Privacy policy

WALABOT WEBSITE
DIY & MAKERS PRIVACY POLICY

Last Updated: July 7, 2025

In order to ensure transparency and give you more control over your Personal Data, this privacy policy (“Privacy Policy”) governs how we, Vayyar Imaging Ltd. (together, “Walabot”, “Vayyar”, “we”, “our” or “us”) use, collect, disclose, sell and store Personal Data we collect or receive from or about you (“you”) in connection with the use of the website walabot.com, together with its sub-domains (the “Site”), such as in the following use cases:

(i)                 When you browse or visit our Site

(ii)              When you make use of, or interact with, our Site

a.       When you complete a form to be a Walabot distributor or reseller

b.      When you are a University researcher and complete a form for research purposes

c.       When you complete a form to return a product

d.      When you contact us (e.g. customer support, help, submit a request)

e.       When you subscribe to our email list

(iii)            When you make use of, or interact with, our subdomain https://walabot.com (Site Store)

a.       When you purchase a product in our Site Store

b.      When you track an order

c.       When you make reviews or publish a question

d.      When you subscribe to our email list

e.        When you subscribe to receive updates regarding iOS on our Site Store

f.          When you subscribe to obtain a discount

(iv)             When you make use of, or interact with, our subdomainhttps://site.walabot.com (DIY Site)

a.       When you make reviews

b.      When you subscribe to our email list

(v)               When you make use of, or interact with, our subdomain https://site.walabot.com/makers (Makers Site)

a.       When you contact us to be a Maker partner

b.      When you make use of the Walabot API guidance and/or tutorials to better understand how to use our API (https://api.walabot.com/)

c.       When you decide to get started and download a Walabot SDK (e.g., Windows SDK, Linux SDK, RaspberryPi 3)

d.      When you subscribe to the email list

Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to certain individuals in certain jurisdictions, and may not apply to you For example, the legal basis in the table below is only relevant to GDPR-protected individuals and the "Do Not Sell My Personal Information" mechanism(s) below are only relevant for CCPA-protected individuals.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.


 

Table Of Contents

1.WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED.                                                                                                                                                                                                                                                                                                                                                                  3

When you make use of, or interact with, our Site 3

When you complete a form to be a Walabot distributor or reseller on our Site 3

When you are an University researcher and complete a form for research purposes on our Site 3

When you complete a form to return a product on our Site 3

When you contact us (e.g. customer support, help, submit a request) on our Site 3

When you subscribe to our email list on our Site 4

When you make use of, or interact with, our Site Store 4

When you purchase a product in our Site Store 4

When you track an order on our Site Store 4

When you make review or publish a question on our Site Store 5

When you subscribe to the email list on our Site Store 5

When you subscribe to receive updates regarding iOS on our Site Store 5

When you subscribe to obtain a discount on our Site Store 5

When you make use of, or interact with, our DIY Site 5

When you make reviews on our DIY Site 5

When you subscribe to our email list on our DIY Site 6

When you make use of, or interact with, our Maker Site 6

When you contact us to be a Maker partner 6

When you make use of the Walabot API guidance and/or tutorials to better understand how to use our API 6

When you decide to get started and download a Walabot SDK (e.g., Windows SDK, Linux SDK, RaspberryPi 3) 6

When you subscribe to the email list 7

2. PERIOD OF STORAGE OF COLLECTED PERSONAL DATA      7

3.HOW WE PROTECT AND RETAIN YOUR PERSONAL DATA      7

4.HOW WE SHARE YOUR PERSONAL DATA      7

5.ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA                                                                                                                                                                                                                                                                                                                                                                  7

6.YOUR PRIVACY RIGHTS    89

7.USE BY CHILDREN      89

8.INTERACTION WITH THIRD PARTY PRODUCTS    89

9.LOG FILES    89

10.ANALYTIC TOOLS    9

11.SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW        9

12. CONTACT US    10

 

 

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes 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 Site or by other means.

