PRIVACY POLICY

Last revised on November 24th, 2020.

Introduction

We, at Keylabs A.I Ltd., a company registered in Israel ("we", "us", "our", or "Keylabs"), respect the privacy of individuals ("you" or "your") from whom we collect Personal Information.

This privacy policy sets out the way we collect, use and share Personal Information from the following audiences:

Visitors – individuals who visit or otherwise interact with our websites, available at [please specify all web addresses], or any other website, webpage, e-mail, text message or online ad under our control (collectively - “Websites”);
Users – individuals who are authorized to use our software and/or our platform (collectively and together with our Websites – "Service"), including (without limitation) on the behalf of our Customers.
Customers – individuals who contact Keylabs on behalf of companies that subscribe or receive access to our Service.

Collection and Storage of Your Personal Information

We may collect and use the following types of information about you:

Personal Information

Personal Information is information that identifies an individual or that may, with reasonable effort, identify an individual. We gather the following types of Personal Information:

Personal Information Collected from all types of audiences:
1. Device information: We collect from our Visitors, Users and Customers specific types of connection details and information with regard to their device, software or hardware that may identify them, such as: online identifiers, device unique identifiers (e.g. UDID, MAC address), IP address and geolocation.
2. Analytics data: Our servers automatically record certain information regarding the use of our Service. Such data may include information such as the website that you were visiting before accessing our Service and other statistics related to our Service. We also perform statistical analysis on all of the data and metadata which is collected through our Service. We use this information to administer the Service and analyze this information to improve and enhance the Service by expanding their features and functionality. Such data is also used for troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Service.
3. Communication information: We collect from our Visitors, Users and Customers, information from their communication with our support team via email, WhatsApp, calls, Zoom, Skype or other means of communication.
4. Voluntary information: We collect Personal Information that Visitors, Users and Customers provide us voluntarily. For example, when they respond to communications from us, or when they share additional information through their use of the Service.
Personal Information Collected only from Users:
1. Registration details received from Users: When you sign up to the Service and create your individual profile (“User Profile”), you or provide us with certain Personal Information, including:
  1. Full name
  2. Home address
  3. Phone number
  4. Email address
  5. Company
  6. Title
  7. Details of the of the entity to which are engaged
  8. Credit card details
  9. Voluntary information you chose to provide us, including your gender, date of birth and a profile image.
    (collectively, “User Data”).
2. User Data received from our Customers: If our Customer has subscribed you to our Service on its behalf, such Customer may provide us with certain Personal Information about you, such as your name, title, phone number and e-mail, in order for us to contact, invite or subscribe you as a User to our Service. Nevertheless, additional data may be provided at the discretion of those providing it. For the purposes of this privacy policy, this data will also be regarded as “User Data”.

Personal Information Collected only from Customers:
1. Customer Data: When a Customer tries, purchases, uses, subscribes to our Service, or obtains support for our Service, Keylabs collects data to provide the Service, to provide the best experiences with our Service and to communicate with our Customers. Such data can include Personal Information, such as contact details of the Customer's designated point of contact.

We also collect Personal Information about you from other sources, such as orders placed by you or from third-party mailing lists. Our partners who obtain this Personal Information will have informed you, at the point of collection, that they are collecting the Personal Information (in part) for us and that the information will be provided to us. Any of your Personal Information we collect from other sources will be stored and used in accordance with this Privacy Policy.

Non-personal Information

Non-personal Information is non-identifiable information that, when taken alone, cannot be used to identify you. As such, we are not aware of the identity of the user from which the Non-personal Information was collected.

We may anonymize or de-identify the information collected by the Service or via other means so that the information cannot, on its own, personally identify you. We also collect aggregate user data regarding your use and activity of/on our Service. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this privacy policy and we may disclose it to others without limitation and for any purpose.

For the avoidance of doubt, if we combine Personal Information with Non-personal Information (e.g. analytics data), the combined information will be treated as Personal Information as long as it remains combined.

How we Use Personal Information

In addition to the purposes listed herein, the Personal Information we collect is used for the following purposes:

to set up Users' account and to provide the Service;
to identify and authenticate Users' access to our Service;
to provide our Visitors, Users and Customers with assistance and support;
to personalize our Service;
to analyze and report on Users' performance;
to provide you with information about related products and services, based on the preferences you have indicated (see more under "Marketing");
to serve you advertisements that are relevant to you and your interests, regarding our Service (see more under “Advertisement”);
to conduct research and improve our Service;
for systems administration and troubleshooting purposes;
to communicate with you and to keep you informed of our latest updates;
to examine job applications we receive via the Website;
to investigate and resolve disputes in connection with your use of the Service;
to detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Service;
and
to investigate violations and enforce our policies and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

With whom do we share the Personal Information we collect?

