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C-DATA – PRIVACY POLICY – MARKETPLACE

C-DATA – PRIVACY POLICY – MARKETPLACE

(Last updated March 2025)

      1. This privacy policy (“PP“) explains how  Computer C-Data Ltd., (the “Company“, “C-Data”) collects, stores, uses, shares, and processes personal data of the resellers, their Personnel and/or their Customers (as applicable) (for the purpose hereof, collectively, “Reseller“) in connection with the Marketplace and any other related services, as may be offered by the Company from time to time (the “Services“). For the purpose of this PP “Personal Data” shall mean any information that refers to, is related to, or is associated with an identified or identifiable individual, pursuant to the Israeli Privacy Protection Law, 1981 and its implementing regulations, as may be amended from time to time (“the “Law”). The PP is an integral part of the Company’s Term and Conditions https://c-data-cloud.co.il/forms/terms, or any other agreement executed between the Company and the Reseller governing the use of the Services (“Terms and Conditions”, together with the PP, the “Terms“). 
      2. This PP does not apply to any Personal Data that Company is provided with, processes, and manages on behalf, or at the direction of Reseller, with respect to the Services, where Reseller decides how and why Personal Data is processed (“Reseller Data“). Such Reseller Data is processed by the Company pursuant to our Data Processing Addendum (“DPA”), subject to and in accordance with the Law, in our position as the ‘holder’ (as defined in the Law). 
      3. It shall hereby be clarified that Reseller is not under any legal obligation to submit Personal Data to Company. However, in case Reseller chooses not to submit personal data to Company, Reseller may not be able to use the Services or any part thereof. By attempting to use or access, or by accessing and/or using the Services, Reseller agrees to be bound by the Terms. If Reseller does not agree with the Terms (or any part thereof), Reseller must not access or use the Services. Reseller’s acceptance of the Terms will be deemed as Reseller’s consent to the processing of Reseller’s Personal Data for all purposes detailed in this PP. To revoke such consent, (to the extent applicable) Reseller may contact us at privacy@c-data.co.il.

The Company collects (whether directly or indirectly by utilizing third-party service providers, including as set forth under Section ‎‎3 below) the following types of personal data, either with respect to Reseller, or with respect to its employees and service providers or other third parties who are using the Services on behalf of the Reseller (“Personnel“), as well as with respect to Reseller’s Customers:

Reseller might choose to provide Company with the following Personal Data, weather voluntarily or automatically when interacting with the Services:  

Reseller hereby represents and warrants that in providing the Company with the above Personal Data of Reseller’s Personnel and/or Customers(i) Reseller fully complies with any applicable laws (including without limitation that Reseller obtained and will continue to obtain the consents of Personnel and Customers required by any applicable law); (ii) Reseller will conspicuously display, maintain, and make accessible to its Personnel and Customers a privacy policy that complies with any applicable law.

      1. Online identifiers and information contained in cookies, as further detailed hereunder, including: 
        1. Screening of navigation, usage and operational analytics and statistics; 
        2. Session recordings and heat maps;
        3. Statistical data with respect to the operation of the Services, including system performance statistics, such as CPU and memory usage;
        4. Data about the Services, including components counts, versions, and types;
        5. Reseller’s settings preferences, backup information; 
        6. Content viewed or searched for, page response times, and page interaction information (such as access logs, scrolling, clicks, mouse-overs and any other information that relates to  activities made through the Services);
        7. Network and connection information, such as the Internet protocol (IP) address and information about Reseller’s Internet service provider; 
        8. Device information, such as browser type and version, operating system, or time zone setting; location of the device, encounters with other devices using the Services.

If the Reseller wishes to object to such processing of the Service Usage Data (or part thereof), please contact the Company at: privacy@c-data.co.il. However, by objecting or disabling the processing of the Service Usage Data (or part thereof), Reseller may not be able to receive certain parts of the Services.

