Privacy Policy

SmartUp

Privacy Policy

SmartUp understands that you care about how information about you is used. This Privacy Policy explains how we collect information relating to individuals and all other types of information through our website and online services (the “Site”); how we maintain, use, and share that information; and how you can manage the way information about you is handled.

From What Sources Does SmartUp Collect Personal Information?

The only data about individuals that SmartUp collects directly is the IP (Internet Protocol) address of the device used by the individual to access the SmartUp platform and any information you choose to provide us, including on completed forms. The IP address is a number assigned to you by your Internet service provider, so you can access the Internet. SmartUp may obtain additional information about you from third parties who have represented to SmartUp that they have obtained it in full compliance with all applicable laws and regulations and have the legal right to provide it to SmartUp. We also collect information using cookies, as described below.  Collectively, this information is referred to in this Privacy Policy as “Personal Information.”

1. Cookies

Most websites, including our Site, use a feature in your browser to set a small text file called a “cookie” on your computer. The site placing the cookie on your computer can then recognize the computer when you revisit the site to allow auto login and track how you are using the site.

When you visit our Site, our servers and/or those of our service providers automatically record certain information that your web browser sends, such as your web request, IP address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, time and date of use and other information.

The information we collect using cookies does not allow you to be personally identified, but we may link this information to other information that you submit while on our Site which does allow you to be personally identified.

You are free to decline cookies. When first accessing the Site, you can accept or reject all cookies. You can also change those actions at any time by altering your browser settings, as well as erasing cookies and being notified when a cookie is set. If you decline all cookies, the website will close, and you will not be able to access our services.

2. Third-Party Cookies

The use of cookies by our partners, affiliates, tracking utility company, and other service providers are not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, and service providers may use session ID cookies in order to:

• personalize your experience
• analyze which pages our visitors visit
• provide website features such as social sharing widgets
• measure advertising effectiveness
• track which areas of our Site you visit in order to market to you after you leave.

3. Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies and/or other tracking technologies to help us analyze how users interact with and use the Site, compile reports on the Site’s activity, and provide other services related to Site activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The Site does not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

Do Not Track Signals

Your browser or device may include ‘Do Not Track’ functionality. Our information collection and disclosure practices, and the choices that we provide to visitors, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

Web Beacons

Our Web pages contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site is used.

How Does SmartUp Use Information?

SmartUp may aggregate collected information about our users in a form that does not allow users to be personally identified for the purpose of understanding our customer base and enhancing the services that we and our strategic partners and customers can provide you.

SmartUp will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual to whom the information pertains. Specifically, we may use Personal Information and platform-use information to allow users easier and more efficient use of SmartUp and to understand how users use SmartUp’s platform in order to improve our user interface and detect problems and bugs.

To Whom May SmartUp Share Information?

• Service Providers, Partners, and Customers: SmartUp may, from time to time, disclose Personal Information or other collected information to service providers and partners providing functions related to our operation of the Site and for their business related to SmartUp activities that may be of interest to users of the SmartUp platform.
• Legal Reasons: We may disclose collected information, including Personal Information, to a third party, if we believe in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants, or orders by public authorities, including to meet national security or law enforcement requirements; (ii) to address a violation of the law; (iii) to protect the rights, property or safety of SmartUp, its users or the public; or (iv) to allow SmartUp to exercise its legal rights or respond to a legal claim.
• Buyer of the Company: If our company or substantially all of our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to SmartUp may be among the transferred assets. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information. SmartUp will only consent to a review of its records in the context of a potential acquisition or merger if an appropriate confidentiality agreement is in place.

How Can You Change or Delete Your Personal Information?

At any time, upon written request to SmartUp at [email protected] or at the postal address at the bottom of this form, you can obtain a copy of all Personal Information that SmartUp may have in its database about you, correct that information, and direct SmartUp to delete it or not to use or transfer it to third parties. For identification purposes, your request to SmartUp should include your SmartUp username and your email address.  SmartUp will act on any such request within five (5) business days of receipt.  We may contact you for further identification information.  Should you direct SmartUp to delete your Personal Information, your ability to utilize SmartUp products and services may be terminated immediately, and you no longer will have access to the SmartUp platform.

Data Retention

SmartUp will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our services, or we are legally obligated to retain this data for longer periods.

How Do We Keep Your Information Secure?

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. However, no method of Internet transmission or electronic storage is 100% secure. Therefore, while we strive to use commercially standard means to protect your information, we cannot guarantee its absolute security.

