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PLATFORM PRIVACY POLICY

Last Updated: July 7, 2019

1. INTRODUCTION

The Explorium Platform (the “Platform”) is a data science and predictive modeling platform that allows Explorium Ltd.’s (“Explorium” “us” “we”) customers to discover new data and predictive features and to build superior machine predictive models. The Platform enables Explorium’s customers to connect their data, define a prediction goal and automatically discover the most effective predictive data across a vast variety of internal and external databases. This way, Explorium empowers its customers in deploying more models that drive value in an array of decision-making junctions in their commercial activities.
This Platform Privacy Policy describes Explorium’s privacy practices in relation to the information collected from our customers and end users of our customers’ products and services (“End Users”) and received by Explorium when customers use our Platform. This Services Privacy Policy does not apply to information collected through use of Explorium’s publicly accessible website or marketing activities, which is described under our Website Privacy Policy. To view the Website Privacy Policy, please click here . Furthermore, Explorium and its customers have entered into agreements that govern the provision of services by Explorium and the use of the Platform by our customers (“Agreement(s)”). Such Agreements may contain additional obligations on the parties with respect to the handling of information. Nothing in this Platform Privacy Policy derogates from such additional obligations.

2. DATA RECEIVED AND PROCESSED BY EXPLORIUM

Customer End User Data:

When a customer uses the Platform, it has full discretion over the type of information it inserts to the Platform. As such, a customer may upload to the platform Technical Information, Behavioral Information and Personal Information as described below about its End Users (collectively, “Customer End User Data”).

Platform Data:

When a customer uses the Platform, we may collect certain information related to such customer, including customer name and customer details, billing information and names and contact details of customer employees and representatives who are using the Platform (e.g. email, phone number and address). We may also collect certain Technical and Behavioral Information of Customer and its employees or representatives (collectively “Platform Data”).

Customer End User Data and Platform Data may include:

i. “Technical Information”: this refers to technical information related to an End User’s or customer’s use of mobile device or computer, such as: type of browser, type of operating system, device type and model, system language, memory, OS version, Wi-Fi status, screen resolution, and IP address.
ii. Behavioral Information includes information related to an End User’s use of customer’s applications and services, or customer’s use of the Platform, including where an End User clicked, scrolled, focused (i.e. zoom), and navigated to a customer’s site or application. It may also include information related to whether you receive, opened or clicked on any links in an email sent to you.
iii. “Personal Identifiable Information”: This is information that directly or when combined or cross-referenced with other information, identifies an individual, such as names, addresses, credit cards or other financial information, health information, or any other type of sensitive personal information (“PII“). In some jurisdictions IP address may be considered PII.

3. HOW DATA IS COLLECTED

Information may be collected through various methods, including:
• When provided voluntarily by customer, for example, when a customer contacts us, or customer’s disclosure of End-User data as per customer’s own Privacy Policy.
Customers have sole control over their properties (including their websites and applications) and the means in which they collect PII from their End-Users. Customers insert information including PII to the Platform at their sole discretion and as required by them to assist them in their decision-making junctions and model building. Customers are solely responsible for obtaining permission from their End-Users to disclose their PII to us. When customers disclose PII to us we serve as their processing sub-contractor and process their data solely according to our customer’s instructions and authorizations as provided in the commercial agreements between us.
• We may use from time to time third-party analytics providers. Analytics providers are third-party companies that collect information when customers use the platform.
o We use FullStory analytics service to better understand our users use of our Platform. Fullstory’s privacy policy can be here.

• To the extent permitted by law, we may receive additional information such as corporate information, and geographic locations, contact details and other information through the various business support tools and services that we use (“Partners”) and public and open data sources such as, public web pages, social media sites, review sites, governmental listings. We may combine the Information received through these sources with other information we have in order to provide our customers with best of market platform.

4. HOW DATA IS USED BY EXPLORIUM

I. When Explorium receives Customer End User Data, it uses such Customer End User Data to enable customers optimal use of the Platform. Explorium serves a processing sub-contractor of any such End-User Data the customers provide to us as further provided in this privacy policy.
II. With regards to Platform Data we use such information to:
a. authenticate login to the Platform;
b. communicate with customers, including to inform customer of any updates to the Platform and services, including new features and functionalities;
c. to process any payments in connection with the Platform and our services;
d. to understand how customers are using the Platform so that we may efficiently audit, maintain and improve the Platform provided to customers and develop new features.
e. Explorium may use information derived from the aggregation of Customer End User Data and/or Platform with other data for research and analytics purposes and improvement and marketing of the Platform (“Aggregated Data”). Aggregated Data shall be anonymous and in no way reveal the identity of the customer or any End User.
f. send customers marketing materials related to the Explorium Platform that we believe may interest our customers such as a periodic newsletter emails or information about Explorium products and services. In some cases, you may have requested and/or consented to receive such materials. Otherwise we may send you such materials only where we have a lawful basis to do so – for example, when we have a legitimate interest to market our products and services to you. In any event, you will always be able to opt out of receiving such materials.
g. where it is necessary for Explorium to comply with its legal obligations and to exercise and enforce its legal rights.