 


 

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

 

(i)     When you browse or visit our Site

  1. Specific Personal Data we collect: Cookies, pixels, analytic tools and log files. For more information, please read our cookies policy http://walabot.com/cookie-consent
  2. Purposes for which the Personal Data is being collected: Marketing, analytics, analysis, market research, to improve our Site
  3. Legal basis (GDPR only, if applicable): Consent; Legitimate interest (e.g. essential cookies)
  4. Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Google analytics, Hotjar, Zendesk, Wufoo, Mailchimp, Bing (Microsoft), Facebook, Google ads, Taboola, BazaarVoice, Pinterest, Google AdSense, LinkedIn (Microsoft), Salesforce, Funnel.io, TikTok, YAMM, CJ.com
  5. Consequences of not providing the Personal Data: Cannot collect and store the information; Cannot use or access some parts of the Site

 

(ii)  When you make use of, or interact with, our Site

a)      When you complete a form to be a Walabot distributor or reseller on our Site

1.      Specific Personal Data we collect: Full name, Email address, Company name, Distributor type, Type of product, Website, Comments, Any other information that you decide to provide/supply us with

2.      Purposes for which the Personal Data is being collected: To process your form; To assess you as a distributor or reseller; To contact you to have further discussions with respect to the form that you decided to complete

3.      Legal basis (GDPR only, if applicable): Processing is necessary for the performance of a contract with the data subject or in order to take steps at the request of the data subject prior to entering into a contract; Legitimate interest (e.g., to assess you as a distributor or reseller)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Wufoo (Form management tool), AWS (Storage – for backup), Salesforce (CRM)

5.      Consequences of not providing the Personal Data: Cannot process your form; Cannot assess you as a distributor or reseller; Cannot contact you to have further discussions with respect to the form that you decided to complete

b)     b. When you are a University researcher and complete a form for research purposes on our Site

1.      Specific Personal Data we collect: Full name, Email address, Company name, Comments and inquiry, any other information that you decide to provide/supply us with

2.      Purposes for which the Personal Data is being collected: To process your form; To assess you as a suitable university for research purposes; To contact you to have further discussions with respect to the form that you decided to complete

3.      Legal basis (GDPR only, if applicable): Processing is necessary for the performance of a contract with the data subject or in order to take steps at the request of the data subject prior to entering into a contract; Legitimate interest (e.g., to assess you as a suitable university for research purposes)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Wufoo (Form management tool), AWS (Storage – for backup), Salesforce (CRM)

5.      Consequences of not providing the Personal Data: Cannot process your form; Cannot assess you as a suitable university for research purposes; Cannot contact you to have further discussions with respect to the form that you decided to complete

c)      When you complete a form to return a product on our Site

1.      Specific Personal Data we collect: Full name, Shipping address, Email address, Order Id, Reasons for the return, Any other information that you decide to provide/supply us with

2.      Purposes for which the Personal Data is being collected: To process your form; To analyze your request to return a product; To contact you for the purpose of assisting you with respect to the return of the product

3.      Legal basis (GDPR only, if applicable): Processing is necessary for the performance of a contract with the data subject or in order to take steps at the request of the data subject prior to entering into a contract; Legitimate interest (e.g., to analyze your request to return a product)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Wufoo (Form management tool), AWS (Storage – for backup), Microsoft Sharepoint/OneDrive (Storage and Backup)

5.      Consequences of not providing the Personal Data: Cannot process your form; Cannot analyze your request to return a product; Cannot contact you for the purpose of assist you with respect to the return of the product or tracking your order

d)     When you contact us (e.g. customer support, help, submit a request) on our Site

1.      Specific Personal Data we collect: Full name, Email address, Attachments, Comments and messages, Any other information that you decide to provide/supply us with

2.      Purposes for which the Personal Data is being collected: To process and answer your questions; To provide support (e.g., to solve problems, bugs or issues); To customize your experience

3.      Legal basis (GDPR only, if applicable): Processing is necessary for the performance of a contract with the data subject or in order to take steps at the request of the data subject prior to entering into a contract; Legitimate interest (e.g., to process and answer your questions)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: AWS (Storage – for backup), Zendesk (Chat tool & CRM)