Your Personal Information may be shared with members of our group, our Customers and with third-parties:

We engage selected third party companies and individuals to perform services complementary to our own. Such service providers include, storage services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems and our legal and financial advisors (collectively, “Service Providers“). These Service Providers may have access to your Personal Information, depending on each of their specific roles and purposes in facilitating and enhancing our Service and may only use it for such limited purposes as determined in our agreements with them.
Basic demographic data including name, address, phone, email, company, title and related information may be disclosed to marketing partners (including but not limited to Google ‘Adwords’, Facebook ‘Ads’ and LinkedIn ‘Insights’). You can prohibit this using the steps set out in the “Marketing” section.
Personal Information concerning Visitors' usage of our Websites and Users' progress using our study materials may be disclosed to third parties such as educational institutions, professors and product development partners. If your company has sponsored your attendance or certification, we will also share progress (started, in progress, completed) course data and successful certification outcomes with the Customer that owns your account.
if we are discussing selling or transferring part or all of our business, the Personal Information may be transferred to prospective purchasers under suitable terms as to confidentiality;
if we are reorganized or sold, Personal Information may be transferred to a buyer who can continue to provide the Service to you;
if we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police; or
if we are defending a legal claim your Personal Information may be transferred as required in connection with defending such claim.

Third-parties who we may share your Personal Information with will be required to meet our standards on processing information and security. The Personal Information we provide them will only be provided in connection with the performance of their function.

Why we use your Personal Information

If you are an individual from the European Economic Area ("EEA"), please note that our legal basis for collecting and using your Personal Information will depend on the Personal Information collected and the specific context in which we collect it. We normally collect Personal Information from you only where: (a) we have your consent to do so, (b) where we need your Personal Information to perform a contract with you (e.g. to deliver the Service you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such Personal Information under applicable laws.

In some cases, we may need the Personal Information to protect your vital interests or those of another person.

Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Information, you have the right to object.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.

Cookies

When you visit or access our Service we use (and authorize 3rd parties to use) pixels, cookies, events and other technologies (collectively, "Tracking Technologies"). Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Service, improve our Service's performance, perform analytics and customize your experience. In addition, we may merge data we have with data collected through these tracking technologies and data we may obtain from other sources and, as a result, such data may become Personal Information. For more information about the cookies we use please read our cookie policy, a copy of which can be found here [insert hyper link].

Marketing

We may use your Personal Information, such as your full name, email address, etc. ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our Service. Out of respect to your right to privacy, we provide you within such marketing materials with means to decline receiving further marketing offers from us. You may prohibit sharing of your Personal Information to our marketing by following these steps: [Please specify] In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to [Please insert email]. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you Service-related updates and notifications.

Through our Service, we may provide advertisements that are tailored to you, for example ads that are based on your recent browsing behavior across different websites, browsers, or devices.

Furthermore, in order to target advertisements to you for products and services in which you might be interested at, we, as well as certain third parties, may use Tracking Technologies to display advertisements based on your visits to Service, to target advertisements to you for products and services in which you might be interested and to measure the effectiveness of such ads. These Tracking Technologies are governed by each third party’s specific privacy policy, not this one.

You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/. [Relevant?]

Your Rights

If you are an EU resident, you have certain rights in relation to your Personal Information:

To receive confirmation as to whether or not Personal Information concerning you is being processed and access your stored Personal Information, together with certain supplementary information.
To receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.
To request rectification of your Personal Information that is in our control.
To request erasure of your Personal Information.
To object to the processing of Personal Information by us.
To request to restrict processing of your Personal Information by us.

However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint on how we have handled your Personal Information, you can contact us at [Insert email address].

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.

For how long do we retain the Personal Information that we collect?

We retain the Personal Information that we collect from Visitors, Users and Customers for as long as needed to provide our Service and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods will be determined taking into account the type of the Personal Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Personal Information at the earliest reasonable time. Under applicable regulations, we will keep records containing your Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.

International Transfer

Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the EEA. In these instances, we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

How do we safeguard your Personal Information?

We take great care in implementing and maintaining the security of the Service and your Personal Information. We employ industry standard procedures to ensure the confidentiality, integrity and availability of our Users' data, safety of your Personal Information and prevent unauthorized use of any such information.

However, we cannot guarantee that hackers or unauthorized personnel will not gain access to Personal Information despite our efforts. You should note that by using our Service, your Personal Information will be transferred through third party infrastructures which are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

We reserve the right to access and verify any Personal Information which is collected from you by us. In the event that we become aware that an individual under the age of 16 shared any Personal Information, we will discard such information. If you have any reason to believe that a minor shared any Personal Information with us, please contact us at [Insert email address].

Minors

The Service is not designated to individuals under the age of 16. If you are under 16 you should not use the Service nor provide any Personal Information to us.

Changes to the policy

We reserve the right to change this Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy through our Websites or we will send you an e-mail regarding such changes to the e-mail address that you volunteered (if you have volunteered it). Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Policy are effective as of the stated “Last Revised” date and your continued use of the Service after the Last Revised date will constitute acceptance of and agreement to be bound by, those changes.

How to contact us

If you have any questions about this policy, please contact our Data Privacy representative at [Insert email address].

If you reside in the EU, you may also approach our EU representative, [Please insert details of representative], regarding matters pertaining to the GDPR by:

[Insert email address and contact details]

[let's discuss]