Privacy Policy

Last Updated: May 18, 2023 

DEVELEAP LTD. – PRIVACY POLICY 

Privacy 

Develeap Ltd. a company incorporated under the laws of Israel (hereinafter: “Develeap”, “we”  or “us”) is committed to collecting, maintaining, and securing personal information (as defined  below) about you in accordance with the law. This policy applies to personal information  collected from our online resources and communications, such as web sites, apps, e-mail, 

comeet (a recruiting and applicant tracking platform that handles your personal data as a  candidate for a position in the company), and other online and downloadable tools (the  “Platform”), that display a link to this policy. This policy does not apply to personal  information collected from offline resources and communications, except in cases where such  personal information is consolidated with personal information that we, or others on our behalf,  collect online.  

Develeap has created this Privacy Policy to let you know what information we collect when  you visit and/or use our Platform, how we collect it and how we make use of it. 

When you access or use our Platform you are required to read this Privacy Policy,  understand what will be made with your personal Information and how it will be  processed, and you understand that your use of the Platform is subject to your acceptance  of this Privacy Policy. 

Personal Information” – applies to any data relating to an identified or identified individual,  including data that identifies that identifies an individual or that could be used to identify, locate  or track behaviour or preferences of an individual.  

The headings in this Privacy Policy are intended strictly for convenience and shall not be used  to interpret its provisions. 

Personal Information Collected 

Develeap collects and stores your Personal Information such as your name, contact details,  mailing and delivery addresses, email address, phone number, and any other personally  identifiable information which you have provided us in any forms you may have submitted to  us, or in the course of any other forms of interaction between you and us, to the extent it may  be considered Personal Information (see below what may not be considered Personal  Information). Apart from the Personal Information collected as stated above, we also collect  and store Personal Information on candidates, inter alia, CV, recommendations, and  information regarding the candidate’s success in the recruitment process. We also collect additional data which is certain administrative and traffic data including without limitation:  source IP address, time of access, date of access, web page(s) visited, language used, type of  browser used, and any data required to ensure your use of the Platform is compliant with the  applicable terms of use. Develeap collects and stores the aforesaid Personal Information when  you visit the Platform and in every communication with us. 

You are responsible for ensuring the accuracy of your Personal Information you submit to  Develeap through the Platform. Inaccurate information will affect the information you receive when using the Platform and Develeap’s ability to contact you as contemplated in this Privacy  Policy. 

In addition, please note that this Privacy Policy does not cover the following information as it  is not considered Personal Information:  

• Information relating to a legal entity (e.g. corporate information, contact details, accounting  information, etc.); 

• Anonymised data – means information that does not relate to an identified or identifiable  person or to Personal Information rendered anonymous in such a manner that the data is  not or no longer identifiable.  

The information we collect is required for us to provide you with our services. As detailed  bellow, you may request that we erase or refrain from processing your information but note  that this may prevent us from providing you with our services. 

Use of Personal Information 

Develeap uses Personal Information collected online to provide services you requested to  receive and other resources that individuals requested; for example, related information about  Develeap business, e-mail programs and tools, for providing customer support, undertaking  necessary security and identity verification checks, and/or for other internal purposes, such as  evaluating, providing, and improving the Platform. 

Sharing and Transfer of Your Personal Information 

Usually, a sharing of Personal Information may occur (i) if you have requested and/or agreed  that the Personal Information will be provided to third parties; or (ii) if the disclosure is required  or permitted by law; or (iii) the transfer is necessary in order to protect the vital interests of the  data subject; or (iv) the transfer is necessary or legally required on important public interest  grounds, or for the establishment, exercise, or defence of legal claims. 

Without derogating from the above, Develeap may disclose your Personal Information to  associated entities and/or to third parties, i.e. service providers which provide us services with  respect to the Platform, server providers, recruiting companies, analyzers, law enforcement  authorities, and administrative and regulatory bodies, at Develeap’s sole discretion, where the  purpose of such disclosure is to provide you with the Develeap’s services and to improve the  Platform. 

In addition, Develeap may disclose your Personal Information if Develeap believes in good  faith that such action is necessary to comply with the following: applicable legislation; a current  judicial proceeding; a court order or legal process; or in order to protect and defend Develeap’s  (or its licensor’s) rights or property, and the personal safety of other users of the Platform or  the public. Develeap reserves the right to share the Personal Information with appropriate  authorities and financial institutions, if Develeap determines at its sole discretion that you  attempted to defraud Develeap, or if Develeap suspects you are committing any fraudulent  activity, or any other prohibited transaction. 

