Anagog uses that information to provide you and other users with the Services. Anagog may make further use of your location information by analyzing it anonymously with other information from multiple users to generate crowdsourced information about sites, shops and other places and attractions that will assist in providing you and others with relevant services in the vicinity.

If you give your consent via an App, signals and data may be collected from the various sensors on your Device, such as the Accelerometer, GPS, Barometer, WiFi, Bluetooth, Cellular network, Gyroscope, NFC, Magnetometer and other on-board sensors. We, or our customers may use these signals and data in order to offer you the Services.

Anagog may also use your location information to create aggregated anonymous data and to use such data in accordance with this Privacy Policy.

When you install the Applications, you may be requested by the Device operating system to provide your consent to the use of your location by the Application. If you do not wish to share your location you can choose to deny such access. Some of the Applications contain an internal opt-out option from the collection of your location data, usually under the Application’s settings.

Regarding any Third-Party App that is installed on a Device, you may uninstall the Third-Party App at all times, by using the Third-Party App’s uninstall options, or by using the programs removal feature of your operating system. Some of the Third-Party Apps may offer you to simply opt-out from the Anagog services. Following any opt-out or uninstallation process, Anagog will not be able to collect any further information from you through such Third Party App, or provide you with location-based information and Service including crowd-based services about sites, shops and other services, places and attractions in your close vicinity, also through said Third Party App.

Anagog may use or process your Personal Information for the following purposes. One or more purposes may apply simultaneously.

  • To send you marketing and advertising material through e-mail messages, subject to your prior consent. At any time you may opt out of the Services’ mailing lists, by changing your preferences in your personal account (should you have such an account) or by sending Anagog a written notice to: dpo@anago.com. You may also unsubscribe from our mailing lists at any time by clicking the unsubscribe link at the bottom of our emails.

If you raise such an objection, we will no longer process your personal data for such purposes.

  • To conduct surveys and questionnaires;
  • To contact you when Anagog believes it to be necessary.
  • We typically do not collect and store any data from our own Applications. If we do collect following your permission, we use such Personal Information to demonstrate to our customers the capabilities of our SDK, which they may then want to install into their own applications. We use information regarding your activity status, your location and your use and duration of third-party applications in order to create a report to our customers or prospective customers showing the sort of data that can be processed through our SDK on the phone itself, if they chose to install it in their applications.
  • To use anonymized aggregated data that does not disclose any particular user’s personal information for various commercial business analytics purposes.
  • To provide you with support and handle request and complaints;
  • To send you software updates and additional information related to the Services; To enforce the Terms of Use;
  • To prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
  • To handle breakdowns and malfunctions;
  • For purposes provided under this Privacy Policy and the Terms of Use.
  • If we intend to further use or process your personal information for a purpose other than set forth in this policy, we will provide you prior to that further use or processing with information on that other purpose.

We may share Personal Information we collect through our website, from our customers or through our Applications with selected third parties, including:

  • Business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analysing data, providing IT and other support services or in other tasks, from time to time. These third parties will only use your information to the extent necessary to perform their functions;
  • Analytics and search engine providers that assist us in the improvement and optimization of our site and subject to the cookie section of this policy and data processors who process your personal information on our behalf and in accordance with our instructions and applicable data protection law.

In addition, we may disclose your personal information to third parties:

  • If all or substantially all of our assets are acquired by a third party including by way of a merger, share acquisition, asset purchase or any similar transaction, in which case personal data held by us about our customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Anagog, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
  • For avoidance of doubt, Anagog may transfer and disclose Non-Personal Information to third parties at its own discretion.

Anagog may use anonymous, statistical or aggregated information to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes.

We also use a tool called “Google Analytics” to collect information about the use of the Services. Google Analytics collects information such as how often users visit the Services, what pages they visit when they do so, and what other websites they used prior to coming to the Services. Google Analytics collects only the IP address assigned to you on the date you visit the Services, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. We use the information we get from Google Analytics only to improve our Services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is restricted by the Google Analytics Terms of Use located at http://www.google.com/analytics/terms/us.html  and the Google Privacy Policy located at http://www.google.com/policies/privacy/.

Anagog may also use anonymous, statistical or aggregated information collected on the Services, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, Partner, other partners and any other third party. Anagog may share such information with the Partners, other partners or with third parties, or use it for our own purposes, without restriction, on commercial terms that we can determine in our sole discretion.