5. SHARING DATA

Explorium does not share or disclose Platform Data and Customer End User Data with any third party, except with:

I. our subsidiaries as necessary to help us support and maintain the Platform and services provided to customers;
II. our data hosting provider. We store our information on Amazon Web Services. Such servers may be located worldwide. European users acknowledge and agree that PII may be transferred outside of the European Union to countries which laws may not offer the same protection as those of the European Union. Amazon web services’ privacy policy can be found at: http://aws.amazon.com/privacy/
III. our payment processors or other business operation service providers. Transfers to service providers are covered by the service agreements with our customers. These companies are authorized to use your personal information only as necessary to provide these services to us.
IV. Upon our customer’s request, e.g. to Partners who enable us to enrich our databases. Any such transfer is done pursuant to our agreements with our Partners and our agreements with our customers;
V. When legally required (e.g. court orders or other lawful requests by public authorities), including to meet national security or law enforcement requirements;
VI. To respond to, or prevent, fraud or to protect the safety of Explorium, its customers, End Users or the public;
VII. As part of any merger or acquisition of Explorium, in which case Customer End User Data may be transferred to the surviving or acquiring entity.

6. CROSS BORDER TRANSFERS

Explorium may need to transfer Platform Data and Customer End user Data to countries other than the country from which the Data originated. Any such transfer shall be done in compliance with all applicable laws.
EEA customers acknowledge and agree that by using the Explorium Platform customers consent to customer and End-User PII being sent and processed in other jurisdictions outside the European Union and European Economic Area, including the United States where there may be less stringent data protection laws.

7. INFORMATION SECURITY

Explorium takes great care in implementing and maintaining the security of the Platform and services, Platform Data and Customer End User Data (for the purpose of this section “Data”). The Data is hosted on our authorized third-party service providers, such as Amazon Web Services, which provide advanced security features. Explorium employs industry standard procedures and policies to ensure the safety of its Platform and the Data, and prevent unauthorized use of any of them. We are SOC2 certified. Notwithstanding the foregoing, as with any SAAS service, we cannot guarantee that unauthorized access will never occur.

8. DATA RETENTION

Explorium retains: (i) Customer End User Data for as long as required by our customer to use the Platform or as required or allowed by law; and (ii) Platform Data for no more time than is needed to serve the legitimate business need for which it was collected.

9. RELATIONSHIP, LAWFUL BASIS AND END USER CHOICES

Under the laws of certain jurisdictions, when processing PII of Customer End User Data in connection with the provision of the Platform and services to a customer, Explorium is deemed a ‘data processor’ while its customers are deemed ‘data controllers’. We process any PII solely for the purpose of providing the services as per our agreements with our customers and as per their instructions and authorizations provided in such agreements. Therefore, End Users should closely review the Privacy Policies of the applications, services and websites they use in order to learn about the privacy practices of our customers.

Where Explorium may be deemed a data controller under the laws of certain jurisdictions (e.g. in connection with its processing of Platform Data), Explorium shall comply with all applicable laws related to its status as a data controller and shall only use the data as described in this Platform Privacy Policy.

The lawful basis relied on by Explorium to process Platform Data is its legitimate interest: (i) to provide its customers using the Platform with more accurate analysis and better predictive models; (ii) to improve, personalize and market our Platform and to promote safety and security of our Platform. Explorium process Platform Data in order to perform the contract with our customers and, where appropriate, on consent obtained from customers.

EEA users have a number of legal rights with respect to their personal information such as accessing, updating and exporting personal data, editing and deleting personal data, in certain circumstances you can object to processing of your information, or to completely be deleted from our database.
Where Explorium is deemed a data processor, End Users should contact our customers to pursue any such legal data subject rights. Explorium will cooperate with its customers to support and comply with any such data subject rights requests.
Where Explorium is deemed a data controller, End Users may exercise their rights by contacting Explorium at: privacy@explorium.ai. We will respond to your requests within a reasonable timeframe. Please note these rights may be limited in certain circumstances as provided by applicable law.

10. CHANGES TO THE PRIVACY POLICY

Explorium reserves 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 policy on the homepage of the Explorium website at www.explorium.ai and/or we will send you an e-mail regarding such changes to the e-mail address that you provided us with, if applicable. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by email (if applicable). Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

11. HOW TO CONTACT US

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to contact us at: privacy@explorium.ai or Explorium Ltd., 23 Menachem Begin Rd., Tel-Aviv, Israel.

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