If Develeap decides for business reasons to reorganize or divest its business through sale,  merger, or acquisition, Personal Information may be shared with actual or prospective purchasers. We will obtain written assurances that Personal Information will be protected  appropriately in these circumstances. Except as provided in this Privacy Policy, Personal  Information about you will not otherwise be shared without your permission.  

International Transfers. Some transfers of data may be located at destinations outside of your  state, province, or country, and if you are a resident of the European Union, such as outside the  European Economic Area. The data protection and privacy laws of the jurisdictions to which  the Personal Information will be transferred may not be as comprehensive as those in your sate  or as comprehensive as those of the European Union (if applicable to you), we will do our best  to send your information only to countries that have strong data protection laws. If you would  like more information about where your information might be sent, please contact us according  to the contact information provided below. 

Your Personal Information collected by Develeap may be processed or accessed in the  country/region where you use our Platform or in other countries/regions where Develeap or its  affiliates, subsidiaries, service providers or business partners have a presence.  

If you are in the European Union, accordingly, we may transfer your Personal Information to  third parties located at destinations outside the European Economic Area and in such case,  Develeap will take measures to ensure that a similar level of protection is provided to your  Personal Information according to one of the following safeguards: 

(a) Personal Information is transferred to countries that the European Commission has  identified as countries ensuring an adequate level of protection of Personal Information; 

(b) In case such transfer is occurred to a country which the European Commission did not  identify as a country which ensures an adequate level of protection, we will apply relevant  standard contractual clauses approved by the European Commission; or we will rely on  binding corporate rules which guarantee the security of your data. 

Cookies 

When you visit the website, it may store or retrieve information on your browser, mostly in the  form of cookies. This information might be about you, your preferences or your device and is  mostly used to make the site work as you expect it to. The information does not usually directly  identify you, but it can give you a more personalized web experience. Because we respect your  right to privacy, you can choose not to allow some types of cookies. Click on the different  category headings to find out more and change our default settings. However, blocking some  types of cookies may impact your experience of the Platform.  

The cookies are used by a third party provider. 

We use different types of cookies in our website, inter alia, as detailed below. Some or all of  the cookies may be stored in your browser. You can view and manage cookies in your  browser (though browsers for mobile devices may not offer this visibility). 

Strict Necessary Cookies – These cookies are necessary for the website to function and cannot  be switched off in our systems. They are usually only set in response to actions made by you  which amount to a request for services, such as setting your privacy preferences, logging in or  filling in forms. You can set your browser to block or alert you about these cookies, but some  parts of the site will not then work. These cookies do not store any personally identifiable  information.

Performance Cookies – These cookies allow us to count visits and traffic sources so we can  measure and improve the performance of our site. They help us to know which pages are the  most and least popular and see how visitors move around the site. All information these  cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we  will not know when you have visited our site, and will not be able to monitor its performance. 

Targeting Cookies – These cookies may be set through our site by our advertising partners.  They may be used by those companies to build a profile of your interests and show you relevant  adverts on other sites. They do not store directly personal information, but are based on  uniquely identifying your browser and internet device. If you do not allow these cookies, you  will experience less targeted advertising. 

You are able to approve or disapprove the use of cookies, and manage the cookies according  to the different types of cookies detailed above. 

For more details about the cookies that will be used click the following link in order to examine  our cookies policy https://www.develeap.com/cookies-policy/.  

Security 

Develeap has implemented suitable security policies, rules and technical measures to protect  and safeguard the Personal Information under its control from unauthorized access, improper  use or disclosure, unauthorized modification, unlawful destruction or accidental loss. Develeap may use third party vendors and hosting partners to provide the necessary hardware, software,  networking, storage, and related technology required. These may be located at destinations  outside the European Economic Area. By submitting your Personal Information, you agree to  the mentioned above. All of Develeap’s employees and data processors that have access to,  and are associated with the processing of your Personal Information, are obligated to respect  the confidentiality of your Personal Information. However, we cannot guarantee the security  of your data, which may be compromised by unauthorized entry or use of the website. 

Reasonable physical, technical, and procedural measures shall be taken to: 

• Prevent and/or to identify unauthorized or unlawful collection, processing, and transmittal  of Personal Information; and 

• Prevent accidental loss or destruction of, or damage to, Personal Information. Links to Other Sites 

Our Platform may contain links to other sites. Develeap is not responsible for the privacy  practices or the content of such other online sites, and any information collected by these third  parties online sites is not governed by this Privacy Policy, and Develeap assumes no  responsibility or liability whatsoever for the policies (including privacy policies), practices,  actions or omissions of such third parties. 

