SparkBeyond SparkBeyond

Privacy Policy

This privacy policy (“Privacy Policy”) governs how we, SparkBeyond Ltd. (“SparkBeyond”, “data controller”, “we”, “our” or “us”) use, collect and store personal data pertaining to you (“you”) in a business context or as a result of your business interactions with you (“Personal Data”). For example, this Privacy Policy deals with the following use cases:

✓ When you exchange business cards or email’s with us;

✓ When you attend a marketing event or trade show and provide us with Personal Data; and

✓ When we acquire your Personal Data from third-party sources (such as lead-generation companies).

Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. Table of contents:

● What Information we Collect, Why we Collect it, and How it is Used;

● How we Protect and Store your Personal Data;

● How we share your Personal Data;

● Additional Information Regarding Transfers of Personal Data

● Your Rights

● Use by Children

● How to Contact Us This Privacy Policy may be updated from time to time and, therefore, we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Data We Collect Why is the data collected and for what purposes? Legal basis Third Parties with whom we Share your Data Period of Storage Consequences of not providing the data
First Name Last Name

Email Address Employers company name

Any Information you might choose to share with us in order to use our system, or receive professional services from us

To offer you potential deals and send you marketing and commercial communications.

Pre-sale services.

Ongoing engagements/projects.

Respond to your requests and/or questions.

Pre-contractual negotiations.

Necessary for the purpose of our legitimate interest market, promote and demonstrate our services, that you may seek or we think might be of interest to you/your company.

CRM platforms (such as Salesforce)

Gmail Suite

Hosting Services (Such AWS)

We will not use your personal data for any longer than needed in order to fulfil the purposes described in this Privacy Policy. After that, we will delete or permanently de-identify your personal data unless required or entitled by law to retain it, or parts of it, as further described in Section 2 We will not be able to contact you, offer you deals, or engage in business discussions with you

2. HOW WE PROTECT AND STORE YOUR INFORMATION

Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such Personal Data appropriate to the nature of the Personal Data concerned. However, please note that we cannot guarantee that the Personal Data will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such Personal Data consistent with this Privacy Policy and all applicable laws and regulations. As the security of Personal Data depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this Personal Data.

Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

3. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described in Section 1, we may share your Personal Data as follows:

● To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

● If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose Personal Data to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

● Where we transfer your Personal Data outside of SparkBeyond, for example to third parties mentioned in Section 1 above, we will obtain contractual commitments from them to protect your Personal Data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States. We bring to your attention that Israel is a country declared as offering adequate level of data protection (see here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)

● Where we receive requests for Personal Data from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

● Where you have provided your consent to us using the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

5. YOUR RIGHTS

● Among others, the following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR:

✓ You have a right to access Personal Data held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

✓ You have the right to request that we amend any Personal Data we hold that it is inaccurate.

✓ You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims.

✓ The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request.

✓ You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority

✓ The right to withdraw your consent. Again, there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.

✓ You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

● You can exercise your rights by contacting us at privacy@sparkbeyond.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further Personal Data in order to fulfil your request. When processing your request, we may ask you for additional Personal Data to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

● In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

6. USE BY CHILDREN

We do not offer our products or services for use by children. If you are under 18, you may not provide us with any Personal Data without involvement of a parent or a guardian. We do not knowingly collect Personal Data from, and/or about children.

7. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@sparkbeyond.com.

You can read more about your rights here: https://ec.europa.eu/info/law/law-topic/data-protection_en