Links to Other Sites

The Site may contain links to other sites that are not owned or controlled by SmartUp. This Privacy Policy applies only to information collected by this Site or in the method(s) otherwise discussed herein.  We are not responsible for the privacy practices of such other sites.

Social Media Widgets

Our Site includes Social Media Features and Widgets, such as the Share This button or interactive mini-programs that run on our Site. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with each such feature are governed by the privacy policy of the company providing it.

Transfers of Data

Your information, including Personal Information, may be transferred to – and maintained on – computers located outside of your country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Israel and choose to provide information to us, please note that we transfer the data, including Personal Information, to Israel and principally process it there, as well as in other jurisdictions where we may operate.

Your consent to this Privacy Policy, followed by your submission of such Personal Information, represents your agreement to the transfers described in this Policy.

If you are located in the EEA, Switzerland, and the United Kingdom, your Personal Information may be transferred to – and maintained on – our computers located outside of the EEA, Switzerland, or the United Kingdom or to other recipients located in countries outside of the EEA, Switzerland and the United Kingdom which may not have data privacy laws equivalent to those in the country in which you are located. By submitting your Personal Information to us, you consent to the transfer of your Personal Information to us and the other recipients described in this Privacy Policy that are located in countries outside of the country in which you are located. You may withdraw your consent at any time. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal, nor the lawfulness of processing based on other legal bases.

Information For Individuals in Europe

If you are located in Europe when you access our Site, you understand that we intend to collect, process, and store your personal information in Israel, which has been determined by the European Commission to have sufficiently rigorous data protection laws as to allow for transfers of personal data between the European Economic Area (“EEA”), Switzerland or the United Kingdom and Israel pursuant to the General Data Protection Regulation (“GDPR”). Any transfers by us will comply with safeguards as required by relevant law.

If you are a resident of the EEA, Switzerland, or the United Kingdom, the following information applies.

• Purposes of processing and legal basis for processing: SmartUp processes personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide services to you; and (3) as necessary for our legitimate interests in providing the Site where those interests do not override your fundamental rights and freedom related to data privacy. The very limited scope of Personal Information collected by SmartUp is within the company’s legitimate interests to operate the Site and provide services to the data subject, given the limited impact of this data on the individual’s private life. SmartUp has put in place safeguards to protect personal privacy and individual choice, including disclosures of its data processing activities, the use of consent or opt-outs wherever possible, and the ready public availability of this Privacy Policy at: SmartUpAcademy.org/privacy.
• Right to lodge a complaint: Users that reside in the EEA, Switzerland, or the United Kingdom have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.
• Transfers: Personal information we collect may be transferred to, and stored and processed in, countries in which we or our affiliates or subcontractors maintain facilities. SmartUp ensures that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.

Individual Rights: If you are a resident of the EEA, Switzerland, or the United Kingdom, you are entitled to the following rights.  Please note that in order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.

• The right to access and correct. You have the right to request access to and a copy of your personal data at no charge, as well as certain information about our processing activities with respect to your data. You have the right to request correction or completion of your personal data if it is inaccurate or incomplete. You have the right to restrict our processing if you contest the accuracy of the data we hold about you for as long as it takes to verify its accuracy.
• The right to request data erasure. You have the right to have your data erased from our Site if the data is no longer necessary for the purpose for which it was collected, you withdraw consent, and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
• The right to object to our processing. You have the right to object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

Privacy Rights of California Residents

California residents are entitled under the California Consumer Privacy Act to contact us for various purposes, including to request information about whether we have disclosed personal information to third parties for their direct marketing purposes.  We do not disclose personal information to third parties for their direct marketing purposes.  California residents have the right to be informed as to what personal information about them we may have, how we collected and may use that information, and how to have it corrected or deleted and may request further information about our compliance with this law by contacting us by one of the means listed in the “How to Contact Us” section below.

Changes To This Policy

SmartUp reserves the right to modify this Privacy Policy from time to time, so please review it regularly. If we make material changes to this Policy, we will notify you here and/or by a notice on our homepage prior to the changes becoming effective.

How to Contact Us

If you have questions or concerns regarding this Privacy Policy, please contact us at:

SmartUp Academy

Attn: Privacy Coordinator
Hasheizaf 4

Ra’anana 4366411, Israel

Phone: +972-54-3976696
Email: privacy@localhost

Last updated: 16 November 2022