Rights with respect to the Personal Information 

In certain circumstances, you have rights in relation to the Personal Information that we hold,  all in accordance with the following:  

Please note that we will require you to verify your identity before responding to any requests  to exercise rights. To exercise rights with respect to the Personal Information, please contact us through our contact information provided below. Please note that for each of the following  rights, we may have valid legal reasons to refuse such requests, in such case, we will let you  know.  

(a) The right to access the Personal Information, including the right to obtain a copy of such  data; 

(b) The right to request to modify or update the Personal Information if the Personal  Information is incorrect or incomplete; 

(c) The right to request the permanent removal of the Personal Information in the following  circumstances: (i) the data subject believes it is no longer necessary for Develeap to hold  the Personal Information, (ii) Develeap is processing the Personal Information based on  the data subject consent and the data subject wishes to withdraw its consent, (iii) Develeap 

is Processing the Personal Information based on Develeap’s legitimate interest and the data  subject refuses to such processing, (iv) the data subject no longer wish Develeap to use the  Personal Information to send the data subject marketing materials or (v) the data subject  believes that Develeap is processing its Personal Information unlawfully.  

(d) The right to receive a subset of the Personal Information provided to Develeap in a  structured, commonly used and machine-readable format and the right to request that  Develeap will transfer such Personal Information to a third party if Develeap processed  the Personal Information based on the data subject’s consent and when the processing is  carried out by automated means; 

(e) The right to object to the processing of the Personal Information we hold regarding the  data subject.  

In some cases, where we are required to retain information by law or regulation, or to continue  to manage a service you have requested, or to ensure that we honor your preferences, or for  other necessary business purposes, we may not be able to delete certain personal information  about you. Where offered, you also may update personal information about you online by 

modifying information that you previously have entered into forms or data fields on our  website. Where permitted by law, your ability to access and correct personal information will  be limited where access and correction would: inhibit our ability to comply with a legal or  ethical obligation, inhibit our ability to investigate, make or defend legal claims, result in  disclosure of personal information about a third party, result in breach of a contract or  disclosure of trade secrets or other proprietary business information belonging to us or to a  third party. 

Retention and Deletion of Your Personal Information 

We generally retain personal information for as long as reasonably needed for the specific  business purpose or purposes for which it was collected and the duration of your use of our  websites, apps and other relevant online tools. In some cases, we may be required to retain  information for a longer period of time based on laws or regulations that apply to our business,  such as applicable rules on statute of limitations or for other necessary business purposes.  Where possible, we aim to anonymize the information or remove unnecessary identifiers from  records that we may need to keep for periods beyond the original retention period. 

Notwithstanding the above, the Personal Information will not be kept for a period exceeding one (1) year as of the date the Personal Information was first collected. 

Marketing Emails 

You can opt out of marketing emails by utilizing the “unsubscribe” link or other mechanism  noted in marketing emails you receive from Develeap. You may also request to opt out of  marketing emails, including those regarding offers from third parties, by contacting us through  one of the methods specified in the Contact Information section below, and sharing the email  address at which you are receiving marketing emails. 

Lawful Bases for Processing 

We will collect and use Personal Information about you where we have the following lawful  bases: 

• You have provided consent; 

• Processing is necessary for performance of a service you requested, and Develeap needs to process your Personal Information to comply with Develeap’s obligations; • Processing is necessary for compliance with a legal obligation; 

• Processing is necessary in order to protect your vital interests; 

• Processing is necessary for legitimate interests of Develeap or by the third party or parties  to whom your Personal Information is disclosed, except where such interests are  overridden by your fundamental rights.  

Modifications to this Privacy Policy 

Develeap reserves the right to make, from time to time, changes and updates to this Privacy  Policy. You are responsible for fluently reviewing information posted online to obtain timely  notice of such changes. If you do not agree to the altered Privacy Policy, you must stop using  the Platform immediately. 

Complaints 

In the event that you wish to learn more about our data privacy practices or to submit a  complaint about how Develeap processes your Personal Information, please contact Develeap in the first instance (see ‘Contact Information’ chapter below). 

You shall also have the right to launch a claim to the data protection supervisory authority in  the European Union country in which you live or work if you believe Develeap has infringed  data protection laws. 

Contact Information 

If you wish to learn more about our data privacy practices or to make a complaint about how  Develeap processes your Personal Information, please contact us in the first instance:  

• At the following email address saar.cohen@develeap.com ; or linay@develeap.com. 
• Our offices address at 9 Dvora HaNevi’a St., Kfar Saba, Israel. 

We will do our best to respond to your inquiry as soon as possible.  

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