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 SDKs that are 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“). SDK (Software Developer Kit) refers to technology provided by Anagog and which is embedded in our customers’ own applications, (“SDK”). 

This privacy policy describes the ways Anagog collects, uses and discloses your Personal Data. Personal data has the meaning given in Article 4(1) of the General Data Protection Regulation (GDPR) 2016/679. This is important; we hope you will take time to read it carefully.

No Data Processing by Anagog

Since 1st November 2019, we have stopped collecting any personal data through our old deprecated SDK and this privacy policy therefore does not apply to the personal data of users of applications containing our old SDK. 

When our customers install one of our current SDKs in their applications, we license the SDK to the customer. In this instance Anagog does not process any personal data in relation to the users of the application and this privacy policy therefore does not apply to those users.

Types of processing covered by this privacy policy

There are different ways in which you may be interacting with Anagog and our SDKs:

Anagog as a Processor

When Anagog’s SDK is installed on your Device, in some use cases, you may be sending location information. Anagog uses that information to provide the SDK details about Point of Interest (POI) nearby. Anagog do not save such data and such session is deleted immediately upon sending the POI information back to the requesting SDK. In this instance Anagog processes the personal data of users as a Processor on behalf of the customer who is the controller of such data.

 

 

 

In the course of evaluating our Services by our customers or per customers request, Anagog offers a Demo version of its SDK to the customer through the use of a dedicated application. In this instance Anagog processes the personal data of users of the Demo application as a Processor on behalf of the customer who is the controller of such data.

Anagog as a Controller

If you install one of our own Anagog Applications, we process your Personal Data as a Controller. 

When you visit our website or otherwise contact us in relation to the Services, we process your personal data as a Controller.

We may process anonymized data used for statistical purposes and business analysis. 

For the avoidance of doubt, this privacy policy provides information about our privacy practices when you interact with us in the ways described in paragraphs 3-7 above.

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, smartwatch, 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 demonstration and evaluation 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:

  1. 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. 
  2. 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. 
  3. 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. 

 

Meta-data that we collect:

Anagog may collect anonymized information about the use of the Services. For example, Anagog may collect the frequency and scope of your use of the Services, the duration of your sessions, advertisements that you view or click on. If collected, such anonymized data will be stored in log files of the Services’ computer servers.

You are not required to provide us with any of the above information; however, if you do not provide certain information, you may not be able to use the Services in part or in full.

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@anagog.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, it means you agreed to be a tester of our Services as part of a Demo and 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 own 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 our 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, analyzing 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.
  • If all or substantially all of Anagog’s 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 it about its 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 Analytical tools to collect information about the use of the Services. Our Analytical tool 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. It only collects 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 the analytics tool with personally identifiable information. We only use the information to improve our Services. 

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, and subject to asking and obtaining your permission, we may also use “cookies” to collect information and improve our Website Services. 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 may 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 or delete 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. In this manner, Anagog and/or advertisers try to customize advertisements to your preferences and for their own business purposes. Any use of cookies by Third Party Apps is subject to their own privacy policies and not to this Privacy Policy. If you wish to study the privacy policies of those Third Party Apps you should visit the respective section in their app or website or contact them directly.

Anagog considers information security to be a top priority and is committed to protecting the security of your personal data. The best way of protecting your personal data is not to collect and store it at all from your mobile app and this is our basic SDK privacy-by-design architecture. Where we need to collect data, such as when you use our Website, we implement 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 under this policy may be stored and processed in various locations (also using cloud services), which are chosen to operate efficiently, to improve performance, and to create contingencies 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.

California Residents – If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personally identifiable information relating to third parties to which we have disclosed certain categories of personally identifiable information during the preceding year, for the third parties` direct marketing purposes, and to obtain such information free of charge up to twice in a 12-month period. You have the right to request disclosure from Anagog of the following:

  1. The categories of personal information Anagog has collected about you;
  2. The categories of sources from which the personal information is collected;
  3. The business or commercial purpose for collecting personal information;
  4. The categories of third parties with whom the business shares personal information; and
  5. The specific pieces of personal information Anagog has collected about you.

 

To make any such requests, please contact us at: dpo@anagog.com.

Anagog will not discriminate against a consumer because the consumer exercised any of the consumer`s rights, including, but not limited to, by:

  1. Denying goods or services to the consumer.
  2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
  3. Providing a different level or quality of goods or services to the consumer.
  4. Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

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., 52 Derech Menachem Begin, PO Box 20166, Tel Aviv, 6713701, 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: August 5, 2021

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