v1.2020

Aidodys

Privacy Policy

 

AM Business SAS (a Contentsquare Group subsidiary) (“AMW“, “we“, “our” or “us“) develops and provides the Aidodys platform.

Aidodys is a customizable platform to adapt all types of content according to a reading profile and disabilities.

We provide such services through the AMW website (available at https://aidodys.com/, “Site”), and the Aidodys platform available therein (“Platform”; and collectively – “Services”).

We respect the privacy of our Site visitors (“Visitors”), our customers and their personnel (“Customer”; and collectively - “you”), as well as our Customer’s end-users (“End-Users”), and are strongly committed to making our practices regarding their personal data transparent and fair.

This Privacy Policy describes how we collect, store, use and disclose such personal data, our roles as “Data Controller” and “Data Processor” of such data (as well as any other personal data we might process on our Customers’ behalf). It applies whenever you visit, interact with us or otherwise access or use any of our Services.

For a simplified explanation of the data processing please use this summary at: https://contentsquare.com/privacy-center/aidodys-summary-of-data-processing/.

Specifically, this Privacy Policy describes our practices regarding:

  1. Data Collection
  2. Data Uses
  3. Data Location and Retention
  4. Data Sharing
  5. Cookies and Tracking Technologies
  6. Communications
  7. Data Security
  8. Data Subject Rights
  9. Children’s Privacy
  10. Data Controller/Processor
  11. Additional Notices

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services.

You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range of Services or with the best user experience when using our Services.

1. Data Collection

We collect Personal Data regarding our Visitors and Customers. We also collect Personal Data of other individuals, on our Customers’ behalf as they use our Services. Such data is typically collected and generated through the Visitor’s or Customer’s interaction with or use of our Site, Platform or Services, directly from such Visitor or Customer, from our Customers regarding their End-Users, or from the End-Users themselves.

In the below, we specify categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data”) we collect through our Services:

Data Collected or Generated

When you visit, interact with or use our Site or Platform, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third-party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).

Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser type, locale and language settings, the cookies and pixels installed on such device, session logging, heatmaps and scrolls, screen resolution, ISP, referring or exit pages, and date/time stamps, and the activity (clicks, browsing, zooms and other interactions) of Visitors and Customers in connection with our Site or Platform.

Data Received from Customers, Visitors or End Users

You may provide us with Personal Data such as your name, workplace and position, contact details (such as e-mail, phone and address), phone number, address and billing address, and account login credentials (usernames and hashed passwords) (collectively, “Account Data“), as well as any other data you choose to provide when you use our Platform, create a user account or contact us through our Site. To the extent that such data concerns a non-human entity (e.g. the bank account of a company or business), we will not regard it as “Personal Data” and this Privacy Policy shall not apply to it.

If you choose to provide us with any Personal Data regarding your End-Users, including without limitation information concerning End-User accessibility needs and disabilities (“End Users Data”), you must receive the End-User's explicit consent for such use and if such End-User is under the age of 16, an explicit parental consent. You are required to maintain a log of all such consent as evidence.

We do not collect any passwords entered to unlock the End-User's device.

Data Received from Third Parties

We may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from business partners or services provides, and through the use of tools and channels commonly used to connect between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.

2. Data Uses

We use Personal Data as necessary for the performance of our Site, Platform and Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and sales offerings, understanding how our Site, Platform and Services are used, optimizing our marketing and advertising services, customer service and support operations, and protecting and securing our Visitors, our Customers, ourselves and our Services.

Specifically, we use Personal Data for the following purposes:

  1. To authenticate the identity of our Customers Visitors and End-Users, and to allow them access to our Platform and Services;
  2. To facilitate, operate, and provide our Services;
  3. To provide our Customers, Visitors and End-Users with assistance and support;
  4. To manage and deliver advertisements more effectively, including contextual, behavioral, and interests-based advertising based on the Visitor’s or Customer’s activity, preferences or other data available to us or to our business partners, including for retargeting purposes;
  5. To create audience-related insights for optimizing ad performance;
  6. To contact our Visitors and Customers with general or personalized messages and communications, as further described under Section 6 below;
  7. to facilitate, sponsor and offer our Visitors and Customers certain events and promotions;
  8. To further develop, customize and improve the Services and general user experience, based on common or personal preferences, experiences and difficulties;
  9. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
  10. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
  11. To comply with any applicable laws and regulations.

3. Data Location and Retention

Data Location:

Your Personal Data (other than End User Data) may be maintained, processed and stored by our authorized affiliates and Service Providers (defined below) in the United States of America (U.S.), the State of Israel, France, UK and other jurisdictions, including the European Union, as necessary for the proper delivery of our Services, or as may be required by law.

AMW has offices in Israel, which offers an adequate level of protection for the Personal Data of EU Member State residents.

AMW may be required to transfer Personal Data (other than End User Data) to countries other than the country in which the data originated. Any such transfers shall be done in compliance with all applicable laws. While privacy laws may vary between jurisdictions, AMW and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Data Retention:

We retain Visitors’ and Customers’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship with them and to provide them with our Services.