5.      Consequences of not providing the Personal Data: Cannot process and answer your questions; Cannot provide support; Cannot customize your experience

e)      When you subscribe to our email list on our Site

1.      Specific Personal Data we collect: Email address

2.      Purposes for which the Personal Data is being collected: To send you marketing communications

3.      Legal basis (GDPR only, if applicable): Consent

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Mailchimp (form and email management tool), AWS (Storage – for backup), Funnel.io, YAMM

5.      Consequences of not providing the Personal Data: Cannot send you marketing communications

 

(iii)                         When you make use of, or interact with, our Site Store

 

1.      Specific Personal Data we collect: Cookies, pixels, analytic tools and log files. For more information, please read our cookies policy http://walabot.com/cookie-consent

 

2.      Purposes for which the Personal Data is being collected: Marketing, analytics, analysis, market research, to improve our Site

 

3.       Legal basis (GDPR only, if applicable): Consent; Legitimate interest (e.g. essential cookies)

 

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Google analytics, Hotjar, Zendesk, Wufoo, Mailchimp, Bing (Microsoft), Facebook, Google ads, Taboola, BazaarVoice, Pinterest, Google AdSense, LinkedIn (Microsoft), Salesforce, Funnel.io, TikTok, YAMM, CJ.com

 

5.      Consequences of not providing the Personal Data: Cannot collect and store the information; Cannot use or access some parts of the Site

a)      When you purchase a product in our Site Store

1.      Specific Personal Data we collect: Shipping address (including, address, region, state or province, city, zip/Postal Code), Email Address, Full name, Company name, Phone Number, Shipping method, Payment method and details, Order Id, IP address and geo location (country and city), Any other information that you decide to provide/supply us with

2.      Purposes for which the Personal Data is being collected: To allow you to purchase our products; To process the order of your purchase; To ship your product; To perform/execute the agreement; To send you related communications to your order, the shipment and other relevant details

3.      Legal basis (GDPR only, if applicable): Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; Legitimate interest (e.g., to process the order of the purchase)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Shopify (e-commerce platform and other marketing tools), Magento (e-commerce platform and other marketing tools), Aero/DSL (Shipping), Paypal (Payment processor), Shopify Payments (Payment processor), TaxJar (Tax processor), Google Pay (Payment processor), Apple Pay (Payment processor), Funnel.io (analytics), Google Analytics

5.      Consequences of not providing the Personal Data: Cannot allow you to purchase our products; Cannot process the order of your purchase; Cannot ship your product; Cannot perform/execute the agreement; Cannot send you related communications to your order, the shipment and other relevant details

b)     When you track an order on our Site Store

1.      Specific Personal Data we collect: Email address, Order Id, Any other information that you decide to provide/supply us with

2.      Purposes for which the Personal Data is being collected: To help you to track your order; To assist you with the shipping method selected by you

3.      Legal basis (GDPR only, if applicable): Processing is necessary for the performance of a contract with the data subject or in order to take steps at the request of the data subject prior to entering into a contract; Legitimate interest (e.g., to help you to track your order)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: AERO (ships the order on our behalf), Funnel.io, Shopify (e-commerce platform and other marketing tools)

5.      Consequences of not providing the Personal Data: Cannot help you to track your order; Cannot proactively track your order and ensure it has been fulfilled; Cannot ship the order

c)      When you make review or publish a question on our Site Store

1.      Specific Personal Data we collect: Nick name, Review, questions and comments, Any other information that you provide/supply us with, such as if you are happy with the purchase and product(s)

2.      Purposes for which the Personal Data is being collected: To invite you to write a review of the purchased products; To allow you to publish questions of the products; To process and analyze your answers; To customize your experience

3.      Legal basis (GDPR only, if applicable): Legitimate interest (e.g. to respond your questions)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Bazaar Voice – a reviews management platform