Anagog does not retain location information longer than required to provide the Services and for reasonable business needs (Thereafter, your location information will be anonymized), or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly.

Anagog may at all times review, retain and disclose any other information as Anagog deems necessary to satisfy any applicable law, regulation, legal process or governmental request and Anagog’s needs and necessities. By doing so Anagog does not either expressly or impliedly endorse, affirm or in any manner assume any responsibility for such communications.

The authority supervising our processing activity is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority.

In addition to gathering Personal Information, we may also use “cookies” to collect information and improve our Website Services, such as Google Analytics. A cookie is a small data file that we transfer to your Device.

The cookies may contain a variety of information, such as the content of search queries, the Website’s pages you have accessed, session durations and IP addresses. We use this information for the above purposes and to monitor and analyze use of the Services, for the Services’ technical administration, to increase our Services’ functionality and user-friendliness, and to verify users have the authorization needed for the Services to process their requests.

We may use “persistent cookies” to save your registration ID and login password for future logins to the Service. We may use “session ID cookies” to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage and web traffic routing on the Services.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your Device’s memory.

If you wish to block the Website’s cookies, please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof.

Anagog may permit, solicit or contract certain other companies to conduct advertising campaigns on the Services and/or conduct such advertising campaigns itself. The advertisements that you may see when accessing the Services are redirected from the servers of Anagog and/or of said advertising companies and may be geographically or contextually targeted. Anagog and/or said advertising companies may use cookies on your Device. The cookies enable the collection of information about sections and features that you have accessed, advertisements posted on those sites and the advertisements that you have viewed. In this manner, Anagog and/or advertisers try to customize advertisements to your preferences and for their own business purposes. The aforementioned use of cookies by the advertising companies is subject to their own privacy policies and not to this Privacy Policy. If you wish to study the privacy policies of those advertising companies you should visit their services or contact them directly.

Anagog considers information security to be a top priority and is committed to protecting the security of your personal data. Anagog implements systems, applications and procedures to secure your Personal Information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing. When we transmit highly confidential data over the Internet, we protect it through the use of encryption. However, these measures are unable to provide absolute assurance.

Personal data collected by Anagog may be stored and processed in a various locations (also using cloud services), which are chosen in order to operate efficiently, to improve performance, and to create contingencies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy policy is processed according to the provisions of this policy and the requirements of applicable law wherever the data is located.

Therefore, although Anagog takes great efforts to protect your Personal Information, Anagog cannot guarantee that Anagog’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Questions about the security of personal data, can be directed to our DPO, which can be contacted at dpo@anagog.com

Data subjects with respect to whose data GDPR applies, have rights under GDPR and local laws, including, in different circumstances, rights to data portability, rights to access data, rectify data, object to processing, and erase data. Data subject rights cannot be exercised in a manner inconsistent with the rights of Anagog employees and staff, with Anagog proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified by data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects generally have a right to withdraw their consent.

If, for any reason, a data subject wishes to modify, delete or retrieve their Personal Information, they may do so, where applicable, by contacting Anagog (dpo@anagog.com) . Note that Anagog may have to undertake a process to identify a data subject exercising their rights. Anagog may keep details of such rights exercised for its own compliance and audit requirements. Please note that Personal Information may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by Anagog.

Data subjects in the EU have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority fails to deal with a complaint you may have the right to an effective judicial remedy.

Where Anagog is a Processor, any data subject rights may be exercised only through the relevant Controller.

If you have a privacy concern, complaint, or a question or believe that your privacy has been compromised by any person, in the course of using the Services, then please contact Anagog at: dpo@anagog.com .

You may send Anagog other requests, responses, questions and complaints by contacting Anagog at: Anagog Ltd., 28 Ha’Arbaa St., PO Box 20166 Tel Aviv 6473925, Israel

We may change this Privacy Policy from time to time, when necessary to reflect customer feedback and changes in our Services. When we post changes to this policy, we will revise the “last modified” date at the top of the policy. If we make a change to this Privacy Policy that we believe materially reduces your rights, we will provide a notice prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. We may provide notice of changes in other circumstances as well. By continuing to use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

Last modified: April 13, 2020