We retain our Customer personnel’s Account Data in accordance with the instructions of their organization (our Customer), or for as long as their account is active, and we have not been notified otherwise, or as long as we consider necessary for the purposes described herein.

We will also retain your Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at [email protected].

4. Data Sharing

Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own, namely - hosting, data analytics, consulting, development, support, marketing and advertising, data and cyber security, payment processing, user engagement, e-mail distribution and monitoring, text messaging and session recording; as well as our business, legal and financial advisors (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

Currently, we use the Service Providers listed at https://contentsquare.com/privacy-center/subprocessors/ as sub-processors as part of the services provided to our customers in relating to any Personal Data (other than End-User Data). For the purpose of processing End-User Data we only use our data hosting provider OVH located in France as a Service Provider.

Sharing Personal Data with our Customers: We may share the Personal Data (including Account Data) of our Customer’s personnel, and Personal Data of our Customer’s End-Users,  with such Customer. AMW is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the “Data Controller” of such data (as further described in Section 10 below).

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of AMW, any of our Customers or their End-Users, or any members of the general public.

AMW Subsidiaries and Affiliated Companies: We may share Personal Data internally within AMW’s group of subsidiaries and affiliates for the purposes described in this Privacy Policy. In addition, should AMW or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of all or part of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, AMW may share your Personal Data in additional manners, such as pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

5. Cookies and Tracking Technologies

Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.

A cookie is a small text file that is placed, for example, to collect data about activity on our Site and Platform. Some cookies and other similar technologies serve to recall Personal Data, such as an IP address, that was previously indicated by the Visitor.

A list of the cookies we use can be found here: https://contentsquare.com/privacy-center/cookie-policy/

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser and recommend the use of cookies for an optimal user experience of our Services, most browsers allow you to control cookies, including whether to accept them or to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

6. Communications

Service Communications: We may contact Customers with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-reset notices, etc. We may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.

Notifications and Promotional Communications: We may also contact Visitors and Customers with promotional messages (such as newsletters, special offers and sales, new product announcements, etc.) or any other information we think they will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone or e-mail), through the Services, or through our marketing campaigns on any other sites.

If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to [email protected], changing your communications preferences in your account, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

7. Data Security

In order to protect your Personal Data held with us and our Service Providers, we use industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.

8. Data Subject Rights

If you wish to exercise your rights under any applicable law (including the EU General Data Protection Regulation (GDPR), such as the right to request access to, and rectification or erasure of your Personal Data held with AMW, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at [email protected].

Please note that once you contact us by e-mail regarding your data subject rights, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.

9. Children’s Privacy

OUR SERVICES ARE NOT DESIGNED TO ATTRACT CHILDREN UNDER THE AGE OF 16. ANY USE OF OUR SERVICES BY A CHILD UNDER THE AGE OF 16 MUST BE UNDER PARENTAL SUPERVISION AND EXPLICIT CONSENT. IF WE LEARN THAT A PERSON UNDER THE AGE OF 16 IS USING THE SERVICES WITHOUT PARENTAL SUPERVISION AND CONSENT, WE WILL PROHIBIT AND ATTEMPT TO BLOCK SUCH USE AND WILL MAKE REASONABLE EFFORTS TO PROMPTLY DELETE ANY PERSONAL DATA STORED WITH US WITH REGARD TO SUCH CHILD. IF YOU BELIEVE THAT WE MIGHT HAVE ANY SUCH DATA, PLEASE CONTACT US BY EMAIL AT [email protected].

10. Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller”, who determines the purposes and means of processing; and the “Data Processor”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

AMW is the “Data Controller” of its Visitors’, Customers’ and prospective Customers’ Personal Data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. AMW furthermore acts as Data Controller with regard to Account Data (excluding End-User Data) as submitted within the creation of a Customer profile or account on the Platform.

All personal data of an End-User shall be processed by AMW on behalf of our Customer, and may be shared with such Customer in accordance with this Privacy Policy and in accordance with their reasonable instructions, subject to our Terms of Service and other commercial agreements. Such Customer shall be deemed the “Data Controller” of its End-Users’ Personal Data and AMW will process such data on this Customer’s behalf, as its “Data Processor”. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers including without limitation, the requirement to provide notice and explicit consent if such is required, establishing a legal basis for processing, and responding to Data Subject Rights requests concerning the data they control.

If and End-User would like to make any requests or queries regarding Personal Data (see Section 8) we process on our Customer’s behalf, please contact such Customer directly. 

11. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Site and Platform. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Site and Platform may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website or service you visit. This Privacy Policy applies only to our Site, Platform and Services.

Questions, Concerns or Complaints: If you have any comments or questions about this Policy or if you have any concerns regarding your Personal Data, please contact AMW’s appointed DPO at [email protected].

Content Square SAS been designated as AMW’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. AMW may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an email to [email protected], or by postal mail to 5 boulevard de la Madeleine, 75001 Paris, France. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.

 

Effective Date: November 11, 2020