5.      Consequences of not providing the Personal Data: Cannot invite you to write a review of the purchased products; Cannot allow you to publish questions of the products; Cannot process and analyze your answers; Cannot customize your experience

d)     When you subscribe to the email list on our Site Store

1.      Specific Personal Data we collect: Email address

2.      Purposes for which the Personal Data is being collected: To send you marketing communications

3.      Legal basis (GDPR only, if applicable): Consent

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Mailchimp form and Emails management tool, AWS - Storage – for backup, Funnel.io, YAMM

5.      Consequences of not providing the Personal Data: Cannot send you marketing communications

e)      When you subscribe to receive updates regarding iOS on our Site Store

1.      Specific Personal Data we collect: Full name, Email address

2.      Purposes for which the Personal Data is being collected: To send you updates and communications; To let you know when the iOS version will be available

3.      Legal basis (GDPR only, if applicable): Consent; Legitimate interest (e.g. to allow you to register to receive the updates)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Mailchimp form and emails management tool, AWS Storage – for backup, Funnel.io, YAMM

5.      Consequences of not providing the Personal Data: Cannot send you marketing communications

f)       When you subscribe to obtain a discount on our Site Store

1.      Specific Personal Data we collect: Email address

2.      Purposes for which the Personal Data is being collected: To allow you to obtain discounts; To send you an email with the discount

3.      Legal basis (GDPR only, if applicable): Consent; Legitimate interest (e.g. to allow you to subscribe to obtain discounts)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Mailchimp - form and emails management tool, AWS - Storage – for backup, Funnel.io, YAMM

5.      Consequences of not providing the Personal Data: Cannot send you marketing communications

(iv) When you make use of, or interact with, our DIY Site

1.      Specific Personal Data we collect: Cookies, pixels, analytic tools and log files. For more information, please read our cookies policy http://walabot.com/cookie-consent

2.      Purposes for which the Personal Data is being collected: Marketing, analytics, analysis, market research, to improve our Site

3.      Legal basis (GDPR only, if applicable): Consent. Legitimate interest (e.g. essential cookies)

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Google analytics, Hotjar, Zendesk, Wufoo, Mailchimp, Bing (Microsoft), Facebook, Google ads, Taboola, BazaarVoice, Pinterest, Google AdSense, LinkedIn (Microsoft), Salesforce, Funnel.io, TikTok, YAMM, and CJ.com.

5.      Consequences of not providing the Personal Data: Cannot collect and store the information. Cannot use or access some parts of the Site.

a)      When you make reviews on our DIY Site

1.      Specific Personal Data we collect: Nickname – full name, email address, location, device type, IP address, title of the review and the review/comments, and any other information that you decide to provide/supply us with.

2.      Purposes for which the Personal Data is being collected: To process your review and publish it in our Site(s) and social media channels; to process and analyze your answers; to improve our services.

3.      Legal basis (GDPR only, if applicable): Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to process your review).

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: BazaarVoice (review management platform) and Funnel.io.

5.      Consequences of not providing the Personal Data: Cannot process your review and publish it in our Site(s) and social media channels. Cannot process and analyze your answers. Cannot improve your services.

 

b)     When you subscribe to our email list on our DIY Site

1.      Specific Personal Data we collect: Email address.

2.      Purposes for which the Personal Data is being collected: To send you marketing communications.

3.      Legal basis (GDPR only, if applicable): Consent.

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: AWS (storage and for backup), Mailchimp (form and emails management tool), Funnel.io, and YAMM.

5.      Consequences of not providing the Personal Data: Cannot send you marketing communications.

 

(v)   When you make use of, or interact with, our Maker Site

1.      Specific Personal Data we collect: Cookies, pixels, analytic tools and log files. For more information, please read our cookies policy http://walabot.com/cookie-consent

2.      Purposes for which the Personal Data is being collected: Marketing, analytics, analysis, market research, to improve our Maker Site.

3.      Legal basis (GDPR only, if applicable): Consent. Legitimate interest (e.g. essential cookies).

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Google Analytics, Hotjar, Zendesk, Wufoo, Mailchimp, Bing (Microsoft), Facebook, Google Ads, Taboola, BazaarVoice, Pinterest, Google AdSense, LinkedIn (Microsoft), Salesforce, Funnel.io, TikTok, YAMM, and CJ.com.