      1. Company and Company’s third-party service providers may use tracking mechanisms such as cookies on the Services so that Company may: (i) facilitate, analyze, personalize, improve and customize the Reseller’s experience of the Services; and (ii) track Reseller’s use of the Services. 
      2. Without derogation from the generality of the foregoing the Company allows ALSO which is a third-party service provider of the Company, to place cookies within its Services, that collects Reseller’s (and its Personnel’s and Customer’s) Personal Data such as relevant contact, business and usage details. Such Personal Data is collected in order for ALSO to provide, maintain, improve, develop and secure the business relationship with the Company and its own services, including by evaluating Reseller’s (its Personnel’s and Customer’s) behavior (tracking) on the Services. ALSO’s use of such Personal Data for its own purposes is governed by ALSO’s privacy policy as provided in the Marketplace, pursuant to applicable law;
      3. For a complete description of cookies and similar technologies placed on the Services, please see the cookie settings in the Marketplace.
      1. Company processes Reseller’s (or its Personnel’s or Customer’s) Personal Data to operate, provide, maintain, and improve the Services, including for the following purposes: 
        1. contacting Reseller and communicating with Reseller with respect to the Company’s Services; 
        2. recognizing and identifying Reseller on the Services;
        3. evaluating Reseller’s behavior (tracking) on the Service;  
        4. improving marketing efforts and promoting Company’s Services;
        5. providing assistance, notification and support; 
        6. fulfilling Reseller requests and providing Reseller care; 
        7. meeting contractual or legal obligations; 
        8. protecting Reseller’s security, e.g. preventing and detecting fraud;
        9. protecting the rights or property of the Company;
        10. complying with applicable laws and regulatory requirements, or as requested by government or regulatory authorities;
        11. internal purposes, e.g. trouble shooting, data analysis, administrative, testing and statistical purposes. 
      1. Except as provided herein, Company does not use any personal data obtained hereunder, except as permitted under applicable law. 
        1. AS set forth under Section ‎3 above;
        2. For integrations with third-party services;
        3. If required to do so by law or regulations according to its understanding of such law or regulations (including, but not limited to, in cases of court orders or subpoenas or other legal process);
        4. To verify the information obtained by Company;
        5. To enforce or apply Company’s terms and other agreements, or protect the rights, property, or security of Company, Reseller, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction;
        6. To prevent or investigate suspected fraud, or any activity that Company believes may be illegal or may expose the Company to legal liability;
        7. Events involving potential threats to the physical safety of any person or property, if Company believes that the respective information in any way relates to that threat;
        8. If Company believes that Reseller’s (or its Personnel’s or its Customer’s) conduct on or in connection with the Services is inappropriate and inconsistent with generally accepted norms of behavior; 
        9. In addition, Company may be required to disclose data to relevant national, state and local law enforcement authorities, whom may further disclose the data.
        10. In the event that Company, or any of its businesses, are sold or disposed of, whether by merger, sale of assets or otherwise, data may be one of the assets sold or merged in connection with such transaction. Data may also be disclosed in connection with a commercial transaction where Company or any of its businesses are seeking financing, investment, and support or funding. 
        11. When Company shares data with third parties, as specified above, Company requires such recipients to agree to only use such Personal Data in accordance with this PP and Company’s contractual specifications and for no other purpose than those determined by Company in line with this PP. However, it is clarified that Company is not liable for such third parties’ use of the Personal Data.

Subject to the Law, the Reseller (including its Personnel and Customers) have the following rights in relation to Reseller’s Personal Data, processes by the Company, and Company shall act in accordance with the Law, in order to comply with Reseller’s requests to exercise Reseller’s rights: 

To exercise any of these rights, please contact the Company, via the contact details set forth under Section ‎12  below.

Company has taken appropriate technical and organizational measures to protect the information Company collects about Reseller, Reseller Personnel or Reseller Customers, from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. Reseller should be aware, however, that no data protection and security measures can guarantee 100% protection and security of any data stored either with Company or with any third parties.

Each Reseller is advised to be aware that personal data Company collects may be transferred to, processed and stored outside Reseller’s jurisdiction, and that data protection laws in the jurisdiction where the information is collected stored and/or processed may differ from Reseller’s jurisdiction, including in Israel, the EU, and Australia, as reasonably necessary for the proper performance and delivery of the Company services, or as may be required by law. Each Reseller hereby gives Reseller’s consent to this transfer, processing and storage of Reseller’s information outside Reseller’s jurisdiction. 

Company will retain Resellers Personal Data for a period of time consistent with the original purpose of collection (see Section ‎4, “Company’s Use of Personal Data”). Company determines the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of Resellers’ Personal Data processed, the potential risk of harm from unauthorized use or disclosure of Resellers’ Personal Data, and whether Company can achieve the purposes of the processing through other means, as well as on the basis of the Law’s requirements (such as applicable minimum statutory retention requirements). After the expiration of the applicable retention periods, Company will delete such Personal Data. If there is any data that Company is unable, for technical reasons, to delete entirely from Company’s systems, Company will put in place appropriate measures to prevent any further use of such Personal Data.

Company does not knowingly collect or solicit any information from anyone under the age of 18. The Services is not directed at children under the age of 18. In the event that Company learns that it has collected Personal Data from a child under the age of 18 without consent from a parent or a guardian, Company will delete that Personal Data as quickly as possible. If Reseller believes that Company might have any information from or about a child under 18, Reseller should contact Company at the email address set forth below. 

If Reseller has any questions about this PP or Company’s data practices in general, including in connection with Reseller’s (and anyone of its Personnel or Customers) rights related to Reseller’s Personal Data, Reseller may contact Company using the following information:

Email: privacy@c-data.co.il

 

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