5.      Consequences of not providing the Personal Data: Cannot collect and store the information. Cannot use or access some parts of the Site.

a)      When you contact us to be a Maker partner

1.      Specific Personal Data we collect: Full name, email address, company/organization name, type of partner, country, comments, and any other information that you decide to provide/supply us with.

2.      Purposes for which the Personal Data is being collected: To process your form; to assess you as a partner; to contact you to have further discussions with respect to the form that you decided to complete.

3.      Legal basis (GDPR only, if applicable): Processing is necessary for the performance of a contract with the data subject or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to assess you as a distributor or reseller).

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Wufoo (form management tool), AWS (storage – for backup), and Salesforce (CRM).

5.      Consequences of not providing the Personal Data: Cannot process your form. Cannot assess you as a distributor or reseller. Cannot contact you to have further discussions with respect to the form that you decided to complete.

b)     When you make use of the Walabot API guidance and/or tutorials to better understand how to use our API

1.      Specific Personal Data we collect: Cookies, pixels, analytic tools and log files. For more information, please read our cookies policy http://walabot.com/cookie-consent

2.      Purposes for which the Personal Data is being collected: Marketing, analytics, analysis, market research, to improve our Site.

3.      Legal basis (GDPR only, if applicable): Consent. Legitimate interest (e.g. essential cookies).

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Google Analytics, Hotjar, Zendesk, Wufoo, Mailchimp, Bing (Microsoft), Facebook, Google Ads, Taboola, BazaarVoice, Pinterest, Google AdSense, LinkedIn (Microsoft), Salesforce, Funnel.io, TikTok, YAMM, and CJ.com.

5.      Consequences of not providing the Personal Data: Cannot collect and store the information. Cannot use or access some parts of the Site.

c)      When you decide to get started and download a Walabot SDK (e.g., Windows SDK, Linux SDK, RaspberryPi

1.      Specific Personal Data we collect: Details of the Walabot SDK downloaded

2.      Purposes for which the Personal Data is being collected: To allow you to download a Walabot SDK.

3.      Legal basis (GDPR only, if applicable): Processing is necessary for the performance of a contract with the data subject or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g., to enable customers to download the servers).

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Cookies. For more information, read our cookie policy http://walabot.com/cookie-consent

5.      Consequences of not providing the Personal Data: Cannot allow you to download a Walabot SDK.

d)     When you subscribe to the email list

1.      Specific Personal Data we collect: Email address.

2.      Purposes for which the Personal Data is being collected: To send you marketing communications.

3.      Legal basis (GDPR only, if applicable): Consent.

4.      Third parties with whom we share your Personal Data: 3rd party platforms such as for the following purposes: Mailchimp (form and emails management tool), AWS (storage and backup), Funnel.io, and YAMM.

5.      Consequences of not providing the Personal Data: Cannot send you marketing communications.

 

Finally, please note that some of the abovementioned Personal Data will be used for fraud detection and prevention, and for security purposes. The abovementioned Personal Data will also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims, if necessary. In certain cases, we will anonymize your Personal Data. Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).  

 

2.      PERIOD OF STORAGE OF COLLECTED PERSONAL DATA

 

Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively deleted or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

 

3.      HOW WE PROTECT AND RETAIN YOUR PERSONAL DATA

 

3.1.   Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information 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 information.

 

3.2.   Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we will 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. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies, you can read more in our cookie policy http://walabot.com/cookie-consent.

 

4.       HOW WE SHARE YOUR PERSONAL DATA

 

In addition to the recipients described above, if necessary, we will share your Personal Data as follows:

 

4.1.   With our business partners with whom we jointly offer products or services. We will also share Personal Data with our affiliated companies.

4.2.   To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

4.3.   If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;

4.4.   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, disclose or assign your Personal Data in connection with the foregoing events; and/or

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

 

If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to privacy@walabot.com.

 

5.      ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

 

5.1.   Storage: Microsoft Azure, Google Cloud, and AWS.

 

5.2.   Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

 

5.3.   Internal transfers: Transfers within the Vayyar group will be covered by an internal processing agreement entered into by members of the Vayyar group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

 

5.4.   External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Data. For more information about transfers please contact us at: privacy@walabot.com.

 

6.      YOUR PRIVACY RIGHTS

 

6.1.   Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR:

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

o   You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;

o   You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;

o   You have the right to object, to or to request restriction, of the processing;

o   You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;

o   You have the right to object to profiling;

o   You have the right to withdraw your consent at any time. Please note that 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. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

o   You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;

o   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 or before the relevant institutions in your place of residence We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

6.2.   The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals protected by the CCPA:

o   You have the right to know what Personal Information is being collected about you, this includes the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell;

o   You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;

o   You have the right to know whether your Personal Information is sold or disclosed and to whom;

o   You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;

o   You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA;

o   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 or before the relevant institutions in your place of residence (e.g., the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution. You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.

 

6.3.   You can exercise your rights by contacting us at privacy@walabot.com.  You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. 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.

 

7.      USE BY CHILDREN

 

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@walabot.com.

 

 

8.      INTERACTION WITH THIRD PARTY PRODUCTS


We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

 

9.      LOG FILES

We use log files. The information inside the log files include internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

 

10.  ANALYTIC TOOLS

 

  • Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.
  • Facebook Custom Audience. We provide Facebook certain data about users. Facebook does not disclose to us which individual user comprises our Audience (as defined in the Custom Audience terms). Our use of this tool is subject to the following terms: https://www.facebook.com/legal/terms/customaudience. You may opt out of this tool according to the instructions available at: https://www.facebook.com/ads/settings.
  • Google Ads Similar Audience. We use this tool in order to personalize our ads. Google uses cookies and/or device identifiers to serve ads based your past visits to our Site and/or apps, on our behalf. You can opt out of Google's use of cookies or device identifiers by visiting Google's Ads Settings. Alternatively, opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device’s settings.
  • Advertising Partners. Through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.
  • Google Analytics. The Site uses a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other websites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • Hotjar. The Site uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Site). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.
  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to us to integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from websites you visit and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Business Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  • Facebook Conversion API. We use Facebook Conversion API in order to match the contact information against user IDs (“Matched User IDs”), as well as to combine those user IDs with corresponding event data (which is information about the your use of our website and app). We use Facebook Conversion API in order to receive reports, generate analytics and insights about people and their use of our Site Store, to improve ad targeting and delivery optimization of our ad campaigns in relation to the Site Store. You can prevent your data from being used by Facebook Conversion API by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

·         Fini Technologies. We use Fini Technologies to analyze user interactions on our Site and to improve customer engagement. Fini Technologies may collect information about your usage patterns, device information, and interactions with the Site to help us better understand user behavior and enhance our services. The data collected by Fini Technologies is used solely for analytics and customer support purposes and is handled in accordance with applicable privacy laws and user consent preferences. For more information about Fini Technologies’ data protection practices, please visit: https://www.usefini.com/company/data-protection. For Fini Technologies’ terms of service, please visit: https://www.usefini.com/company/terms.

·         Little Data. We use Little Data to help organize and analyze visitor information from our Site and to improve the accuracy and effectiveness of our analytics and advertising. Little Data may collect information about your interactions with our Site, including device and usage data, to help us better understand user behavior and optimize our marketing efforts. Little Data processes data in accordance with applicable privacy laws and user consent preferences. For more information about Little Data’s privacy practices, please visit: https://www.littledata.io/privacy-policy.  For Little Data’ terms of service, please visit: https://blog.littledata.io/terms/.

 

We reserve the right to remove or add new analytic tools.

11.  SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

 

11.1.                    This Privacy Policy for California Residents supplements and is expressly made part of the information contained in this Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Privacy Policy to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.

 

11.2.                    California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@walabot.com. Please note that we are only required to respond to one request per customer each year.

 

 

11.3.                    Our California Do Not Track Notice (Shine the Light): Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

 

12.  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@walabot.com.